Blocking a new GM Trojan horse in India

Illustration from the publication ‘Seed Stories’, La Via Campesina

On 15 November 2021, the Food Safety and Standards Authority of India (FSSAI) issued a draft regulation called the Food Safety and Standards (Genetically Modified or Engineered Foods) Regulations, 2021.

This draft regulation, through the medium of a regulatory agency (the FSSAI) is the latest attempt by the agricultural biotechnology multinationals and their Indian subsidiaries and partners to trick Indians into consuming foods made from genetically modified or genetically engineered crops. Altogether the opposite of protecting the citizen, the draft regulation of the FSSAI is a Trojan horse which, the industry has built and deployed to pave the way for the easier entry of GM foods into India.

The first section of my response to the FSSAI follows, and the full document is available as a file at the end of this post.

Section 1, intent of the regulations

At the outset, I completely reject modern biotechnology in India’s farming and food. There is no case now, and there never has been a case, for its inclusion, based both on sound science and on public interest. Genetically modified/edited seed and crop of any kind is a threat to the health of Indian citizens. It is a threat to the environment and to the existing agricultural biodiversity of India. It is a threat to the socio-cultural traditions that our agriculture and food rests upon. The Union Government of India and every state and union territory government must prohibit genetically modified/edited seed and crop. There can be no compromise on this matter.

What then is this draft legislation brought for? Nowhere in the text of the draft legislation do I find any reference to any work carried out by the FSSAI or commissioned by it from independent authorities, nor any reference to such work carried out by either the Ministry of Agriculture or the Ministry of Environment – as both these are subject areas associated with the subject of this draft legislation – that assesses the need for such products in India.

In the same way, nowhere in the text of the draft legislation do I find evidence of the precautionary principle applied. The precautionary principle is central to the Cartagena Protocol on Biosafety which India has ratified. Thus the precautionary principle is an obligation, hence a draft legislation about genetically modified or engineered foods must explicitly state that such foods manufactured from, and such foods that contain ingredients derived from (whether in small part or larger part) genetically modified/edited seed and crop will under no circumstances be allowed into India, whether by import of finished goods, or by manufacture (food processing) based on such ingredients or by cultivation within India.

There is a voluminous international record of more than 25 years which shows conclusively that GM foods carry with them biosafety risks during production and health risks during consumption. No Indian citizen should be presented such foods, in whatever form, for consumption. Vulnerable sections of the public such as infants, children, pregnant and lactating mothers, the elderly and people with existing morbid conditions should more particularly be protected from such foods.

I find there is no recognition whatsoever – let alone the provision to act upon such recognition – of these first principles in the text of the draft legislation.

Illustration from the publication ‘Seed Stories’, La Via Campesina

Where something can cause serious irreversible harm, it is right and proper for scientists to demand evidence demonstrating that GM is safe beyond reasonable doubt. This is also an approach that is contained by the precautionary principle (for scientists and for the public, it is just common sense). Scientific evidence is no different from ordinary evidence, and should be understood and judged in the same way. Evidence from different sources and of different kinds has to be weighed and combined to guide policy decisions and actions. That’s good science as well as good sense.

Genetic modification/ engineering/ editing involves recombining, that is, joining together in new combinations, DNA from different sources, and inserting them into the genomes of organisms to make ‘genetically modified organisms’. GMOs are unnatural, not just because they have been produced in the laboratory, but because many of them can only be made in the laboratory, quite unlike what nature has produced in the course of millions of years of adaptation and change. Thus, it is possible to introduce new genes and gene products, many from bacteria, viruses and other species, or even genes made entirely in the laboratory, into crops, including food crops. We have never eaten these new genes and gene products, nor have they ever even been part of our food chain.

The artificial constructs are introduced into cells by invasive methods that result in random integration into the genome, giving rise to unpredictable, random effects, including gross abnormalities in both animals and plants, unexpected toxins and allergens in food crops, and unknown effects on humans and animals. This problem is compounded by the overwhelming instability of transgenic lines, which makes risk assessment virtually impossible.

None of these risks are acknowledged by the draft legislation which therefore fails completely to establish why in the first place the provisions and mechanisms it contains are needed or are suitable for India. It also fails as a protective legislation by not prohibiting foods based on or derived from genetically modified/edited seed and crop.

You can find a pdf file of the full document here, or an open document format text file here.