ISIS Report 08/12/08
Letter in Support of the Latest Hearing on a Petition for a Moratorium on
GM Crops Filed with the Supreme Court in India
1 December 2008
Cc: Aruna Rodrigues arunarod@gmail.com
sunray_harvesters@vsnl.net
To Whom It May Concern
I write on behalf of the Institute of Science in Society (ISIS), a civil
society organisation dedicated to providing critical scientific information
to the public and to promoting social accountability and ecological sustainability
in science. Our scientists have monitored and reviewed extensive scientific
literature and empirical evidence on genetically modified organisms (GMOs)
over the past ten years. I am on the Roster of Experts for the international
Cartegena Protocol on Biosafety that seeks to protect biological diversity
from the potential risks of GMOs and came into force on 11
September 2003.
We fully concur with Dr. Pushpa Bhargava’s recommendations to the
Genetic Engineering Approval Committee (GEAC) on the biosafety assessment
of GMOs, and take great exception to GEAC’s defamatory remarks on him and
its unscientific and unprofessional response to his recommendations. We are
referring to GEAC’s Counter Affidavit of September 2008, the Indian Government’s
‘Reply’ to the Application filed by Aruna Rodrigues and others in August 2008
(Reference Application I.A. No. 25 of 2008 in the matter of Writ Petition
(Civil) No. 260 of 2005).
Dr. Bhargava, founder and director of India’s prestigious Centre for Cellular
and Molecular Biology, is an acknowledged world-class authority on genetic
engineering, biotechnology and molecular biology, and highly regarded in international
scientific circles. GEAC’s defamatory remarks on him betray its possible lack
of competence in the relevant scientific and technological disciplines on
which the Committee is providing advice to the Indian Government, and/or its
willingness to compromise science to serve vested interests in GMO approval.
All of Professor Bhargava recommendations are fully justified on
the most rigorous scientific basis as key elements of biosafety assessment,
and consistent with widely recognized standards of good, responsible science;
as is also clear from both the text and ‘annexures’ to the Petitioner’s Rejoinder
Affidavit of November 2008. Ample evidence has been presented in depositions
by several leading biosafety experts appended to the Rejoinder Affidavit.
In the Rejoinder Affidavit of November 2008 the Petitioners have
abstracted the essential elements of a biosafety assessment protocol from
world-class biosafety experts in section 23, and noted that Dr Bhargava's
guidelines are virtually the same. The testing procedures outlined in Section
23 of the Rejoinder, which are to be combined with standard crop testing procedures,
to determine if a new GM product falls within the accepted norm of safety
of current food crops, are:
1.
The
Ames test for mutagenicity
2.
Metabolic
Profiling for toxic and nutritional compounds; to detect unexpected changes
in small-molecule metabolism
3.
Molecular
analysis of the gene insertion sites and transformation-induced mutations
4.
Extended
multigenerational animal feeding studies for carcinogenic, reproductive, and
other adverse effects
5.
Allergenicity
testing,
6.
Genomic
profiling/DNA Finger Printing/Proteomics
7.
Gene
flow, testing on non-target organisms, soil micro-organisms
8.
Post
market surveillance, both health and the environment
The list is complete except
for tests on genetic stability of the GM insert, which is required in EU Directive
for environmental release, although it is seldom enforced (see Transgenic Lines Unstable
hence Illegal and Ineligible for Protection (http://www.i-sis.org.uk/transgenicLinesUnstable2.php).
Transgenic
instability in the field essentially compromises all safety assessment performed
before environmental release, a point that has been stressed by ISIS from the beginning.
The Austrian Government study published in November 2008 (GM Maize Reduces
Fertility & Deregulates Genes in Mice http://www.i-sis.org.uk/GmMaizeReducesMiceFertility.php),
followed by a peer-reviewed report from the Italian Government showing that
GM Maize Disturbs
Immune System of Young and Old Mice (http://www.i-sis.org.uk/MON810gmMaizeMiceImmuneSystem.php)
confirm a string of previous findings on adverse health impacts from GM food
and feed, which
has served to convince scientists like us that GM is Dangerous and Futile
(http://www.i-sis.org.uk/GMDangerousFutile.php),
essentially because the technology is based on an obsolete view of genetics.
The recent studies find problems with fertility, immune response
and gene regulation in different GM maize varieties by carrying out precisely
the kind of tests recommended by Dr Bhargava and other scientists; i.e., long-term
multi-generational feeding trials, coupled with DNA arrays, proteins and metabolic
profiling. The GM crops in the feeding trials have been commercialized; they
were approved by government regulators in United States and Europe that have ignored stern scientific
warnings over safety, as documented in ISIS’
peer-reviewed publication (Ho
MW, Cummins J and Saunders PT. GM food nightmare unfolding in the regulatory
sham. Microbial Ecology in Health and Disease 2007, 19, 66-77, http://www.i-sis.org.uk/pdf/GM_Food_Nightmare_Unfolding.pdf).
GEAC should not be allowed to repeat their mistake, which is overwhelmingly
condemned by the European and American public.
For India to implement the series of assessments recommended by Dr.
Bhargava and other scientists would not only be good science, but would also
be extremely prudent government policy in view of India’s great genetic biodiversity,
and her many farming communities whose health and livelihood depend on crops
that are proven safe and productive through appropriate tests. At the very
least, a five-year moratorium would allow the desired protocols for rigorous
safety assessment to be put in place to ensure that any GMO introduced will
not cause harm.
ISIS
brought together an Independent Science Panel (ISP) of dozens of eminent scientists
from nine countries to compile all the evidence on the health and environmental
impacts of GM crops on the one hand, and the benefits and successes of non-GM
sustainable agriculture on the other. The ISP produced a report in 2003, The Case for
a GM-free Sustainable World (http://www.i-sis.org.uk/pdf/GM_Food_Nightmare_Unfolding.pdf),
calling for a world-wide ban on further releases of GMOs and a comprehensive
shift to non-GM sustainable agriculture. The report was translated into at
least 5 languages and republished within a year. Our demands have proven all
the more relevant and urgent since then, as evidence of harm from GMOs has
accumulated further, while organic, localized agriculture is now widely acknowledged
as the solution to the current food, fuel and financial crisis as well as
the most important means for mitigating and adapting to climate change (see
ISIS Report, Food Futures
Now: *Organic *Sustainable *Fossil Fuel Free (http://www.i-sis.org.uk/foodFutures.php)
Yours sincerely,
Dr. Mae-Wan Ho
Director
Institute of Science in Society
www.i-sis.org.uk
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