Around 100 Indian scientists back experts call for GM moratorium - India Environment Portal


11 déc. 2012 (il y a 8 années et 7 mois)

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Around 100 Indian scientists back experts call for GM

Thursday, 08 November 2012 12:27


Below is an open letter sent by n
early a hundred Indian scientists to the Supreme Court.
They write in support of the report of the Supreme Court's Technical Expert Committee (TEC)
calling for a 10 year moratorium on GM field trials while regulation is put in order.

The scientists come
from across India, and include Vice Chancellors and heads of various
scientific institutions and from various specializations, mostly related to the Life Sciences. Most
are (or were) associated with institutions connected to DARE (the Department of Agricul
Research And Education), CSIR (India's main R&D body for science and industry), or ICMR (the
Indian Council of Medical Research).

Open Letter from Indian Scientists to the Supreme Court


In the case of Aruna Rodrigues Vs. Union of India (Writ Petition (Civil) No. 260 of 2005)

November 8 2012

To: Hon'ble Justices Swatanter Kumar & S.J Mukhopadhyay

Supreme court of India

In the case of Aruna Rodrigues Vs. Union
of India

(Writ Petition (Civil) No. 260 of 2005)

Respected Sirs

Sub: Request to accept the interim report submitted by the court
appointed Technical Expert
Committee on the matter of field trials of GM crops and passing Orders on the same

Never in the h
istory of agricultural science had a technology been as controversial as Genetic
Engineering/Genetic modification of crops. The unpredictability and irreversible nature of Genetic
Modification (GM) as a living technology and the uncontrollability of Geneti
cally Modified (GM)
crops in the environment, coupled with scientific studies pointing at the potential risk to human
health and environment has resulted in a controversy across the world where questions around
the safety as well as the very need for intro
ducing such potentially risky organisms into our food
and farming system are being raised. Added to this is also the issue of corporate control of the
seeds, the most important input in agriculture, through this technology (rigid Intellectual Property
ts go hand in hand with this technology, given the ease with which tinkering at the level of
genes allows exclusive monopolistic rights to accrue to commercial entities; most such IPRs on
important components


processes of GM are already in the hands of

a handful of MNCs). In
the Indian context there are also concerns on massive displacement of farm labour if Herbicide
Tolerant GM crops are introduced. Given that the world is heavily tilted against the introduction of
the technology at this point of time
, with a majority of nations not opting for it, this also raises
serious trade security issues. All of these issues have been appropriately taken on board by the
TEC appointed by the Court.

The debate around GM crops in India started in late 1990s, around

the time when the field trials
of Bt cotton, the first and only GM crop to have been commercialised in our country, started. It
has grown in sum and substance over time with increasing scientific evidence on the adverse
impacts of GM crops, both potential

and real, emerging from within the country and outside. This
debate was most visible around Bt Brinjal, the first GM food crop that had reached commercial
approval stage in 2009 and has only got stronger ever since. It was the scientific concerns on the
pen releases of GM crops in general and Bt brinjal in particular from both eminent global and
Indian Scientists along with specific concerns on the inadequacy of the biosafety assessments for
GM crops

in our country and the inability of our regulatory sys
tem to do assessments and
monitoring of GM crops that finally led to the indefinite moratorium on the commercial release of
Bt Brinjal by the then Minister forEnvironment and Forests, Sri Jairam Ramesh. As said in the
moratorium order by him, that decision

was indeed “responsive to science and responsible to

The debate around Bt Brinjal as well as regular reports from around the country brought out by
investigations on field trials by certain state governments and civil society groups also opened

various issues with regard to any open release of GM crops including field trials.

It is necessary to look at the Technical Expert Committee’s recommendations in this context and
hence, our letter to the learned judges requesting you to fully apprecia
te the important and critical
recommendations of the Committee.

The fact that members of the TEC, who are eminent scientists in the fields of biodiversity,
nutrition science, toxicology, molecular biology etc. were jointly agreed upon by the petitioners
nd the respondent (Union of India) adds to its credibility. It is worthwhile to remember that safety
assessment is the matter in question (not the technologist’s job of creating a GMO) and the TEC
members are experts in that field. It is also noteworthy th
at the committee followed the Terms of
Refrence given to it by the Court which again was mutually agreed upon by both the parties in the
case. Added to this is the process through which the Committee has come to its set of
recommendations in this first rep
ort. The Committee has heard experts from all fields and interest
groups before arriving at its own conclusions. The Committee’s first report submitted to the
Hon’ble Court on the 7th of Oct 2012 has a thorough scientific assessment of the situation with
egard to various aspects

of GM

crops and its impact, both potential and actual, in the Indian
scenario. The report also does a comprehensive analysis of the regulatory system for any open
releases of GMOs in our country.

A lot of us in the scientific frat
ernity hence feel that this is a Committee which has credibility in its
composition, clarity in mandate and has taken up an elaborate and detailed process to come to
its conclusions. The conclusions and recommendations themselves are sound and scientific,
the reasoning in the report showcases.

It is no surprise that the Committee has come up with logical recommendations on the matter of
field trials of GM crops. To start with, the Committee’s stress on a precautionary approach
towards GMOs in which pote
ntial risks from such a novel technology and its living products need
to be identified and minimised, is a globally accepted norm. So it is completely logical when the
committee says that “a comprehensive assessment including the risk assesment should star
t with
a need assessment of the technology/product and should encompass a socio
economic analysis
which looks at impact of it on various sections of the society and economy”.

The need for overhauling the unsound regulatory system

Given the serious questi
ons raised on the design, capacity, intention and implementation of our
regulatory system (from the time field trials of Bt cotton started), the committee has looked at the
various aspects of the existing regime. This included the way approvals for field t
rials have been
given, when they are given and the way they have been conducted besides the manner in which
monitoring during and after the trials has happened in the country.

The glaring gaps in the regulatory system whether it is lack of rationale for d
eciding on a
particular crop or a trait, particular time or location, incorrect sequencing of biosafety assessment,
lack of comprehensive risk assessment including long term independent testing besides serious
issues of conflicts of interest are all real i
ssues that beg for an immediate correction. It is to be
remembered that unlike any regulatory mechanism in other sectors, regulation here deals with
living organisms that can contaminate, reproduce, spread and remain in the system for ever.
Hence utmost ca
re needs to be put in place in keeping them contained, until and unless, based
on a credible set of biosafety assessments, one can say with confidence that these novel
organisms do not pose a threat to health of humans or environment, now or in future.

e recommendations of the Committee not to permit event selection trials outside contained
conditions in greenhouses/glasshouses and the need to do a set of biosafety tests including food
safety and toxicity studies including sub
chronic feeding studies on
rodents along with molecular
characterisation of the Genetically Engineered plant, potential toxicity of the

novel protein and
potential allergenicity before open field trials merit attention and action from this Court.

The Committee also stresses the
need for independent, long
term, inter
generational feeding
studies to be conducted as part of the risk assessment as food is something that we consume
throughout our life and this would help in determining safety at various stages of development
from conception till end of the life cycle.

Delving further into the existing risk assessment procedure by looking at the Bt cotton biosafety
data, the Committee observed that there were instances where the number of samples were
lower than minimum prescr
ibed, thereby affecting the quality and sensitivity of the tests even
though such dossiers passed through the lax regulatory system. There were also cases of
significant differences in bioindicators like blood cell parameters, tissue and organ health and
ntegrity, milk yield between Bt and control samples. The fact that hundreds of hybrids of Bt cotton
have been approved by our regulator over the last 10 years with all these gaps in biosafety
assessment is a testament of the weakness in the review of biosa
fety data in the existing
regulatory regime. This had been pointed out many a times in the past including during the Bt
Brinjal consultations. The Committee is therefore correct in asking for a review of all biosafety
data both of approved GMOs as well as
ones in thepipeline.

This, when viewed along with the observation by the Expert Committee that there is a serious
issue of conflict of interest, completes the picture of an inadequate and unscientific regulatory
regime with clear vested interests. The iss
ue of conflict of interest had come into focus several
times in the past too, and has vitiated the entire regulatory process of GMOs in India, including
field trials. There have been instances of GM crop developers with their products in the pipeline
ng in both RCGM and GEAC, the two nodal agencies for risk assessment and approval for
open releases.

Besides putting in place a rigorous biosafety and risk assessment protocol, the TEC also felt that
there is a need for a wider set of representation to be

included in the regulatory system including
sociologists, agriculture economists, toxicologists, ecologists, plant breeders, representatives
from civil society and farmers’ unions to ensure a rigorous assessment of GMOs beyond just
biosafety checks.

ear Moratorium on Bt crops' field trials:

The TEC found serious flaws in the safety conclusions from the Bt cotton biosafety dossier as the
examples cited in the report indicate. Further, there are several scientific studies which point out
to the serious

problems with this technology for pest control, including pest resistance, changes in
pest ecology, impacts on soil biology etc. This is true with Bt cotton in India too, with pest
resistance as well as secondary pests being reflected including in officia
l records. Even after ten
years of Bt cotton, there has been no official review and the lack of post
marketing monitoring
was clearly noted by the TEC also. Issues around Bt GMOs’ safety to animal and human health
are unresolved. The unsustainability of th
e science of Bt technology for pest management is well
noted in other processes of inquiry too. The then Minister for Environment & Forests is reported
to have quipped that “Bt is a solution looking for a problem,” given that highly successful


chemicalpesticides and Bt crops exist for crop pest management, which are
controlled, nature
friendly, safe and affordable. The Bt brinjal biosafety dossier analysed
by eminent scientists also pointed to the inadequacies in the safety conclusion
s of that Bt product
which began with something as basic as incorrect molecular characterization! It is all in all very
appropriate that the TEC had called for a moratorium on Bt crops’ field trials.

Protecting Centres of Origin and Diversity:

The TEC’s
recommendation not to permit field trials of those crops for which India is a Centre of
Origin/Diversity is a matter that needs urgent attention. It is a globally accepted norm that regions
which are rich genetic pools in the megabiodiversity countries lik
e India need to be protected and
enriched. This is essential both for the survival of communities who are dependent on them for
their livelihoods and also for the growth of science. GMOs have been acknowledged as one of
the main threats to this biodiversit
y in global treaties like the Convention

on Biological Diversity
(CBD) which has stressed on the need for precaution when dealing with GMOs. Given that India
hosted the CBD last month and that we are a presiding nation for the next two years, we should
ke a leadership role in protecting biodiversity from potential threats. It should not be forgotten
that we have only seen the ‘tip of the iceberg’ of the wild genepool that has been the basis of our
agriculturalbreeding and development. It will be an injus
tice to our future generations if we
promote its destruction without even getting a chance to unravel and utilise such diversity

Moratorium until a comprehensive independent review of Herbicide Tolerant GM crops:

The other major recommendati
on is the need to revisit our policy of permitting any open releases
of herbicide tolerant GM crops due to various scientific concerns emerging on the impact of such
GM crops and the related usage of herbicides, on human health and environment. This is mor
so in a country like ours where farm sizes are small and application of herbicides cannot be
restricted to one’s boundaries. There is also a serious concern on the socioeconomic impact of
these crops as they are being brought in to replace farm labour. I
t is important to remind
ourselves that we are still an agrarian country with majority of our population dependent on
agriculture. More than 80 percentage of our farmers are small, marginal and landless and depend
on agricultural work like weeding for sust
enance. So any technology that takes away such
employment chances especially for rural women will have serious socioeconomic repercussions.
In fact this was pointed out by the Taskforce on


Biotechnology led by Dr M.S Swaminathan set up by the
government way back in 2003.

Task Force also recommended the avoidance of this technology in India.

TEC recommendations reinforce other such in
depth inquiry processes in India:

The TEC interim report comes after the report on GM food crops by the
Parliamentary Standing
Committee on Agriculture on 9th of August, 2012. The Standing Committee, comprising of 31

Parliamentarians from across party lines including those from the ruling coalition, did widespread
consultations over two and half years wit
h diverse experts and stakeholders before coming to the
conclusion that the country should not embrace GM crops in a haste and that there should be a
based approach towards GM crops. Identifying the inherent risks of GM crops to
human health,

that of livestock and biodiversity and the inadequacy of the regulatory system to
conduct field trials, the Parliamentary Committee had recommended for a stopping of all field

Several recommendations of the TEC also find resonance in the report o
f the Task Force on
Agricultural Biotechnology, set up by the Government of India, whose report was accepted in
2004. Similarly, the Bt brinjal public debate and the subsequent moratorium order also reflected
the main concerns and recommendations of this T

It is to be remembered that the scientific debate around environmental release of GMOs is
happening around the globe and a majority of countries have decided to stop the open releases
of them until the answers to various concerns have been arrived at.

Any haste in doing this will
not only impact the society and the environment but also impede scientific progress. Already
there is a growing concern amongst the scientific community that Genetic Engineering and GMOs
are getting undue attention where as ot
her non controversial and sustainable technologies like
agro ecology are getting ignored in the process. Within the vast area of biotechnology, there are
many safer and proven tools which need to be harnessed better.

All open
air field trials are delibera
te releases of untested organisms:

The TEC was absolutely right in recognizing that all field trials are essentially deliberate open air
releases of untested and unknown organisms and has correctly given its recommendations based
on such an analysis (the
issue of open air releases gains more significance in the context of
repeated violations of biosafety norms and Rules, with impunity)

the fact that need assessment
should take place before clearing all applications, that certain traits and crops should b
e avoided,
that biosafety testing should precede open air testing at least to some extent, that regulation
should be devoid of conflict of interest, that safety assessment should be comprehensive with
more tests including long term and inter
that monitoring and liability regimes have to
be put into place, that biosafety review capabilities have to be built etc. are all welcome
suggestions based on the legally and scientifically valid Precautionary Principle.

WE would like to specifically poin
t out that many who argue that ‘America has allowed GM crops
on a large scale and so should we’ are fundamentally wrong in making a comparison with

neither our food production nor our food consumption patterns are comparable, not to
mention the s
economic conditions of our producers and consumers. Further, the American
regulatory system is very lax and does not even have any segregation or labeling systems. There
are no studies that indicate that some of the increasing health problems in the U
SA are not
connected to GMOs. Chemical use in agriculture has been increasing there, while superweeds
and superpests are a major issue that farmers are contending with. Some of the biggest losses of
the biotech industry are from the US due to contamination

from field trials. America is also facing
threat to its agri
trade security by adopting transgenics. Any comparison with America is

As part of the scientific community in India, we hope that the Hon’ble Court will not overlook
important analys
is and recommendations of the TEC,

and would take a prudent, science
and precautionary approach. We sincerely hope that the learned judges will accept the
recommendations of the court appointed TEC in toto. This is important for upholding the scient
temper in India and most importantly not losing vision of humanity while translating science into

The Signatories:

Padma Bhushan Dr Pushpa Bhargava, Hon Distinguished Professor, School of Life Sciences,
JNIAS, Founder
Director of Centr
e for Cellular & Molecular Biology (CCMB)

Supreme Court
appointed Observer in India's apex regulatory body for GMOs (GEAC)

Dr A Biju Kumar, Associate Professor and Head, Dept. of Aquatic Biology & Fisheries, University
of Kerala, Thiruvananthapuram, Ker

Dr A K Yadav, Rajendra Agri University, Pusa, Bihar

Dr Alok Mukhopadhyay, Managing Trustee, Health for the Millions

Dr Amol Patwardhan, Entomology expert, Prof of Zoology, Thane

Dr Anbazhagan Kolandaswamy, Molecular Biologist, Post doctoral Researc
h engineer on human
immune cells, France

Dr Anupam Paul, Agriculture Scientist, State Agricultural Technologists' Service Association,
West Bengal

Dr Anurag Goel, Agriculture Scientist, WAPRED

Dr Aruna Chakraborty, Consultant Biochemist, BN Hospital, Ko

Dr Atul Mehta, Plant Breeder, Anand Agriculture University

Dr B Chaudhary, Former Director Research, RAU, PUSA.

Dr B N Viswanath, Agricultural Entomologist, Consultant in Organic Farming, Bangalore

Dr C T S Nair, Former Chief Economist (Forestry
Dept), Food and Agriculture Organisation (FAO)
and Former, Exec
Vice President, Kerala State Science Technology and Environment Council

Dr Chandrakant Pandav, Professor & Head, Centre for Community Medicine, AIIMS

Dr D G Bhapkar, Retd. Director of Resear
ch, Mahatma Phule Krishi Vidyapeeth, Rahuri,

Dr Debal Deb, Centre for Inter
disciplinary Studies, Odisha.

Dr Dhanya Bhaskaran, Asst Professor (Environmental Science), University of Agriculture
Sciences, Raichur

Dr Dileep Kumar R, Post Doctor
al Fellow, Institute of Venom Science, Centre for Computational
Biology and Bio informatics, University of Kerala,Thiruvananthapuram

Dr Dinesh Abrol, Scientist, NISTADS

Dr E Kunhikrishnan, Professor, Dept of Zoology, Kerala University

Dr Elizabeth Josep
h, Retd. Scientist (Fisheries), Kerala Agriculture University

Dr G S Kaushal, Retd. Director Agriculture, Govt of MP

Dr Goldin Quadros, Senior Scientist, Wetland Ecology Division, Salim Ali Centre for Ornithology
and Natural History, Coimbatore

Dr H R P
rakash, Retd. Soil Scientist, Department of Agriculture, Bangalore

Dr Hrideek T.K, Scientist, Genetics and Tree Breeding, Kerala Forest Research Institute

Dr J K Roy, Joint Director (Retd), Central Rice Research Institute, Cuttack.

Dr Jagdish Parikh, Me
dical Scientist, Ex
Deputy Director, National Institute for Occupational
Health (NIOH)

Dr Johannas Manjrekar, Associate Professor, Microbiology Department, MS University

Dr K V Sankaran, Former Director, Kerala Forest Research Institue, Peechi, Kerala

r K M Shyamprasad: Chancellor, Martin Luther Christian University, Shillong, India

Dr Lalitha Vijayan, Sr Scientist, Salim Ali Foundation and formerly, Acting Director and Senior
Principal Scientist, Salim Ali Centre for Ornithology and Natural Studies (S
ACON), Coimbatore

Dr Latha Anantha, Director, River Research Centre, Thrissur, Kerala

Dr M Ganapathy, Executive Director, Public Health Resource Network, New Delhi

Dr M S Chari, Former Director, CTRI (Managing Trustee, CSA, Hyderebad)

Dr M Seenath, Pro
fessor, Zoology, University of Calicut

Dr Madhuri Pejavar, Zoologist, Principal of B. N. Bandorkar College, Thane

Dr Manas Pandit, Associate Professor, Dept of Vegetable Crops, Bidhan Chandra Krishi
Viswavidyalaya, West Bengal

Dr Mangal Borkar, Prof. of

Botany, Thane

Dr Meenakshi Gautham, Public Health Specialist

Dr Mira Shiva, Coordinator, Initiative for Health & Equity in Society

Dr Mogalli Ganesh, Hampi University, Karnataka

Dr N Paul Sunder Singh, Karunalaya Social Service Society, Chennai

Dr Na
ndita Shah, Medical Doctor, Homeopath,


Dr Nimisha Shukla, Professor, Gujarat Vidyapeeth

Dr Om Rupela, Soil Microbiology, Formerly with ICRISAT

Dr P K Prasadan, Botanist, University of Calicut

Dr Partha Chakraborty, Scientist, CSIR, IICB

Dr Par
tha Sarathi Ray Asst Prof, IISER, Kolkata

Dr Ponnammal Natarajan, Retd Dean, Anna University

Dr Priti Joshi, Botany, National Organisation for Community Welfare, Wardha

Dr R K P Singh, ICRA, Patna

Dr Ramanjaneyelu GV, Executive Director, Centre for Sus
tainable Agriculture, Hyderabad

Dr Ravi Narayan, Community Health Advisor, SOCHARA

Dr Rudraradhya, Retd Senior Plant Breeder, University of Agricultural Sciences, Bangalore

Dr S Jeevananda Reddy, Former Chief Technical Advisor

WMO/UN & Expert


Dr Sagari Ramdas, Veterinary scientist & Director, Anthra

Dr Sant Kunmar Gautam, Plant Breeder, Delhi.

Dr Santhi, Ecologist, Trivandrum

Dr Santosh M. Tungare, Environmental Chemistry, TechnoGreen Environment Solutions, Pune

Dr Sasikumar Menon,

t in Medicinal Plants & Species Conservation,

Univ of Mumbai

Dr Siddhartha Gupta, Pathologist, CPT Hospital

Dr Sivaraman, Siddhha Expert, AROGYA

Dr Sujatha Byravan, PhD, Scientist based in Chennai, Former President, Council for Responsible
Genetics, Ca
mbridge, Massachusetts

Dr Sujatha Lakhani, Agriculture Scientist, WAPRED

Dr Sultan Ismail, Soil Biologist & Ecologist, Tamilnadu.

Dr Sunita Rajadhyaksha, Pharmacology, Mumbai University

Dr Sunita Rao, Ecologist, Vanastree and ATREE (Ashoka Trust for Re
search in Ecology and the
Environment), Sirsi

Dr T A V S Raghunath, Entomologist, Centre for Sustainable Agriculture, Hyderabad

Dr T K Maqbool, Professor in Zoology, Calicut University

Dr T S Channesh, Agriculture Scientist, UAS Bangalore

Dr Tarak Kate

Organic Farmers' Association of India, Wardha

Dr Thelma Narayan, Director, SOCHARA School of Public Health, Equity and Action

Dr Thomas Varghese, Soil Scientist (Retd.), Kerala Agriculture University, Ex
Chairman, Kerala
State Agriculture Prices Boa

Dr Tushar Chakraborty, Principal Scientist, CSIR, IICB, Kolkata

Dr TV Sajeev, Scientist (Entomologist), Forest Health, Kerala Forest Research Institute

Dr Usha Balram, Professor and Head (Retd.), Dept of Zoology, All Saints College, Trivandrum,

Dr V S Vijayan, Chairman, Salim Ali Foundation, Former Chairman, Kerala State Biodiversity
Board; Former and Founder Director, Salim Ali Centre for Ornithology and Natural Studies
(SACON, a Centre of Excellence of the Govt of India)

Dr Vanaja Ramprasad
, Founding member of Foundation for Genetic resources, Energy, Ecology
and Nutrition ( Green Foundation), Bangalore, Karnataka

Dr Vijaya Venkat, Founder of The Health Awareness Centre (THAC), Mumbai, Maharashtra

Prof A Prasada Rao, Retd Professor, Achary
a N G Ranga Agricultural University (ANGRAU)

Prof B N Reddy, Professor of Botany, Osmania University

Prof Jalapati Rao, Professor in Agronomy and Registrar (Retd), ANGR Agricultural University,

Prof K R Chowdhary, Retd Professor, Acharya N G R
anga Agricultural University, Hyderabad

Prof Lalit M Nath, Retd Professor & Dean, Centre for Community Medicine, AIIMS

Prof M K Prasad, Ex
VC, Calicut University, Ex
Chairman, Information Kerala Mission

Prof Mahadeb Pramanik, Dept of Agronomy, Bidha
n Chandra Krishi Viswavidyalaya, WB

Prof N Venugopala Rao, Retd Professor of Entomology, ANGRAU, Andhra Pradesh

Prof R N Basu, Retd. Vice Chancellor, Kolkata University

Prof S Krishnaswamy, Structural Biologist and Former President, Tamil Nadu Science F

Prof Satya Prasad, Professor of Botany, Osmania University, Andhra Pradesh.

Prof Shree Ram Padmadeo, Convener, Department of Biotechnology, Patna University, Patna.

Prof Sudarshan Iyengar, Vice Chancellor, Gujarat Vidyapeeth

Prof T K Bose, Former
Research, Bidhan Chandra Krishi Viswavidyalaya, WB

Prof Veena Shatrughna, Deputy Director (Retd), National Institute of Nutrition, Hyderabad