An open letter to Sonia Gandhi asking her make the Government consult people before tabling the Biotechnology Regulatory Authority of India (BRAI) bill.

Respected Madam,

The unpredictability and irreversibility of Genetic Engineering (GE) and the uncontrollability of GE crops in the environment coupled with studies pointing at the potential risk to human health and environment has resulted in a controversy across the world around the need for introducing such potentially risky organisms.

The nationwide debate on Bt Brinjal highlighted the concerns of all sections of the society including scientist on GM food in general and Bt Brinjal in particular. This also saw 10 state governments writing to the central government about the concerns they have with Bt Brinjal. All this at that time had lead to a moratorium on Bt Brinjal declared by the Union Environment Minister Jairam Ramesh.

Instead of heeding the citizens concerns and establishing a strong regulatory mechanism with the mandate of protecting the health of the citizens, livelihood of our farmers and safety of our environment the Government is going ahead with the establishment Biotechnology Regulatory Authority of India (BRAI) which will act as a single window clearance mechanism for GM crops, in effect paving the way for the re-approval of Bt Brinjal.

Here are some of the problems with this bill:

• The approval of GM crops would be based on a presumption that GM crops are a potential solution to all agricultural problems and that the country’s food security crisis can be resolved by introducing GM crops. On the contrary, many scientists agree to fact that real solutions for today’s agricultural problems are in ecological farming methods.
• The approvals also presume that the safety of a GM crop can be best assessed by the company which stands to benefit from the approval.
• The bill proposes a centralised, technocratic decision making authority with no scope for democratic intervention. The apex authority is the BRAI with a chairperson and two members, all scientists with either a biotech or a health background.
• BRAI gives no role to state governments in the approval of GM crops even though agriculture is a state subject under the Indian constitution.
• BRAI sits inside the Ministry of Science and technology creating serious conflict of interest.Dept of Biotechnology – under the Ministry of Science &Technology, has the mandate of promotion of GE crops. DBT funds several GE crop development projects using public funds and is the nodal agency for redirecting funds from foreign governments to GE crop development projects.
• Sections of the bill super cede the Right to Information Act and place the decision to disclose information for public interest with the authority instead of the Central Information Commission or the Delhi high court. The BRAI would kill any informed public debate on GE crops in future, one of the aspects that helped in stopping Bt Brinjal.
• BRAI kills consumer choice and promotes GE polluters as it has no provision for labeling of GE crops, or liability of the crop developer due to economic losses by contamination.

There is a need re-draft the bill, first with an effort to disclose the draft bill and hold public consultations and take in suggestions and issues that are concerning the all citizens of our country.

With the Government failing us by giving an approval for the BRAI bill, our hope lies with the National Advisory Council under your chairpersonship. The fact that the council pro-actively and effectively intervened in the drafting of two important legislations, the Food Security bill and the Communal Violence bill and is doing so with many others, gives us confidence that you will heed the concerns of us citizens and would stop the bill from being tabled in the Parliament in its present form.

The agri-biotech policy of this country is in need for a critical review and we hope the NAC can provide millions of farmers who practice ecological farming a chance to rejuvenate the country’s food production and re-establish its food security.

Sincerely,

SJR Kumar