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. 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. 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.” AquAdvantage salmon went largely untested for increased disease susceptibility, despite findings of focal inflammations and elevated white blood cell counts suggestive of infection. 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.
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. 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
 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.
 AquAdvantage Salmon Briefing Packet for Veterinary Medicine Advisory Committee, Center for Veterinary Medicine, Food and Drug Administration, Sept. 20, 2010, p. 75-76.
 Briefing Packet, p. 104.
 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
 VMAC at 87-88
 Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10 http://documents.foodandwaterwatch.org/release-FWW-Omnibus.pdf
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.