Carbon Reduction is a Red Herring to Mask a GMO Salmon Disaster
Introduction
Genetically engineered salmon poses the single greatest, intentional, man-made threat to marine life and human health in modern history. Yet the recent Federal Department of Agriculture (hereinafter “FDA”) approval of genetically engineered[1] salmon passed largely without media attention or much public scrutiny. No sweeping national headlines, no Congressional objection, no coordinated protests, nothing. With a fictitious aim to “feed the world” and help preserve the environment, AquaBounty after long last won over the FDA.
Aquabounty Technologies
Ronald Stotish is the president and chief executive officer of Aquabounty Technologies (hereinafter “Aquabounty”), the company responsible for the eventual mass production of bioengineered salmon. Aquabounty is currently the only company producing GMO salmon that is authorized to market and sell. Key innovations of Aquabounty that set them apart in the field of biotechnology is the combination of two modern technologies to develop GMO salmon: modern genetics and land-based aquaculture. Pairing these technologies allows Aquabounty to significantly shorten the production cycle of the salmon. Despite the rapidity of GMO growth, Stotish asserts he does not anticipate the salmon will reach the market for another two years as this current crop completes the developmental process.[2]
Understanding the Effects of Climate Change and Global Warming
“Increases of carbon dioxide, methane, and nitrous oxide in the earth’s atmosphere throw the planet’s highly sensitive ecosystem off-balance. This climate change, or global warming, results when gases trap warmth in the earth’s atmosphere instead of letting the atmosphere release it.”[3] Purposeful human reduction in carbon production is the only way to break the current trend of fluctuating, dangerously high, gas emissions. But is GMO salmon the answer to the climate change epidemic?
What is a carbon footprint? The Nature Conservancy explains it as the lasting imprint that humans leave. Relating it to everyday life: “Inevitably, in going about our daily lives — commuting, sheltering our families, eating — each of us contributes to the greenhouse gas emissions that are causing climate change.”[4] Despite the internationally accepted scientific consensus, the nexus of rapid climate change remains a controversial topic in the United States among factions of fringe science deniers. Notwithstanding settled science on the cause of this rapid change (humans), the science of climate change is undeniable and as a result, companies reconsider how they will operate in order to more efficiently utilize resources adversely affecting the climate. AquaBounty is no exception, in fact they promote their process as carbon reducing and the most environmentally friendly method of salmon production.
According to AquaBounty, “[Frankenfish] require 20-25 percent less feed than any other farmed Atlantic salmon on the market today.”[5] AquaBounty also asserts that transporting their salmon “emits 23 to 25 times less carbon than the two major sources of US Atlantic salmon. Do the benefits from reducing the carbon footprint outweigh the risk of harm associated with manufacturing test tube salmon?
Aquabounty’s feed statistics represent a reduction in carbon. But that reduction is not as substantial as other inhibiters of carbon production. The measure of salmon feed only minimally compares to burning coal or petroleum.[6] Intrexon Corp., which holds a 58 percent stake in AquaBounty[7] would be better served investing in wind or solar energy, as those are more sustainable and leave almost no carbon footprint. AquaBounty’s Salmon were not engineered for their environmental utility. Salmon was selected for its popularity and resilience – motivated by profit. Reducing the carbon footprint was the selected phrase by public relations specialists because it is an easily palatable excuse for the mainstream. But that excuse cannot withstand even weak challenges as to its authenticity.
FDA Approval
“After an exhaustive and rigorous scientific review, the FDA arrived at the decision that AquaAdvantage salmon is as safe to eat as any non GMO salmon, and also as nutritious.”[8] In making its determination, the FDA reviewed extensive data submitted by AquaBounty as well as other peer-reviewed data. Their central concern was insuring the GMO salmon met the standards of safety and effectiveness, and secondly, the environmental impact of the salmon. According to the FDA, “the inserted genes remained stable over several generations of fish, that food from [GMO] salmon is safe to eat by humans and animals, that the genetic engineering is safe for the fish, and the salmon meets [AquaBounty’s] claim about faster growth.”[9]
The FDA also addressed concerns about the potential for the GMO salmon to reach local waters. The FDA claims, “AquaAdvantage Salmon would not cause significant impact on the environment of the United States…based on the extremely low likelihood that AquaAdvantage Salmon could escape into the environs surrounding PEI and Panama facilities and survive in an ocean or waterway and interbreed with wild Atlantic salmon.”[10] This lack of assurance from the FDA should concern the public. A “low likelihood” seems an obscure measure for a decision that may change future of salmon forever. Producing a larger, faster growing, more immune resilient, organism into the wild, could have devastating ramifications. Applying a “low likelihood” standard falls below the public expectation of acceptable reasoning from the FDA for approving such a venture.
Analysis
The term “Frankenfish” represents a derogatory moniker bestowed on GMO salmon by critics of the scientific creation. From 19th century sawdust beef noted in Upton Sinclair’s The Jungle[11], to the 20th century Monsanto seed controversy, the United States is no stranger to food production controversy and shall soon provoke outrage once again, when it introduces 21st century bioengineered salmon, to the world.
Several legitimate fears arise from artificial salmon production and the fear is not isolated to the unknown stratosphere of bioengineered salmon. To start, GMO salmon reaches market size nearly 40% sooner than traditional farm-raised competitors. Next, GMO salmon carries the high risk of contaminating wild salmon populations. Also, GMO salmon will not be labeled as such. Consumers have a right to know what food they are providing their families. Making a conscience choice is taken away from consumers against their will by denying GMO labeling.
Aquabounty not only received final FDA approval to continue researching and developing this biotech innovation. But Aquabounty has received federal authority to mass-produce and sell these test tube adaptations for human consumption. In due course the “carbon footprint” excuse will be exposed as a red herring and force regulators to focus on the salmon’s stages of development. As with any living organism, development is essential to proper function. Cutting the developmental stage in half eliminates the bioengineered salmon’s opportunity to complete smoltication. Smoltification is a complex developmental transformation, involving physiological, biochemical, morphological, and behavioral changes, that allows young salmon (parr) to transition from living in freshwater to living in saltwater.[12] The FDA failed to adequately address the developmental setbacks of bio engineering salmon.
GMO Labeling
This concept of placing identifying information on food labels represents a classic Consumer Rights versus Manufacturer Freedom showdown. Do consumers have the right[13] to know the origin of their food sources? Should the FDA be held to clear, known, public standards removing all guesswork from their rulemaking authority? As a federal agency with decision-making authority that carries the weight of law, it is individually capable in these circumstances of playing “kingmaker.” Too much is left to human error and risk of coercion. GMO labeling is only statutorily mandated in certain instances. “The Federal Food, Drug, and Cosmetic Act (FD&C Act) provides statutory authority for mandatory labeling of food if there is matieral information that must be disclosed within the meaning of sections 403(a) and 201(n) of the FD&C Act. Because the data and information evaluated show that AquaAdvantage Salmon is not materially different from other Atlantic salmon, the FDA has determined that no additional labeling of food from AquaAdvantage Salmon is required.”[14]
A battery of published requirements should guide FDA decision-making. The FDA appears content undertaking extreme measures to keep AquaBounty a secret from consumers. Why not proudly proclaim the derivation of these test tube creatures? Assuming a patriarchal authoritative role, that presumes, “governmental agencies know best,” is both wrong, but also antithetical to the ideals of free will.
Final Thoughts
Longevity does not always demonstrate good decision-making – the FDA review of AquaBounty’s application before final approval was the longest review in FDA history. FDA support for American ingenuity is admirable. But FDA bypassing sound judgment and then amplifying the wrong by rejecting mandatory GMO labeling is unforgivable. Federal agencies play a clear role in the United States. Their role is to protect health and safety. Authorizing the sale of salmon artificially created should only happen with intense, unquestioned scrutiny. To quell any fear of the threat of cross-breeding, according to the FDA, Anna Edney of Bloomberg reports, “the salmon are sterile, so if they do escape, they can’t breed with wild fish.”[15] This seems unlikely. But even if true unnecessarily dangerous. Engineering a sterile creature from conception would require a substantial alteration to the animal’s genetic code. What information has the FDA or AquaBounty produced to eliminate fears associated with mass-producing living creatures that, by themselves, are naturally unable to reproduce? None, neither the FDA nor AquaBounty has released a single study to temper or marginalize those fears. Thus, the fears justifiably remain, and heighten skepticism from everyone except the authoritative body responsible for denying approval – the FDA.
Ultimately, the heart of the issue with the mass production of test tube Frankenfish is lost. The heart of the issue is this: Aquabounty invented an unnecessary and dangerous solution to a non-existent problem. Salmon production and distribution has not faltered. As previously acknowledged, the carbon footprint justification is an untenable excuse. Thus, the FDA approved a science experiment with the potential for destroying entire fish populations based on “encouraging data from Aquabounty.” This is unacceptable reasoning for stakes this great.
AquaBounty Technologies Inc. seeks to disguise corporate, profit-driven motivations under the guise of environmental sustainability. Giving the impression that a reduction in the carbon footprint suffices for an acceptance of the threats posed against marine life. The truth is, just like all other organelle derived from biotechnology, the science is too nuanced to truly know the long-term ramifications. Scientists and fishing communities should prepare for the worst. Envisioning the potential for Frankenfish to infiltrate local streams is not very far-fetched. Reducing carbon footprint. Brilliant! But at the cost of potentially introducing death spawn of bio engineered salmon into local waters. Not so brilliant. Do the carbon reduction ends justify the bioengineered means? Sure, when the goal is actually carbon reduction. But when the goal is to hide behind a popular sentiment like climate change, in order to peddle strictly profit-driven motivations that endanger fish, wildlife and every person that consumes it, no. Those bioengineered ends do not justify the means.
---------------------------
Notes:
[1] The following definition of genetic engineering is provided by the Non GMO Project: GMOs (or “genetically modified organisms”) are living organisms whose genetic material has been artificially manipulated in a laboratory through genetic engineering.
2 Pollack, Andrew, “Genetically Engineered Salmon Approved for Consumption” Nov. 19, 2015
GMO is most commonly referenced in conjunction with plant life. This study will focus on GMO application to artificial salmon organelle and the resulting environmental harm.
[2] Pollack, Andrew, “Genetically Engineered Salmon Approved for Consumption” Business Day, New York Times, Published November 19, 2015
[3] Description of the greenhouse gas effect: Understanding the Effects of Climate Change and Global Warming, provided by Dummies.com
[4] Homepage Nature Conservancy website: nature.org
[5] Aquabounty fails to cite a source for this statistic, name the research organization responsible, or list the entity that commissioned the study, thus the legitimacy of the alleged findings cannot be independently confirmed.
[6] According to the Union of Concerned Scientists, “Coal plants are the nation’s top source of carbon dioxide (CO2) emissions, the primary cause of global warming. In 2011, utility coal plants in the United States emitted a total of 1.7 billion tons of CO2.
[7] Edney, Anna, “'Frankenfish' Wins Approval as First Genetically Altered Animal” posted on Bloomberg.com on November 19, 2015
[8] Consumer Health Information, FDA. Nov. 2015
[9] Consumer Health Information, FDA. Nov 2015
[10] Protecting and Promoting Your Health, FDA. Questions and Answers on FDA’s Approval of AquaAdvantage Salmon
[11] Sinclair, Upton “The Jungle” written in 1906. The book was eye-opening and exposed rampant health neglect standards and corruption in the meat production industry. This novel is credited with being the driving force for establishing meat production regulations;
[12] According to the National Oceanic and Atmospheric Administration
[13] To be clear, when using the term “right” in this context, established principles of entitlement is meant. The varying degree of the ‘right’ should be determined by the reader. Is there a legal right or a moral imperative? Is there a combination of the two? If there is a legal right, under what body of law should citizens appeal the FDA decision? If there is only a moral imperative, does the government have an obligation?
[14] Protecting and Promoting Your Health, FDA. Questions and Answers on FDA’s Approval of AquaAdvantage Salmon
[15] Edney, Anna, Bloomberg.com
