UPDATE February 13: Following significant public pressure, the U.S. Food and Drug Administration has just announced that it is extending the public comment period for AquaBounty Technologies' application for AquAdvantage Salmon for a further 60 days. Originally slated to end on February 25, 2013, the comment period will remain open until April 26, 2013. It's more important than ever that we raise our concerns and make sure our voices are heard - see end of article for further details.
It's a well-known PR tactic to release bad or potentially unpopular news during the Holiday Season. So I always keep my eyes peeled to catch any news releases that might otherwise slip the net. I didn't have to wait long.
On December 21, when most people were focusing on their upcoming festivities, the U.S. Food and Drug Administration (FDA) quietly released its draft environmental assessment on the highly controversial genetically engineered (GE) salmon, created by AquaBounty Technologies Inc.. The decision effectively gives the public less until February 25, 2013 to stop the commercial release of the world's first GE animal intended for human consumption.
Dubbed the "Frankenstein fish" by its critics, AquaAdvantage Salmon, according to AquaBounty, is genetically engineered to "include a growth hormone gene from Chinook salmon which provides the fish with the potential to grow to market size in half the time of conventional salmon." Introducing the new genetic material results in "shorter production cycles and increased efficiency of production." AquaBounty already has plans for GE trout and GE tilapia.
According to the company's proposals, the production of GE salmon eggs would take place on Canada's Prince Edward Island. From here, the eggs would be shipped to the Panama highlands, where the GE salmon would be raised to maturity in inland tanks (not at sea in nets), minimizing any risk of escape. Once they reach maturity, the fish would be slaughtered in Panama and processed into cuts, before being exported back to the U.S. for sale for human consumption.
I first wrote about AquaBounty's proposal to introduce GE salmon back in 2010 when it was still pending FDA approval. At the time, it looked like the "Frankenstein Fish" would stay in the lab where it belongs. But the FDA's recent decision could now signal a green light for the global production of GE salmon, and arguably open the floodgates for a range of other genetically engineered animals, including pigs, cattle and poultry.
As someone who puts animal welfare and the environment front and center in my food choices, AquaBounty's claim that their GE salmon will reach a marketable weight in half the time immediately set alarm bells ringing. You don't get such unnatural growth rates without some kind of cost -- whether that's to the animal, to the environment, or to the consumer. Indeed, an expert panel from the Royal Society of Canada was set up in 2001 to look at the potential impacts of genetically engineered animals. They noted documentation has focused on "deleterious consequences to fish morphology, respiratory capacity, and locomotion associated with the introduction of growth hormone (GH) gene constructs in some transgenic variants of salmonids, notably Pacific and Atlantic salmon..." and concluded that significant health and welfare problems are "the rule rather than the exception in fish... [and are] manifested by changes to enzyme activity, gross anatomy, behavior and, in all likelihood, hormonal activity."
We already know that our drive to produce ever-greater quantities of cheaper animal protein has led to significant welfare problems through intensive breeding programs and hybridization across all farmed species. You only have to look at the wretched breeds favored by the intensive poultry industry to see the extreme suffering they experience to fuel our demand for cheap chicken meat. The Cornish Cross breed has not (yet) been genetically engineered, but it's been bred to put on weight so quickly that its body cannot physically cope. If you could (legally) walk among the tens of thousands of birds that are cooped up in just one intensive poultry house, you'd see that most birds cannot walk more than a few steps without having to slump down in exhaustion. Many can't even move at all. These birds can suffer from heart strain and are prone to bone, joint and ligament problems. The point I am making is that the drive to constantly increase growth rates and shorten the time these animals need to reach a marketable weight has led to significant associated welfare problems that the industry would prefer us not to know about. So we should all take AquaBounty's claims that their GE salmon will bring about "fish health benefits" with a (very) large pinch of salt.
We also know that intensive fish farming already has a similarly appalling animal welfare and environmental record as, say, intensive broiler production. Both systems involve large numbers of animals packed together in a confined space, where they're pushed to grow as fast as possible; there is a high risk of disease and parasitism, leading to routine use of medication; and we know that the environmental pollution from intensively farmed fish feces is a huge cause of concern -- whether it's an inland operation, as proposed here, or out at sea in cages.
As an environmentalist, I am extremely concerned about the impact that these GE salmon will have on wild salmon populations when they inevitably escape into the wild. Forgive me if I don't swallow AquaBountry's promises about the environmental safety of their operations hook, line and sinker, but we've heard all these safety claims before. According to the environmental campaigning groups, Friends of the Earth, "the FDA's decision to approve the GE salmon without a comprehensive Environmental Impact Statement under federal law is irresponsible and inexcusable." Friends of the Earth claim that FDA's assessment "relies heavily on data provided by AquaBounty" and, worryingly, "ignores the fact that up to five percent of the fish may be fertile at a commercial scale." When we're potentially talking about millions of fish, just five percent becomes a pretty big figure: "This opens the possibility that fertile, genetically engineered fish could escape into local waterways and wreak havoc on the ecosystem and already threatened wild salmon populations," warn Friends of the Earth. Despite promises from the likes of Monsanto and the biotech industry that GE crops were an environmental panacea, less than two decades after they first went on sale we're now seeing the widespread emergence of herbicide-resistant weeds and massively increased applications of ever-more toxic herbicide combinations -- problems which we were also told would either never happen or which were nothing to worry about.
Some critics have wrongly claimed that the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service weren't involved in the recent environmental assessment. While internal emails and documents from the FWS (received by Food & Water Watch) sent in 2010 reveal significant concern among FWS staff about AquaBounty's GE salmon and the limitations of the FDA's expertise to undertake the assessment, both agencies have now officially provided supportive comments to the FDA (see pages 135-136 of the FDA's draft environmental assessment). But although the official FWS statement effectively concurs with the FDA's overall assessment on environmental risk, they did note this was only based on Aquabounty's current plans. In other words, if AquaBounty was intending to modify its production systems in any way or wanted to sell eggs to other fish farming facilities, they would have to apply to the FDA for each and every instance.
The problem is that Panama could be just the start: AquaBounty may be hoping its facility there will demonstrate the profitability of inland GE fish farming to other interested players. Indeed, the company's processing facilities at Panama are far too small to ensure its future viability -- particularly when you take into account the multi-million dollar "debts" AquaBounty now built up over the years to fund its research. No, some believe AquaBounty is hoping the real money will come from selling "millions upon millions" of GE salmon eggs to fish farms across the world.
And therein lays the risk. As production of GE salmon increases across the world, accidents could happen. In the pursuit of profit, corners are typically cut and risks typically taken. Regulations could be ignored or not enforced, and "best practice" advice could not be followed. I think it's inevitable. Indeed, the earlier internal emails from the FWS reveal that one of AquaBounty's initial proposals included plans to grow the GE fish in an area where they could be discharged into the ocean off the coast of Maine. Although the FDA has ruled out any ocean-based production of GE salmon in the U.S., who's to say that this won't happen elsewhere in the world?
Which is probably why there is still significant concern among FWS staff about AquaBounty's proposals: James Geiger, FWS assistant regional director in the Northeast region, recently spoke to the Boston Herald. "Although AquaBounty claims their fish are sterile, that sterilization process is not 100 percent," he said. "There is the possibility that some of these fish could escape and reproductively interact with wild native salmon. Any potential offspring could reduce the biological and ecological fitness of the native wild salmon."
As someone who enjoys eating sustainably-sourced salmon, I'm also concerned that the FDA's decision could jeopardize my health and the health of my family -- as well as the livelihoods of sustainable fishing businesses. Friends of the Earth claim that the FDA has ignored the potential risks to human health posed by the GE salmon, as research shows that GE salmon has higher levels of IGF-1, "a growth hormone that, according to the National Cancer Institute of the National Institutes of Health, may increase the risk of several types of cancer." Consumers Union has also raised concerns about the potential allergic reactions from the fish, claiming that the FDA "has allowed this fish to move forward based on tests of allergenicity of only six engineered fish -- tests that actually did show an increase in allergy-causing potential." Yet despite these health concerns, current labeling laws mean that it's likely we won't even know if we're eating GE salmon. In this great nation of ours, it seems that we no longer have the right to know how the food we are eating is produced, let alone the freedom of choice over whether or not we actually eat it. As a result, some people may simply choose to avoid eating salmon altogether, to the detriment of countless U.S.-based sustainable salmon businesses.
Food & Water Watch claims the FDA recently came under intense fire at a Senate hearing last December for lacking the necessary expertise to properly assess the full range of risks GE fish pose to marine ecosystems. Over 40 members of Congress and scientists at other federal agencies have voiced strong opposition to GE salmon, citing the lack of scientific rigor and expertise at the FDA as a key concern. We already know that the regulatory regime for the approval of GE crops is founded on selected information provided by the GE companies themselves and that there is little, if any, truly independent or long-term assessment of their safety. Worryingly, the process for approving the world's first genetically engineered animal destined for our plates appears to be equally negligent: The FDA's draft environmental assessment for AquaBounty's GE salmon is almost entirely reliant on data provided by the very company which stands to profit most from its commercial release.
We now have less than 20 days to stop GE fish from reaching our plates. Please contact your member of Congress now by using Food & Water Watch's online petition.
Alternatively, you can submit your comments directly to the FDA on their website. For the required field "Organization Name," just enter "Citizen." Please send all comments to the FDA no later than February 25, 2013.