The Centre's Department of Agriculture & Cooperation had appointed a Task Force in May 2003 to examine Agbiotechnology and make recommendations for its implementation. The body headed by Dr. M S Swaminathan was given the following mandate: to formulate a long-term policy on applications of biotechnology in agriculture; make suggestions for harmonizing decision making; recommend a role for the Agriculture Ministry and generate awareness.

Released earlier this year, the importance of the recommendations of the Task Force lies in the fact that this is the first effort to formulate a policy. Civil society organizations have been frustrated in the past by the refusal of the Department of Biotechnology (DBT) to engage in any dialogue on public concerns or be receptive to any suggestions for improving a clearly unsatisfactory system. The former head of DBT is famously on record for doggedly insisting that India did not need a biotechnology policy when all around her, from the most vocal protagonists to the most determined opponents, were demanding a national policy.

The task force process itself was somewhat participatory. NGOs, industry, academics and other stakeholders were consulted. The time frame was 3 months which was a limitation. The consultations were not as wide as I have seen for some other processes. The terms of reference of the task force did not include debate on the GM controversy itself, but rather how to improve the efficiency of Agbiotech. That was the limited mandate of the body.

One of the report’s basic recommendations is that the national policy should seek the ‘economic well-being of farm families, food security of the nation, health security of the consumer, protection of the environment and the security of our national and international trade’. If the recommendations of this Task Force are upheld, no policy implementation can deviate from these goals.

The report highlights the need to link transgenic research in India to the international market. Transgenic research should not be done on crops that we sell in the international market, like soybean, Basmati rice and Darjeeling tea. Readers will recall the hare brained schemes of the DBT to promote Bt Basmati and introduce the beta-carotene construct of Golden Rice into Basmati rice. Nobody seemed to be thinking that we are exporters of Basmati (and other) rice as well as soybean (to special niche markets) and that our major trading partners are all rejecting GM foods. So who would buy our Bt Basmati or our GM Soya?

The report is critical of the prevailing gung-ho climate when any proposal for research on a GM crop, however nonsensical the goal, is likely to get sanctioned, often at the cost of conventional research which is more likely to yield results of relevance. It recommends that all alternatives to GM technology should be examined and the GM route used only when other options are not available. There is an explicit injunction against using negative GM traits like herbicide tolerance that can reduce employment (by taking away the opportunity to earn wages by weeding) and impinge on rural livelihoods (by destroying vegetation that is used as nutritious leafy greens or fodder to support livestock).

The report says that our policy on transgenics should be sensitive to biodiversity conservation and the socio-economic context of our composite agrarian system. In other words, small farmer interests have to be protected. In recommending the breeding of both varieties and hybrids and supporting apomixis (asexual reproduction through seeds) as a strategy, the recommendation is clearly in favour of the farmers’ right to save seed from previous harvests.

The recommendation that Centres of Origin and diversity like the Jeypore tract for rice must be protected, is an important one. However the proposed mechanism for earmarking GM and non-GM zones does not appear to be feasible. The task force also did not look the implications of non-GM food preferences developing in the Indian domestic market in the same way that it has developed in the export markers. As a result it ends up advocating a policy of developing non-GM crops for export, but permitting GM crops for domestic consumers. If a country like India would do this, the cost of segregation would be high and in my opinion, segregation of GM and non-GM is practically impossible in India.

For example, if the cultivation of GM rice is permitted in certain areas but not in the diversity rich areas of Orissa, Jharkhand and Chattisgarh, there is no way of preventing GM rice landing up there. Foreign genes in that case are bound to move to wild relatives of rice in its centre of origin. We have seen the speed with which the illegal Bt cotton originally put out by Navbharat seed company has spread to almost all cotton growing areas, despite the fact that its planting is illegal. Similarly, contamination of native corn in Mexico has taken place inspite of the ban on the cultivation of GM corn in the country. Zoning or segregation is unlikely to work. The only way of protecting native germplasm from foreign genes with likely negative impacts is to disallow the GM version of that particular crop.

I have a disagreement on the edible vaccine strategy that forms part of the report. I do not believe India should invest in edible vaccines since it will be impossible to keep vaccine bearing fruit separate from ordinary fruits. Mixture with the food chain is inevitable since one bunch of bananas looks like another. It would be even harder to segregate grains. In the US, Starlink corn, which was not allowed as food but only animal feed, was found mixed up with food corn. In the Prodigene case in the US, a GM corn carrying pig vaccine was found mixed up with soybean for human use, showing segregation is not possible even in the highly regulated conditions of US agriculture. India should have a strict policy of allowing the expression of pharmaceutical molecules like vaccines only in non-edible plants.

With respect to regulation, the report has suggested much needed technical competence and transparency. I would have liked to see a greater role for civil society, as is the case in the Philippines and other ASEAN nations. The structure of the regulatory authority would benefit from greater autonomy, demonstrable competence and independence to inspire confidence. The authority should be able to not just assess Biosafety, environmental and long term ecological impact but also other aspects like social and economic impacts, particularly the impact on small farmers, of the introduction of a particular GM crop.

The Task Force report appears to be in favour of biotechnology because many submissions made by formal bodies and experts were overwhelmingly pro biotech.
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In my view, it would be best to divide the regulatory function into two parts, one Advisory, the other Statutory. The Advisory body should have a broad based multidisciplinary membership that includes all relevant scientific disciplines, social scientists, environmentalists, civil society groups, members of farming and adivasi communities, representatives of panchayati raj institutions, and legal experts. A person of the highest technical calibre who has experience in the regulation of GM crops should head the body.

The statutory body should be an independent body staffed by people skilled in Bio safety Assessment, Environmental Assessment and Environmental Impact Assessment. This body should have overall responsibility for all aspects of risk assessment, risk management, risk communication leading up to decision-making about the safety of a GM crop for the environment, human and animal health and post release monitoring.

It is important to ensure that there is no conflict of interest and rules should be framed in a clear and unambiguous manner so that it is not possible to stack the Agency with particular kinds of people. Clear-cut channels should be created for the public to participate in the decision-making process and to voice concerns. There should be an annual review of the decisions taken on GM products and the rationale for these decisions. This review should be presented to Parliament. Overhauling the regulatory system from its currently appalling state should be high priority.

On balance, the Task Force report appears to be in favour of biotechnology. Part of the reason is that the many submissions made by formal bodies and experts are overwhelmingly pro biotech, as are the annexed reports of the Committees. Other views are also there but these being fewer in number, they do not determine the flavour of the report. I am of the view that promoting biodiversity and promoting biotechnology can be contradictory goals, in the same as promoting high yielding varieties is. We must have a much bigger public debate on the pros and cons of GM technology for India. A broad multistakeholder dialogue must decide whether we must allow GM crops or not. And if GM crops, then which crops and which traits.

Despite this, it is hoped that the process begun by the Task Force will help to establish a competent and participatory system (better than the situation today) and a more responsible way of evaluating which GM crops could be relevant for Indian farmers.