The latest salvo by proponents of genetically engineered (GE) salmon [“Big Salmon Says Science Is On Its Side” by Dan Flynn, July 28, 2011] takes direct aim at letters sent by 23 members of Congress to FDA earlier this month urging the agency to put the brakes on its misguided approval process for the AquAdvantage salmon and shift priorities in light of the Young-Woolsey amendment that was included in the house-passed Agriculture Appropriations Act of 2012.  Contrary to the claims by proponents, the science just isn’t there to back up assertions of human and environmental safety or economic and food resource benefits of GE salmon.

Not only are arguments that the engineered salmon is “safe” unfounded, but claiming that FDA provides exemplary “science-based” regulation is misleading.  FDA has never promulgated mandatory regulations nor amended existing regulations to cover GE animals. To the contrary, in 2009 the agency announced in a non-binding Guidance to Industry that it would approve GE animals under existing new animal drug provisions.  FDA’s approval process under the 2009 provisions lacks transparency, public engagement and the regulatory and scientific rigor necessary to assess the full suite of novel human health, environmental, animal welfare and socioeconomic risks.  Instead of criticizing Congressional efforts to correct this, we should be asking why an agency with neither expertise in fisheries nor environmental risk assessments is tasked to review and assess GE fish.

A recent study conducted by Canadian researchers found that transgenic Atlantic salmon can pass their genes on to wild salmon if they escape into the wild.  Echoing the concerns raised by members of Congress and the public over the past year, the study’s lead author, Darek Moreau of Memorial University of Newfoundland, Canada said, “little is known about the potential impact on wild salmon populations if the GM species were to escape captivity.”  Despite company claims that all GE fish are designed to be sterile females, FDA analysis of company data reveals that the triploid sterilization process is not 100% effective, as up to 5% of the entire commercial stock could be fertile and able to reproduce.  As the company has boasted, AquaBounty has orders for 15 million eggs, this could mean the production of upward of 750,000 fertile, genetically engineered eggs.

Regardless of any escapes, the farming of carnivorous fish like salmon requires massive quantities of wild forage fish for use as fishmeal and fish oil, inputs that cannon be sufficiently replaced by vegetarian alternatives.  It can take from 3 to 10 lbs. of forage fish feed to produce just 1 lb. of farmed salmon.[1] This is a massive discrepancy that stands to be made worse by GE salmon designed to grow faster as they will likely need more food, thus increasing the pressure on wild fish stocks that are already over-fished for use by aquaculture operations.  The public is being led to believe that GE salmon will reduce the pressure on wild stocks and they are being deceived.

Consumers choose to eat wild salmon for its health benefits yet the data AquAbounty produced for FDA paints a very different picture of GE salmon.  FDA reviews cite the presence of proteins to which some people are acutely allergic to, which might be elevated in the transgenic fish.[2] In later discussion on food allergies, FDA states “the technical flaws in this [AquaBounty’s allergy] study so limit its interpretation that we cannot rely on its results.”[3] AquAdvantage salmon went largely untested for increased disease susceptibility, despite findings of focal inflammations and elevated white blood cell counts suggestive of infection.[4]  Chemical levels of folic acid, niacin, vitamin B6, magnesium, phosphorus and zinc, as well as ratios of Omega 3/Omega 6 fatty acids, vary in engineered salmon compared to non-GE salmon, which is possibly indicative of food quality differences.[5]

Approving GE salmon to be grown across our borders in Canada and Panama, as the company is seeks, is not in our country’s best interests.  The possibility for escape is too high, due tofactors including human error, glitches in containment or serious weather events.  Given the tremendous investment by Federal and State agencies to restore wild salmon fisheries in the Northeast where Atlantic salmon is currently on the endangered species list, ecological and economic costs associated with escapes would be devastating.

A near unanimity of Americans, 91%, felt the FDA should not introduce GE fish and meat into the marketplace, according to poll by Lake Research Partners.[6]  Now AquaBounty is threatening to take its business elsewhere (although no domestic jobs would result from an approval anyway).  As the most influential country in the world, the U.S. should represent the highest pillar of excellence in economic, environmental and social sustainability – rather than catering to the lowest.  If another country permits dangerous and damaging practices of questionable consequences to take place, that is up to their citizens, scientists, and policymakers to decide.

Fortunately, we can draw from successful approaches to management here in the U.S.  Taking a cue from Alaska, which has prohibited fish farming and instead invested in proper management, wild fisheries can flourish when properly supported and thus produce abundant food while generating jobs and economic benefits throughout sectors.  For their efforts, Alaska is being rewarded with near-record salmon returns this year – but these successes need not be limited to Alaska.  We know there is great appetite for salmon, however the solution is not to ‘farm’ genetically engineered versions to put more on our dinner tables; the solution is to support and work to bring our vanishing wild salmon populations back

[1] Naylor, R.L and Burke, M. (2005) Aquaculture and Ocean Resources: Raising Tigers of the Sea. Stanford University Annual Review of Environment and Resources, Vol. 30, page(s) 185-218; Pinto, F. and Furci, G. (2006) Salmon Piranha Style: Feed Conversion Efficiency in the Chilean Salmon Farming Industry, Edited by R. Pizarro, Terram Publications.

[2] AquAdvantage Salmon Briefing Packet for Veterinary Medicine Advisory Committee, Center for Veterinary Medicine, Food and Drug Administration, Sept. 20, 2010, p. 75-76.

[3] Briefing Packet, p. 104.

[4] Briefing Packet, p. 41: “Comprehensive disease challenge tests have not been conducted on these fish.”  “An increased presence of focal inflammation in various tissue types in AquAdvantage salmon has the strongest correlation with the presence of the AquAdvantage construct [inserted gene] among the findings in this study.  That these fish may have been immunocompromised as a result of seasonality or other factors confounds the interpretation of these findings.”  In other words, FDA waves off the strongest finding of difference between GE and control salmon with airy speculation, and fails to demand further study to clarify these “confounded” findings.  In particular, FDA does not demand “comprehensive disease challenge” tests to determine, based on SCIENCE and DATA, whether these GE salmon are more susceptible to disease.  This is inexcusable, particularly given peer-reviewed literature showing that salmon engineered with a growth hormone gene are more susceptible to a significant salmon pathogen (Vibrio anguillarum) that causes the devastating salmon disease vibriosis than non-GE salmon.  See Jhingan et al (2003).  “Disease resistance, stress response and effects of triploidy in growth hormone transgenic coho salmon,” Journal of Fish Biology 63: 806-823.  For elevated white blood cell (lymphocyte) counts, see p. 35, and Figure 5, p. 147

[5] VMAC at 87-88

[6] Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10




Colin O’Neil is a regulatory policy analyst for the Center for Food Safety a non-profit public interest organization based in Washington, D.C.


  • Doc Mudd

    Hmmm…in what fashion would Mr. O’Neal prefer to have “the public fooled”, exactly? This screed from Center for Food Safety (CFS) is little more than a desperate, emotional rant…a tantrum, really.
    It is frantically woven almost entirely of choice uninformed, uncredentialed opinions of Mr. O’Neal and his handlers over at CSF. They did, at least, consult one legitimate source for estimates of food conversion efficiencies of carnivorous fishes – but, why? Apparently only to provide the sole published scientific reference cited in the paper’s bibliography!
    One point of congratulations: CFS made a most excellent purchase when it paid “Lake Research Partners” to conduct their little poll — 91% agreement with CFS’s extreme position! Now, 68% or 74% might have been believable results, but 91%, “A near unanimity of Americans”…sounds a little fishy. Heck, why not, then, go to 99%, even 100% if Lake Partners were instructed to test our gulliblity (our intelligence was long ago irreparably insulted by CFS, so no risk of further harm there, at least).
    The remainder of CFS’s propaganda effort is less remarkable for several sound reasons, perhaps the most fundamental being CFS’s fragmented arguments and frenzied hand-wringing are founded upon the good ol’ precautionary principle…and little else. In fact, this CSF-paid propaganda broadside wonderfully exemplifies the fallacies and deceit of the precautionary principle in the hands of skilled extremists:
    It is amusing, in a fashion, to read Mr. O’Neals imploring appeals to our gullibility, charmingly mounted in child-like naivety.
    Mr. O is anquished over fish food – the domesticated fish must eat…other fish! And what, does Mr. O’Neal suppose “wild” salmon eat, if not other fish…only scary spiders and magic beans?
    Mr. O’Neal acknowledges a brisk American appetite for salmon and discretely admits wild salmon populations are “vanishing”. Of course, he stops short of mentioning how transgenic salmon demonstrate a very real opportunity to lift excessive fishing pressure from our vanishing wild populations, to let them recover. Would the precautionary principle not raise concern that modern fishermen would fish wild salmon until the last fish is canned and sold?
    Have no fear, Mr. O’Neal. Indeed, “the public” will not “fooled” by CFS’s paid propagandists like yourself or Lake Partners, faux-environmentalists who desire to profitably fish wild salmon into oblivion. No, the public won’t be fooled, but Congressmen, now, they clearly are another matter entirely.

  • Steve

    Was this written in a language other than English and then poorly translated?

  • Steve Kopperud

    Mr. O’Neil’s piece against FDA’s approval of AquaAdvantage salmon roe — AquaBounty does not/will not be growing/selling fish — rehash the same tired arguments already dismissed by experts familiar with technology and the underlying science of genetically enhanced Atlantic salmon. Further, he cherry picks studies to make his case regardless of whether conclusions have been dismissed or not. As to the congressional energy surrounding this first application of food animal biotechnology, it’s a bit disingenuous to imply there’s something wrong with the approval system when AquaBounty has given FDA permission to release an unprecedented amount of usually protected information, so there’s your transparency. Check the AquaBounty website or the FDA/CVM website to review the science, independent reviews, etc. The congressional interest — including the Young-Woolsey amendment that was accepted on the House floor by voice vote with fewer than a dozen members present — is all about protecting the wild caught salmon market, meaning these are economic concerns, not scientific ones. This is understandable, but the reality is the PNW/Alaska source of wild caught is pretty much maxed out, and a farm-raised fish at a likely $7-10/lb. will not compete with the high-end wild caught product at $25-30/lb. There must also be considered the deficit of trade in fish products experienced in this country, a trade lag surpassed only by petroleum. Almost 97% of the farm-raised salmon consumed in the U.S. is imported from Chile, Norway, the UK and Canada. A home-grown Atlantic salmon raised in containment near major urban areas means a carbon footprint that’s miniscule by comparison to 747s hauling fish from Chile or Europe, and it also means, perhaps more importantly, local investment, local jobs creation and local tax revenue. Mr. O’Neill also neglects to mention that as conditions of approval — should FDA approve the application — all AquaBounty Atlantic salmon roe will 1) be labeled, 2) will yeild only female fish, 3) all triploid, i.e. sterile (99.8% by independent review), and 4) may only be grown in inland, freshwater, recirculating containment facilities first inspected and certified by FDA. The Center for Food Safety never seems to find technology that measures up; this is just the latest example.

  • Mary

    It cracks me up to see foodies and environmentalists side with “Big Fish”. Strange bedfellows.
    In another breath they also tell me how great it will be to have urban aquaculture tanks.
    Yet in those conversations I’m not hearing about how dreadful escape will be. And it’s the same thing….
    Funny how that’s working out.

  • Catherine J Frompovich

    Okay, if Congress and the public are not fooled by GMO salmon, what’s happened with GMO milk, soy, corn, canola, zucchini, squash, tobacco, cotton, sugar beets, alfalfa, etc.?
    Shouldn’t Congress get off its duff and take on GMOs in the foods people have been forced to eat unknowlingly since the late 1990s?
    If Congress and the public are so astute and smart about GMO salmon, can’t they connect the dots about all the other GMOs in the food supply that are damaging human health?

  • Doc Mudd

    “…all the other GMOs in the food supply that are damaging human health”
    Which GMOs, specifically, and what damage to human health, exactly? There is no evidence of disease outbreaks due to GMO, none at all.
    The idea that GMO foods are damaging our health holds about as much water as an idea that the color of ink used to print our paper currency has caused the depression. Just loopy scaremongering with no basis in fact.
    The rational thinking public is not fooled by GMO scaremongers — we’re smarter than that and we don’t scare so easily, anyhow (to the intense frustration of paid propagandists like Colin O’Neil).

  • Ted

    Great overview article — and the numbers are fully consistent with other consumer surveys.
    And of course there’s more rants-as-usual from propagandist Doc Tantrum hisself, this time flaunting the GMO party line, hook, line and sinker. Yes, all GMOs should be addressed — genetic pollution and contamination is a nasty reality in farmers’ fields — and now their sights are set on the oceans.
    And of course, GMOs remain completely unlabeled in our food supply — just how traceable is that exactly? Ahhh… I see — keep things unlabeled and there’s “no evidence”…. Goes right along with VP Dan Quayle’s Council of Competitiveness’ regulatory Carte Blanche given under the fiction that GMO foods are “substantial equivalent” to non-transgenic foods (but somehow different enough to be patentable) and the food industry’s favorite old rubber-stamp standby, “Generally Regarded As Safe”….

  • Doc Mudd

    More grimacing and hand-wringing, this time from our resident multi-monikered paid NOFA propagandist.
    We’ve been safely consuming and benefiting from GMO foods for a decade or more with no resultant human morbidity or mortality, just a lot of annoying whining from professional scaremongers.

  • Mary

    So, the folks who are making claims of evidence, please produce it.
    Or maybe Bill Marler can give us some evidence of human health harm–he’s on top of stuff like that, right?
    I’d love to see it.