Our Work Aquaculture: Genetically Engineered Salmon

A New and Troubling Way to Farm Fish

Take Action: Demand all genetically modified fish be labeled. If approved without labeling, consumers won't know the difference between genetically engineered and natural salmon at the fish counter. Photo: AP

Right now, the FDA, under the agency's authority to review "new animal drugs,"ⁱ is considering whether to allow the production and sale of the first-ever genetically engineered animal for human consumption. AquaBounty Technologies, Inc. wants commercial approval of its AquAdvantage salmon, a farmed Atlantic salmon genetically engineered to grow twice as fast as natural salmon. The company claims that its fish will help meet the world’s growing demand for seafoodⁱⁱ—but it may be that the costs to ocean and human health far outweigh any potential benefit.

If the US Food and Drug Administration (FDA) approve the first genetically engineered animal for human consumption a new breed of farmed fish may soon be at your local grocer or seafood restaurant without you even recognizing it. If GE fish technology proliferates before we have answers to a host of critical questions, we'll be gambling with the health of our oceans, the economic well-being of our coastal communities and the safety of our seafood supply.

• Have questions? Check out the Q&A with George Leonard, Ocean Conservancy's director of aquaculture, explaining why the GE salmon approval would have broad implications for the future of fish, seafood and fish farming

Environmental Impacts of Genetically Engineered Fish

The environmental consequences of farming genetically engineered fish, including salmon, are not fully understood—but what is known is troubling. We know that farmed fish can escape their enclosures, whether they are in land-based tanks or ocean-based net pens.ⁱⁱⁱ Escaped genetically engineered salmon are likely to compete with wild fish, including endangered Atlantic salmon, for habitat, food, and mates.^iv Research published in the Proceedings of the National Academy of Sciences found that the release of just 60 genetically engineered fish into a wild population of 60,000 could lead to the extinction of the wild population in less than 40 generations.^v There is still considerable debate about whether this "Trojan gene effect" would occur if AquaBounty's genetically engineered salmon escape. But the company's data, and FDA's conclusions based on analysis of that information, indicate that up to 5 percent of the eggs may not be sterile.^vi

Photo: NOAA

Growing genetically engineered salmon in contained, land-based facilities, the initial step being considered by the FDA, does not alleviate these concerns. Some re-circulated water is eventually released into the environment, providing an escape route for genetically modified fish or eggs. Land-based facilities are also subject to natural disasters, human error, or intentional sabotage. The New Animal Drug Application process used by the FDA does not fully address the scope of the environmental damage that could result should genetically engineered salmon or salmon eggs escape containment.^vii

Human Health Impacts: Are Genetically Engineered Salmon Good for Us?

Beyond the environmental concerns of genetically engineered fish, the limited data made public by the company suggest that the product may pose food safety concerns as well. These concerns must be thoroughly evaluated before genetically engineered salmon is approved for human consumption. Some of the differences between genetically engineered salmon and conventional salmon include:^viii

• Six chemicals (folic acid, niacin, vitamin B₆, magnesium, phosphorus and zinc) are present in genetically engineered salmon at values that differ by more than 10 percent from conventional farmed salmon, indicating potential food quality differences among the two kinds of fish.
• The omega 3/omega 6 ratio in genetically engineered salmon is more than 12 percent less than in conventional farmed salmon, a difference that could be of interest to seafood consumers looking to maximize omega 3 levels in their own diets.
• Data indicate there may be higher levels of allergy-producing compounds in genetically engineered salmon, meaning the fish may pose a greater food allergy threat. Given the limited sample sizes, more study is needed to definitively rule out this concern.
• Levels of Insulin-like Growth Hormone (IGF-1) are elevated in genetically engineered salmon compared to conventional farmed salmon. The long-term health impacts of this are unclear, but IGF-1 is a known carcinogen.

Wild Salmon is an iconic species and one of our nation's last great natural foods. Photo: NOAA

Genetically Engineered Salmon and the Future of Fish

The decision before the FDA could have consequences that go well beyond salmon. An FDA decision will mark a critical turning point for the future of our seafood supply. Should genetically engineered salmon be approved, it will be nearly impossible to reverse course once the "genie is out of the bottle," especially if labeling is not required. Approval could pave the way for the proliferation of other species of genetically engineered fish and, in so doing, fundamentally alter the nature of our seafood supply.

Our ocean is our life support system, and a bountiful wild fish supply is one of its most precious resources. Over a billion people rely on fish as their primary source of protein,^xvi and billions more value fish for sport and tourism. Wild fisheries also produce enormous economic benefits to coastal communities and throughout the economy estimated at more than $90 billion each year.^xvii Decisions about the future of fish farming – including the role of genetically engineered fish – should not be made in isolation, or in ways that threaten the health of our ocean.

Ocean Conservancy is calling for a comprehensive Environmental Impact Statement before a decision is made on genetically engineered salmon. And we are calling for mandatory labeling of any genetically engineered fish or genetically engineered fish product sold to U.S. consumers. Only then will consumers have the information they need to avoid it in the marketplace if they so choose.

References

ⁱ The FDA regulates genetically engineered animals under the new animal drug provision of the Federal Food, Drug, and Cosmetic Act (FFDCA; 21 USC 321, et seq.) because the recombinant DNA (rDNA) construct used to make genetically engineered animals meets the definition of a new animal drug.
ⁱⁱ See company website at: http://www.aquabounty.com/company/aquaculture-293.aspx
ⁱⁱⁱ Diana JS. 2009. Aquaculture production and biodiversity conservation. BioScience 59(1): 27-38.
^iv Ford JS and Myers RA. 2008. A global assessment of salmon aquaculture impacts on wild salmonids. PLoS Biology 6(2): e33.
^v Howard RD, DeWoody JA, Muir WM. 2004. Transgenic male mating advantage provides opportunity for Trojan gene effect in a fish. Proceedings of the National Academy of Sciences 101:9.
^vi FDA stated that AquaBounty’s characterization of the AquAdvantage Salmon as “sterile” is “potentially misleading” because “sterility has not been explicitly verified in these fish and up to 5% of the eggs sold for grow-out may be non-triploid and still within the release specifications.” FDA Briefing Packet, September 20, 2010 at p. 115.
^vii Howard et al. 2004; See also Muir, W. M., and R. D. Howard. 1999. “Possible Ecological Risks of Transgenic Organism Release when Transgenes Affect Mating Success: Sexual Selection and the Trojan Gene Hypothesis.” Proceedings of the National Academy of Science 96(24): 13853-56. See also comments by Anne Kapuscinski in the transcript from VMAC hearing, September 20, 2010. Pp. 320-322.
^viii FDA Briefing Packet, September 20, 2010 at pp. 67, 88, 95, and 97. ix For a complete list of recent, relevant polling data, see http://ge-fish.org/policy-comments/polls- on-genetically-engineered-fish/
^x http://stopgefish.files.wordpress.com/2010/09/final_enviro_conshlth_combinedge_fish_letter. pdf
^xi http://stopgefish.files.wordpress.com/2010/09/final-letter-chefs-etc1.pdf xii http://articles.latimes.com/2010/aug/14/business/la-fi-super-salmon-20100814; See also: http://www.dailyfinance.com/story/company-news/fda-hearings-on-gm-salmon-are-a-fish-fight- over-labeling/19641350/
^xiii http://www.akmarine.org/congressional-letter-on-ge-salmon-2010.pdf. After this letter was submitted, Senator Boxer (D-CA) wrote separately to FDA expressing her concern. See: http:// stopgefish.files.wordpress.com/2010/11/senator-boxer-letter-to-fda-on-ge-salmon-final-2.pdf
^xiv http://stopgefish.files.wordpress.com/2010/09/house-fda-ge-salmon-09-10.pdf
^xv http://www.sacbee.com/2010/11/20/3199355/gene-spliced-salmon-a-risky-unknown.html
^xvi Food and Agricultural Organization of the United Nations (FAO). 2009. FishStat,. xvii FAO. 2009. FishStat.