Genetically Engineered Golden Rice

To:

Shri A.K. Jain,

Chairperson,

Genetic Engineering Appraisal Committee,

Ministry of Environment, Forest & Climate Change,

Indira Paryavaran Bhavan, Jor Bagh, New Delhi.

Date – 19th October 2021 

Dear Sir,

Its with great shock and concern that we learn about the recent discovery of Genetically modified rice in a consignment that we had exported to EU countries. Rice being one of the biggest agricultural exports, such an incident will dearly cost us. Given the fact that our country exported 65000 crore worth rice in the last financial year 2020-21, such loss of reputation would in turn also affect the market prices that our farmers earn because of higher values realised for agri commodities  from the export.

Background

Earlier this year in June 2021 https://webgate.ec.europa.eu/rasff-window/screen/notification/484015 500 tonnes of genetically modified rice from India was discovered in France.

The article https://gmwatch.org/en/news/latest-news/19879  mentions that the rice flour made from the GM broken rice was marketed in several European countries (Andorra, Austria, Belgium, Czech Republic, Denmark, France, Germany, Greece, Italy, Ireland, Netherlands, Poland, Romania, Spain, United Kingdom and Ukraine), as well as in the United States, Iraq, Mauritius, Qatar, Dubai, Lebanon, Senegal and Turkey.

The RASFF specifies that the issue concerns 500 tons of broken Indian white rice which was imported into Europe, transformed into rice flour, resold and put on the market in many European countries as an ingredient in (among other things) chocolate sweets from the Mars company (M&M’s Crispy) and baked goods.

“These alerts” (regarding GM rice from India) “concern several retail chains or wholesalers: Action, Galec (purchasing group for E. Leclerc stores), Confisud, ITM, Selecta, Casino, Baby Delice, Relay, and Supergroup. Many batches have been withdrawn”

The French Directorate General for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF) is quoted to have said that they “discovered this contamination during a usual check of these cereals which they carry out regularly; the sample analyzed by one of its laboratories was found to be positive. This led to a withdrawal and recall of all the products concerned.”

Concerns and context of GM seeds contamination/leakage from field trials

Whilst India does not allow for GM rice cultivation, we’ve had various GM rice varieties at various stages of confined field trials https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6069684/

Reports have earlier warned on how the increase in number of field trials for GM rice in India could lead to contamination or leaks. Global experiences show us that seed and food supply chains can get contaminated from field trials of GM crops in general and GM rice in particular.The 2006 GM rice fiasco in Us where a GM rice variety, LL601, which was being field trialed by Bayer,contaminated US rice and seeds. This eventually  lead to US rice exports plunging in the upcoming year. Bayer had to eventually pay $750 million in damages to 11,000 farmers whose rice crops its GM variety contaminated and $137 million to a rice exporter company for damages caused to it due to contamination with the GM rice variety.

The cases of HTBt cotton, Bt brinjal and GM soybean found to have been grown illegally in India gives us a clear indication that there is a trend of GM crops from field trials ending up in our farms and food. It is an unfortunate truth that our regulatory system has been found ineffective in curbing this. It is also shocking that GEAC has failed to take effective action to even identify those behind seed supply, leave aside stopping the illegal cultivation. DBT had earlier in 2007 said not to conduct field trials of GM rice in basmati producing states of Punjab, Haryana and UP after the contamination of GM rice in China and US.

The issue with GM field trials is that once they take place, they can contaminate crops long after the actual trials either directly or through seed leakages – for instance between 2001-03 a GM wheat was being field trialled in US with the last trial in 2003, 10 years after which in 2013 GM wheat was found growing in a field without approval in the country. GM wheat was however never commercialised in the world and in response to discovery, Japan and South Korea suspended US wheat import for months. It was also found growing in 2018 in Canada without approval following another ban by Japan and South Korea on Canadian wheat imports.

Given the urgency of the matter there is an urgent need to

  • No field trials should be permitted to avoid any contamination of our food and seed supply chains.
  • Identify the source of GM rice contamination. GEAC must work with APEDA and European Authorities to identify the organisation which exported the broken rice and investigate the supply chain to the seed level
  • A Rule be instituted under the EPA 1986 making the Event Developer as the one who is legally liable for any unapproved releases of GMOs into the environment, including illegal cultivation of GMOs, which in itself will go a long way in preventing leakage of seeds.
  • Event-specific test protocols with primers be deposited by all event developers, starting from the event selection stage itself, with these being available with all accredited laboratories notified as designated labs for testing by authorities enforcing EPA 1986 as well as other regulations in India (under Foreign Trade Act, Food Safety & Standards Act etc.).
  • Standard operating procedures (SOPs) be put into place for every complaint related to illegal GM cultivation which are rigorous and lead quickly to liability-fixing, assessment of contamination and remediation of the same.
  • An inter-ministerial, inter-agency empowered body be set up with GEAC facilitating the creation of such a body, so that illegal GM imports do not become the route to breach India’s bio-safety and bio-security.
  • An applicant’s dossier on a particular GM crop application (event based approval), have a time period validity and not be kept open for any number of seasons/years.

We had shared some of these suggestions earlier too, we ask you to take action on these to prevent further damage to Indian food and agriculture systems.

Kind  Regards,

Rajesh Krishnan (a paddy farmer)

Vayalorathu House, Thrissilery PO, Wayanad, 670646, Kerala

On behalf of Coalition for GM Free India

Copy to:

1) MOEFCC Minister, Shri Bhupender Yadav

2) MOEFCC Secretary

3) Minister of Commerce & Industry, Shri Piyush Goyal

4)  Minister of Commerce & Industry Joint Secretary, Shri Diwakar Nath Misra

Coalition for a GM-free India 

Website: www.indiagminfo.org, email : indiagmfree@gmail.com,  Facebook page – GM Watch India


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