GM mustard, if approved, will open the floodgates for other such crops making India one of the largest users of GM crops in the world. Given that its agriculture is largely in the hands of MNCs, India will end up bartering its freedom for the benefit of a few and the misery of the rest.
Genetic engineering (or modification) technology is one of the most powerful technologies invented in the 20th century. It has made drugs that were not available earlier, such as human insulin, affordable. But genetically modified (GM) crops pose substantial risks to human, animal and plant health, and to the environment and biodiversity. These risks are ignored by governments, especially by the United States (US) government, as the technology can also benefit multinational corporations (MNCs) and help acquire control of another country’s agriculture. The Indian government’s support to GM-mustard ignores the scientific strength of the opposition to it and merely makes a show of following prescribed rules and procedures.
Whosoever controls food production around the world effectively controls the world. To do so, one only needs to control production of seeds and agrochemicals. For the latter, the system of intellectual property rights (IPRs) applicable to other chemical entities, which has been in place for decades, is enough. To control seed production, genetic engineering or genetic modification has been touted as the best possible approach under the garb of providing an advantage that no other technology would appear to provide.
It is in this context that GM-mustard, which is up for the Government of India’s approval for commercial release, acquires special significance. An approval of GM-mustard—(making it the first GM food crop to be approved in India) would open the window for other GM food crops to rush in, eventually transferring virtually our entire food production to the largely US-controlled MNCs that have the IPR for GM seeds and with whom we would never be able to compete.
This is not a critique of the GM technology. It involves altering the genetic make up of a living organism—a microorganism, a plant or an animal—in such a way that it (and its progeny) is able to perform a function that it was unable to perform earlier. Thus, normally, a bacterium or yeast is incapable of making human insulin, but a GM-bacterium or a GM-yeast in which the gene for human insulin has been placed and made to work—through the process of genetic engineering—would produce human insulin in commercially exploitable quantities.
There is, therefore, no problem in encouraging the use of this technology for production of drugs such as human insulin or human erythropoietin—both widely used—as we can simply switch off the production as and when we find that the original objective is not being served. But using this technology for producing a GM plant is something else altogether. For, once you release a plant in the environment, it is virtually impossible to recall it, something you may want to do, if it turns out to be deleterious to human, animal or plant health, or harmful to the environment or biodiversity. Water hyacinth and parthenium, which probably came with the PL-480 wheat in the late 1950s and early 1960s are good examples. Water hyacinth has choked our waterbodies on innumerable occasions, and parthenium (popularly known as Congress grass) has led to allergy in a large number of cases all over the country.
India has been, perhaps, the only developing country which has been aware of the possible benefits and risks of genetically modified organisms (GMOs) from the time this technology, for which Paul Berg shared the 1980 Nobel Prize for Chemistry, was developed. The term “genetic engineering” was used for the first time in India (and, perhaps, for the first time in the modern context, anywhere) in a syndicated article by me which was also published in The Motherland of 11 March 1973. I used the possible potential of this technology as an argument for setting up one of India’s most prestigious laboratories, the Centre for Cellular and Molecular Biology (CCMB) at Hyderabad in 1977. I also chaired the first national committee on genetic engineering and molecular biology in the 1980s.
K S N Prasad of CCMB was the first in the country to be trained in this technology. Later, he produced India’s first GM product—Shanvac-B, Shantha Biotechnics’ Hepatitis B-Vaccine in CCMB. This brought down the price of the vaccine more than 50-fold.
Bt-cotton and Bt-brinjal
Bt-cotton which contains a gene for an insecticidal protein from bacillus thuringiensis, a soil bacterium, was the first and the last GM plant released in India for commercial use. It was released in 2002 at a time when civil society was unaware of the implications. The Department of Biotechnology (DBT) (I had a role in the setting up DBT and I was a member of the first Scientific Advisory Committee) was a key player in the release of Bt-cotton. Unfortunately, I was unaware of its release.
In this context, it is important to note that no GM plant has been released in India for commercial cultivation in the last 14 years. Civil society groups have alleged that both the Review Committee on Genetic Modification (RCGM) of the DBT and the Genetic Engineering Approval Committee (GEAC) of the Ministry of Environment, Forest and Climate Change (MoEFCC), the two key players in approving open (commercial) release of a GMO, have many members that have a conflict of interest.
It is noteworthy that the GEAC had cleared the commercial release of Bt-brinjal developed by Mahyco–Monsanto Biotech, in its meeting on 14 October 2009, but the then Minister for Environment and Forests, Jairam Ramesh, deferred any decision on its release for the next three to four months to allow time for civil society, including affected groups such as farmers, and interested scientists from India and abroad, to go through the biosafety dossier presented to the GEAC by its promoters (Mahyco–Monsanto) and to hold a public consultation in major cities.
This resulted in the announcement of an indefinite moratorium on Bt-brinjal’s open release. Ramesh’s statement (with appendices) issued on this occasion (9 February 2010) is one of the finest documents issued by any government in independent India. It is noteworthy that he had the courage to do so in spite of the immense pressure on him by the then Prime Minister Manmohan Singh and his government to clear the open release of Bt-brinjal. Ramesh paid the price for being scientific, fair and courageous: he was transferred! It is well-known that the United Progressive Alliance government was under pressure from the US government to have Bt-brinjal cleared.
Neglected Biosafety Measures
I emphasise here four more points that argue against the open release of GM-crops, without adequate thought and proper testing for biosafety which no approved GM crop has gone through anywhere.
(i) Success of Bt-cotton is overemphasised. First, Bt-cotton has failed in rain-fed areas which represent two-thirds of cotton growing areas in India; it has succeeded only in irrigated areas. Second, when talking of success of Bt-cotton, a hybrid is being compared with a variety. Third, similar yields as with Bt-cotton have been obtained with non-Bt-cotton grown under specified conditions. Fourth, in several places such as Gujarat, pests have developed resistance to Bt-protein. Fifth, in Rajasthan and some places in Punjab, other harmful insects such as mealy bug on which Bt-protein does not work, have appeared. Sixth, several thousand cattle died in Andhra Pradesh, after foraging on remnants of Bt-cotton plants. And lastly, a number of Bt-cotton farmers committed suicide because of bad yields and having to pay a high price for the seeds.
(ii) Proponents of the GM crops say that GM food has been consumed in the US now for 16 years and not shown any adverse impact. The fact is that concurrently with the consumption of such food in the US, there has been an increase in the incidence of gastrointestinal tract disorders and cases of allergy. Although it does not establish a cause and effect relationship, it certainly makes it possible—even probable in view of some 30-odd reliable animal studies based on GM food and that have been published in respectable journals.
(iii) The GM crops and/or food are used only in some 20 countries (out of nearly 200) around the world, the US accounting for two-thirds of the use—and Canada, Argentina and Brazil being the other main ones.
(iv) An appropriate and adequate testing of a GM plant has never been done anywhere in the world before its open release. For example, it has not been tested for chronic toxicity before its release in the environment. Where other highly responsible scientists have done this testing and showed notable adverse effects of genetic modification, their results have been mocked by those who supported the release.
It is against this background that the case of GM-mustard developed by a team led by Deepak Pental, former Vice Chancellor of the Delhi University, should be looked at. I consider Pental to be a good scientist though, I believe, he has slipped up in this case. Following my request to the GEAC, he sent me eight volumes (totalling 3,126 pages) of his biosafety data on GM-mustard and I have kept my boy-scout promise to him that I shall not share it with anyone else. But let me get back to events as they occurred, in sequence.
First, I do not understand on what basis the RCGM, to which Pental’s application seeking open release was first submitted in accordance with the law of the country, cleared the GM-mustard from the biosafety point of view and forwarded the application to the GEAC.
From here onwards—as all the evidence suggests—there have been two streams of operation. In the first stream, the Prime Minister, the environment minister, the chairperson of the GEAC, and all others involved officially, had already taken a decision to approve the GM-mustard, irrespective of any other consideration and in defiance of all scientific evidence that may be against it. So, there have been newspaper reports from time to time saying that the GEAC has approved Pental’s GM-mustard when it actually had not. The MoEFCC—and it goes to the credit of the ministry—at least on one occasion, contradicted such a press report, but such reports continued to appear in one form or another. For example, the MoEFCC minister Anil Madhav Dave, said, “you will get to know about our view on GM-mustard very soon” (Das and Bharadwaj 2016). The report continues, Environment Minister, Anil Madhav Dave, said “India would also come up with other GM food as its population increases and available land shrinks.” And, “Allowing GM-mustard is seen as critical to Prime Minister Narendra Modi’s goal of attaining self-sufficiency in edible oil.” Practically speaking, attaining self-sufficiency in edible oil cannot bear any direct relationship to GM-mustard, even if it produces 30% more oil, as mentioned in Reuter’s report.
Even though the Bharatiya Janata Party (BJP) government has been hell-bent on permitting the open release of GM-mustard—if only to please the US and the US-based MNCs involved—it has wisely seen no harm in trying to appear fair.
Conflict of Interest
The GEAC is aware that many of its “reputed” members have a conflict of interest—like the RCGM—which is to the advantage of the government. So a subcommittee of seven members—with at least three having a clear conflict of interest—chaired by the vice-chairman of the GEAC, is appointed to look at Pental’s GM-mustard data and conclusions. The subcommittee, as expected, clears the GM-mustard unconditionally after some four meetings lasting at most few hours each, during which the subcommittee is supposed to have had a careful look at least 3,126 pages of data, experimental details and related material. So, as far as most of the members of GEAC are concerned, the entire data has been carefully looked at by an expert committee, and the committee has declared Pental’s GM-mustard safe for human and animal health and for environment and biodiversity. What else can anyone want to check or comment upon?
But, in our government’s reckoning, people can be contrary at times for no reason! Serious and knowledgeable civil society representatives, led by Kavitha Kuruganti of the Alliance for Sustainable and Holistic Agriculture (ASHA), who were well aware of the functioning of both the RCGM and GEAC, know from past experience what the report of the subcommittee would say and were, therefore, far from satisfied. To quell their fears and make them feel that their views and concerns would be taken care of by the subcommittee and GEAC, the following eight forming the group1 (which we would call KKG) led by Kavitha Kuruganti were invited to make a presentation of their concerns, queries and questions, over two-hours—the period they had asked for—at a special meeting of the GEAC on 18 July convened at the instance of the chairperson of GEAC, Amita Prasad, additional secretary in the MoEFCC.
In my opinion, the KKG collectively did an incredible job of scientific analysis on the basis of the scanty information on GM-mustard available to it. The group had almost certainly spent, individually and collectively, much more time on preparing its comments than the subcommittee probably did on looking at and analysing the entire data. There were no comments by anyone after the presentation on 18 July as, perhaps, most members of the GEAC knew that no substantial action was likely to be taken on the comments of the KKG and the decision had already been taken by the government to approve the GM-mustard. What happened subsequently confirmed that the 18 July meeting was meant only to satisfy what has been termed as the “anti-GM lobby.” It was a political—and not a scientific—move to neutralise what has been perceived by the pro-GM MoEFCC as the anti-GM-mustard lobby.
At the next, 130th meeting of the GEAC on 11 August (a one-page note ostensibly summarising what was said by the KKG on 18 July, prepared by S R Rao of DBT, was circulated to the GEAC members, not for discussion, but for information. It was supposed to be discussed by the subcommittee.
The Note and Follow-up
I found that Rao’s note had 12 points—all inadequately covered—with more than 90% of the major and important issues raised by the KKG on the 18 July, totally ignored. Therefore, on the 24 August, I sent the following letter to Amita Prasad.
Dear Dr Prasad,
At the last (130th) GEAC meeting held on 11th August 2016, Dr S R Rao of the Department of Biotechnology gave us a list of 12 issues (Annexure 1) that, in his opinion, were presented by the team led by Ms Kavitha Kuruganti during the two-hour special meeting of GEAC on 18th July 2016, regarding GM-mustard.,
While I greatly appreciated Dr Rao’s efforts to summarise the two-hour presentation in less than a page, I felt that Dr Rao had not covered all the important implications of the presentation by the above team, and that many important points mentioned by the team were not included in the 12 points listed by Dr S R Rao which are recalled in Annexure 1. I, therefore, went through the material given to the members of the GEAC by Ms Kavitha Kuruganti, and also had a consultation with her and Shri Kapil Shah who was a member of her team. With the help of Ms. Kavitha Kuruganti and Shri Kapil Shah, I prepared two documents. The first one (Annexure 2) is a point-by-point commentary on the 12-point summary of Dr S R Rao. The second one (Annexure 3) is a list of important points presented by Ms. Kavitha Kuruganti’s team but not covered at all by Dr Rao.
would appreciate it very much if the GEAC office will consider circulating this letter to all the members of the GEAC.
As the above letter was not circulated by Prasad to members of the GEAC, I did so on 6 September, following which, on 7 September, it was also circulated to the GEAC members by the GEAC office, apparently at the instructions of Prasad. It is interesting that no member of the GEAC has responded to it till now. And, as predicted, no action whatsoever has been taken on any of serious points raised by the KKG.
At the meeting of the GEAC held on 11 August, a brief summary of what was purported to be the proceedings of the subcommittee—that is, an assessment of Pental’s GM-mustard for food and environment safety—was circulated. The five-page summary was titled, “Report on Environmental Release of Genetically Engineered Mustard Hybrid DMH-11 and Use of Parental Events for Development of New Generation Hybrids.” It is important to note that only a summary—and not the entire document—was circulated, and even then, no time was allotted for reading or discussing it, at the meeting of the GEAC.
I assumed that the full report of the sub-committee will be made available to the members of GEAC later, and that there would be enough time available for the members to go through it and then discuss it. This never happened, just as no action was taken on the points raised by the KKG at the special meeting of the GEAC on 18 July, that were also listed in my letter of 23 August to the chairperson of GEAC. After all, the decision to permit open release of GM-mustard had already been taken.
Report on Ministry’s Website
Since the environmental minister had reassured Kuruganti and her colleagues at an earlier meeting that the views of civil society would be sought before a final decision was taken about the open release of GM-mustard, the ministry put on its website a document titled “Assessment of Food and Environmental Safety (AFES) for Environmental Release of Genetically Engineered Mustard (Brassica guncea) hybrid DMH-11 and use of parental events (Varuna bn3.6 and EH2 modbs 2.99) for development of new generation hybrids.” This was supposed to be the report of the subcommittee, a summary of which was circulated at the 130th meeting of the GEAC on 11 August. It was very embarrassing for me to say as a nominee of the Supreme Court on GEAC that I had not seen the report when I was asked by the media on 5 and 6 September about my opinion of the report. As it was supposed to be the report of a subcommittee appointed by the GEAC, the members of GEAC had the first right to see and comment on it.
Incidentally, it seems quite possible—even probable—that the subcommittee did not write the report. Such a report would generally have the names of its members, the dates on which the meetings of the subcommittee were held, acknowledgement of those who helped, and signatures of the subcommittee members. The report has none of these; it is not even mentioned as to whose report it is! As stated earlier, the subcommittee had just four meetings. For a seven-member group to go through at least 3,126 pages of data contained in eight large volumes and write a 133 page report complete with references, in such a short time, is a virtually impossible task.
It is, therefore likely that the report has been largely written by Pental or someone from the Department of Biotechnology or Environment! It is also quite possible that the report does not represent the views of all the members of the subcommittee. It may have been written by one, pro-GM and pro-government member of the subcommittee; therefore, it does not have the names. As the decision to approve the GM-mustard was taken before the subcommittee was appointed, nothing that would argue against this decision could be permitted by the government. As already mentioned, a number of members of GEAC (thus of the subcommittee) have a conflict of interest, and others (exceptions granted) may not, for various reasons, want to oppose the government.
It is interesting that the minutes of the 130th meeting of GEAC held on 11 August, say, “GEAC reviewed this (the AFES report that is on the MoEFCC’s website) and suggested that the report may be placed on the website for a period of 30 days.”
What has been particularly alarming is the impunity with which the MoEFCC has defied the orders of the Central Information Commission to make all the biosafety data public—so much so that the Information Commissioner, Sridhar Acharyulu, had to send a show cause notice to the MoEFCC on 12 August for not following the orders of the commission. So the data, which alone in most cases can settle scientific or technical issues, has not been put in the public domain. The notice on the ministry’s website says that if you want to have a look at the data you may call (but no telephone number is given) and, by prior appointment, visit the ministry where you may have a look at the data, but not copy it. Imagine anyone from outside Delhi spending time and money to come to Delhi to get the information on such conditions. Further, the submission to the MoEFCC in response to what has been put on the website must follow a format that has been prescribed. You may not ask any questions outside of that format and outside the areas defined by the report. And the time given was one month (until 5 October 2016).
I have submitted some 25 questions and queries in response to the report on the ministry’s website. I do not believe anyone (including me) will get a reply. At the end of a reasonable period after 5 October 2016, a statement would be issued by the ministry that the subcommittee and GEAC have carefully looked at all the comments, queries and questions, and recommends that permission be granted for open (environmental) release of Pental’s GM-mustard. Is this not a sign of a dictatorial regime? What may happen after that, I dare say, is unpredictable. Many states like Kerala, Tamil Nadu, Uttarakhand, Rajasthan, Madhya Pradesh, Chhattisgarh, Bihar, West Bengal, Odisha, Andhra Pradesh and Telangana have said that they will not permit GM-crops. Further, the BJP is being constantly reminded that in its election manifesto, it had aligned itself strongly with the anti-GMO lobby. And to throw more spanners in the work, an influential farmers union affiliated to the Rashtriya Swayamsevak Sangh has been opposing GM-crops for many years.
What is sure is that if GM-mustard is approved, and the approval becomes effective, the floodgates for other GM-crops would open and India may emerge as the largest user of GM-crops in the world in the next 10 to 12 years with its agriculture largely in the hands of multinational seed and agrochemical producing companies—that is, by proxy, in the hands of the US. We would have then bartered our freedom for advantage to a few and misery for the rest.
In a way, GM-mustard holds the key to our future—unless all concerned directly such as farmers, come together and lodge a massive protest as happened with Bt brinjal in 2009–10.
Pushpa M Bhargava (email@example.com)is a nominee of the Supreme Court on the Genetic Engineering Appraisal Committee of the Ministry of Environment, Forest and Climate Change and currently chairman of the Southern Regional Centre of the Council for Social Development.
1 (1) Kavitha Kuruganti, (2) Rajesh Krishnan (co-convener, coalition for a GM-free India, and an organic farmer), (3) Debal Deb (ecologist), (4) Sharad Pawar (Breeder and Fellow, National Academy of Agricultural Sciences), (5) Kapil Shah (National Secretary, Organic Farming Association of India), (6) Rampal Jat (president, Kisan Mahapanchayat), (7) Yudhvir Singh (convener, Indian Coordination Committee of Farmers’ Movements), and (8) Ananthoo (Safe Food Alliance).
Bhargava, P M (1973): “Fantastic Strides in Biochemistry,” The Motherland, p 5, 11 March, New Delhi.
Das, N Krishna and Mayank Bharadwaj (2016): “Interview—India Soon to Make GM Mustard Stance Public, Develop More Varieties,” Reuters, 2 September, http://af.reuters.com/article/commoditiesNews/idAFL3N1BD2KJ.
– See more at: http://www.epw.in/journal/2016/44-45/insight/genetically-modified-mustard-and-indias-future.html#sthash.QObZ0uN0.dpuf