Biotechnology Regulatory Authority of India (BRAI)
An Appeal to endorse a Position Document on BRAI
Date: 2/18/2010 5:56:46 AM ( 11 y ) ... viewed 4695 times
From Dr. Shiv Chopra
I am currently on a speaking tour in India hosted by SAGE which is the first NGO to object to BRAI. A huge number of other NGOs are joining hands with them to do the same. I too am strongly opposed to it. In fact, it is primarily the subject of my talks here.
If accepted, Biotechnology Regulatory Authority of India (BRAI) will become the most offensive authority against the cultivation, trade and consumption of food and agricultural products of one's choice. It will be unconstitutional and contrary to natural law or, if you like, the will of God.
It will be similar to what India faced due to imposition of salt tax during the British rule. It must be resisted by the same method and force that Mahatma Gandhi and his 78 disciples employed for the Salt March to protect a fundamental human right to obtain just one natural ingredient of food - salt.
BRAI is designed to preclude the public's right to grow, own, trade, transport, share, feed and eat each and every food that nature makes.
Similar regulatory regimes are being proposed in Canada as Bill C-6 and in America as Bill S510. In the U.S, it is said to be engineered and steered by the food safety "czar", Michael Taylor, who is a lawyer and who many times in the past served Monsanto and USFDA to the chagrin of public interest groups.
As for the politics of GMO-related food safety issues, the name Gandhi to the Indian people is gold. Rahul and Varun are the golden grandsons of Indira Gandhi. They also share in their genes some gold from the Nehru lineage. What India needs to know if either or both of them are cut out to be the Kohi-e-Noor. One way to test such a possibility is to invite them separately or together to speak their mind at public meetings on Mahatma Gandhi's ideology of "Nai Talim" - (New Learning) to teach traditional methods of food and agricultural production in elementary and secondary schools.
Other luminaries of Indian politics who should be invited to do the same thing in public are Minister Jairam Ramesh and his opponents in the government concerning the introduction of GMOs for food production in India.
If people need to see more of what this is about, they can watch these:
Food Laws - Forcing people to globalize
State Imposed Violence ... to snatch resources of ordinary people
On Mon, Feb 15, 2010 at 7:16 PM, satheesh periyapatna
Please see the Position Document on BRAI from the South Against Genetic Engineering a five year old coalition working with over 100 groups in South India.
If you wish to endorse this, we will be grateful
p v satheesh
Director, Deccan Development Society
Convenor, South Against Genetic Engineering
SOUTH AGAINST GENETIC ENGINEERING
A CALL TO “REJECT” THE BIOTECHNOLOGY REGULATORY AUTHORITY (BRAI) BILL, 2009 ON GROUNDS OF ETHICAL, SOCIAL AND POLITICAL CONCERNS
The National Biotechnology Regulatory Authority Bill (NBRA), 2008 has now been revised and rechristened as Biotechnology Regulatory Authority of India Bill (BRAI), 2009. The document has been received from anonymous sources and is still marked as “SECRET”. Such documents are often not disclosed (even through the Right to Information) by the concerned Ministry and in this case the Ministry of Science and Technology (MoST) as they are being worked upon under the Official Secrets Act, 1923.
At this point of time, the South Against Genetic Engineering (SAGE) has taken a position that we are not looking closely at particular clauses of such a legislation in order to make some cosmetic changes in it. SAGE would rather present our objections to the very premise of introducing such a Bill in India's Parliament. We say this because:
1. Regulating and not Restriction/Protection from Modern Biotechnology: The BRAI Bill, 2009 is essentially being brought on board to regulate research, manufacture, import of organisms, transfer and so on related to modern biotechnology. It works on the premise that modern biotechnology is acceptable and its research applications will continue. The Bill defines modern biotechnology The introduction of this Bill pre-supposes the importance of such modern biotechnology and only seeks to regulate its introduction and application. This stands antithetical to the position of all SAGE partners who are working on revival of agrobiodiverse farming controlled by farmer's knowledge and practices. The BRAI does not respect this.
2. Conflict of purpose in locating the NBRA under the Department of Biotechnology, Ministry of Science and Technology: The BRAI Bill, just like the NBRA Bill emanates from the DBT, Ministry of Science and Technology which is mandated to promote Biotechnology, and in particular modern biotechnology. Further, the Chairperson of the proposed BRAI is specified to have a doctorate or an equivalent degree from the life sciences which today is deeply interconnected with modern biotechnology. In fact this person needs to have had a leadership role in a scientific institution/organisation/agency for twenty years. and other related criteria The Chairperson of the Inter-Ministerial Advisory Board will be from the Ministry of Science and Technology. In all, the composition leaves little or no space for social, political and environmental reasoning related to biotechnology in the realm of decision making.
3. Functions and Powers of proposed BRAI: The functions and powers of the BRAI are to regulate transport, import, manufacture and research of use of organisms and research as specified in Schedule I of the proposed BRAI legislation. The BRAI will look at impacts on human and animal health as well as environment. The issues of social justice, inter-generational equity, impact of genetic pollution (beyond environmental impacts) and political economy of these decisions don't figure in this mandate. Considering the genesis of this Bill is from the DBT, this is not surprising. Yet, it is surely disconcerting. A mandate like the above takes the entire realm of discussion on modern technology into an “expert scientific” domain without any political understanding of where such science is likely to emanate from or is sponsored towards. The Bt Brinjal experience has shown that there is no “scientific consensus” on the impact of genetic engineered food crops (which is an integral component of modern biotechnology). The regulatory decisions of the proposed BRAI are likely to be marred with such polarised position, leaving it to the dicretion of those in position to ascertain which politics of science they want to allign with.
4. No Public Scrutiny of applications: It is ironic that when there is much debate and an strongly expressed need exists for public disclosure and scrutiny of approval processes, the BRAI Bill and the process it prescribes, presents no scope for this. The Bt Brinjal public consultations brought to light that even limited public debates can bring to light facets of impact assessments which no laboratory research or closed door decisions can process. Social, Environmental and Ethical concerns can only be processed in a public arena. The BRAI Bill seems to be stuck in a time warp. Once an application is received, it will be sent to a Risk Management Unit under the BRAI. This unit will do a “science based evaluation” and submit a risk assessment report. Following this it will go to a Product Rulings Committee for their recommendation.
What is interesting is that this process states that the reasons for rejecting an application is stated in clause 26 (5). It is stated here that, “ if the authority has reasonable grounds to believe that the person may not comply with the conditions which may be imposed under clause (a) with respect of the authorisation, it may in writing refuse to grant authorisation....”. We might have instances where larger corporations/agencies might give in writing that they will comply with conditions and cleverly renege from that commitment subsequently. Given the corrupt nature of the regulatory systems as we have evidenced in the past, this situation is not unimaginable. In that case, the BRAI is silent whether such an approval will be revoked, although there is a provision to appoint a monitoring officer.
These are four fundamentals based on which SAGE rejects the proposed Bill. It is likely that the BRAI Bill, 2009 is introduced in the coming session of the Parliament. Any fine tuning or tweaking of such a Bill would imply the acceptance of modern biotechnological applications in agricultural and related research. This goes against the very basic vision and principles of SAGE.
P.V.SATHEESH National Convenor
KANCHI KOHLI, Adviser, SAGE
 See also:
 The setting up of a separate Department of Biotechnology (DBT), under the Ministry of Science and Technology in 1986 gave a new impetus to the development of the field of modern biology and biotechnology in India. In more than a decade of its existence, the department has promoted and accelerated the pace of development of biotechnology in the country. Through several R&D projects, demonstrations and creation of infrastructural facilities a clear visible impact of this field has been seen. The department has made significant achievements in the growth and application of biotechnology in the broad areas of agriculture, health care, animal sciences, environment, and industry http://dbtindia.nic.in/uniquepage.asp?id_pk=4
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