GMOs — “Frankenfish” Just One of the Problems
By Zeke Grader and Glen Spain
Last year we waited. In late 2012, the Food & Drug Administration (FDA) indicated it was prepared to approve the first genetically engineered fish, indeed the first genetically engineered animal, for human consumption. We submitted comments, consulted lawyers, and waited throughout 2013 for a decision.
Perhaps by the time you read this the FDA will have acted on AquaBounty’s pending application to market its genetically engineered, or genetically modified organism (GMO), faster-growing Atlantic salmon (dubbed “Frankenfish”) for aquaculture in the U.S. After all, in late 2013 Environment Canada did approve the Massachusetts-based biotech company’s application to develop the eggs for these GMO salmon at a Prince Edward Island AquaBounty facility. From there, the eggs would be exported to Panama where the fish would be raised to maturity, slaughtered and exported for sale in the U.S. and other developed world markets.
More Than Steroids
AquaBounty?’ purpose for inserting a gene from a Chinook salmon and one from an ocean pout into an Atlantic salmon was to make the fish continuously grow and be ready, as a result, for harvest in 18 months rather than 3 years. Their claimed advantage would be a saving to the fish farmer in feed costs. However, these fish are not more nutritious, nor has their diet changed (e.g., creating a purely vegetarian salmon), nor are the fish more warm-water tolerant — a consideration with climate change. The single “advantage” of “AquaAdvantage” GMO salmon is its fast growth rate.
AquaBounty’s GMO salmon, the FDA concluded, are “safe to eat” — and that, it seems, is about as far as the agency looked into the implications of growing and putting these genetically modified fish onto the market or the ecosystem.
Of course there are lots of foods the FDA finds safe that others may question, particularly for the long-term health impacts of many foods currently in the American diet. But the FDA, like the USDA, is largely under the thumb of the big food and chemical corporations, including, it seems now, Big Biotech. So unless some substance in question immediately makes you sick or kills you, you can expect FDA approval.
Okay, if AquaBounty’s GMO salmon will not kill you or make you sick, at least not immediately, what’s the problem? Whether or not these genetically-engineered fish are safe to eat, there are two other GMO issues that bear consideration. First is the consumer and marketing issue. Second is the issue of wild salmon mitigation and supplementation.
Consumer Lack of Choice
The FDA, at least based on its December, 2012 statement, is not going to require the labeling of these GMO fish. Thus, while country-of-origin-labeling (COOL) is required for most seafood products, as well as whether the fish is wild-caught or farmed, there is currently no requirement — outside of Connecticut and Maine currently, by state law — for the GMO labeling of these fish or any other genetically-engineered food. Given the power of the industrial agricultural lobby — 90 percent of the nation’s corn, soy and sugar beet production is now genetically-engineered — the big food lobby and the growing power of the biotech industry in places such as Massachusetts and California, don’t expect Congress to rush to require GMO labeling. The Grocery Manufacturers Association (GMA), for example, is pushing national legislation that would make GMO labeling voluntary only.
Consumers, as a result, will be left in the dark. True, in many instances salmon is labeled either “wild-caught”or “farmed,” so informed consumers will know to choose wild salmon if they don’t want GMOs. This is one reason a number of large salmon farmers are opposed to FDA approval of GMO salmon. But even the existing salmon labeling requirement of wild and farmed doesn’t extend to every application, and restaurants can and do label the fish simply as salmon, leaving it to the consumer to guess what they’re getting or be left to cross-examiner their waiter.
If the FDA is going to approve these fish, at the very least they should do it conditioned on these fish being accurately labeled as GMOs so consumers have a choice.
Who’s Going to Pay?
Second, we fully expect, if the FDA approves, that it’ll be only a matter of time before AquaBounty or some other biotech fish operation is back arguing for rearing the fish “closer to their major markets,” which isn’t Panama. No doubt a carbon footprint case will be made for rearing the fish in the U.S. or Canada or both. For the foreseeable future anyway, this means rearing GMO fish in open-water net pens and the certainty of escapes.
GMO fish escaping nets pens place fishermen and government hatchery operations alike at risk for lawsuits from the biotech companies holding the patents to these fish. Will fishermen have to pay AquaBounty for any escaped GMO fish they may accidentally catch in the wild? Will government fish hatcheries have to pay AquaBounty for any escaped GMO salmon that end up in the returns to their hatcheries?
Don’t scoff — if the current legal precedent for the Monsanto cases against farmers whose crops were inadvertently cross-contaminated with Monsanto’s GMO seeds holds up, fishermen and public hatcheries could also be sued this same way. And, under the perverse rulings of the current Supreme Court majority (remember that corporations are “persons,” and their campaign contributions are “free speech”?) fishermen and public hatcheries could be held liable for payment to AquaBounty or some other biotech fish manufacturer because of GMO salmon escapes.
Into the Wild
A compelling case is being made for moving salmon farming to onshore, contained recirculating water facilities. At that point GMO fish would be much less of a threat. But this is not going to happen overnight, despite the compelling reason for onshore aquaculture — eliminating pollution (including that from herbicides, pesticides and antibiotics used in net pen operations), reducing feed waste, reducing the incidence of disease and parasites, and eliminating the escape problem.
Moreover, there is opposition from many of the large salmon farm operators to moving their operations onshore — particularly since they currently can externalize their pollution costs and even get government subsidies for fish losses. Worse, NOAA, anxious to keep its nose in aquaculture — which they see can happen only if it occurs in the ocean — is actively pimping open ocean aquaculture, actively ignoring the many threats posed by open ocean net pens.
What could happen when fast-growing GMO salmon raised in open ocean net pens escape to the wild, as they inevitably will? Many fish biologists fear the “Trojan Gene” effect in which fish from these fast-growing GMO stocks could outcompete smaller wild fish for mates, and the less adaptive genes from these escaped GMO fish could then intermingle into the wild salmon gene pools, resulting in a major crash of these wild stock populations over time. See for instance, the 2004 study, “Transgenic Male Advantage Provides Opportunity for Trojan Gene Effect In a Fish,” www.pnas.org/content/101/9/2934.abstract).
Remember, no aquacultured fish sterilization program is 100% effective. Once they escape, there will be some inbreeding. But modeling projections show that the combination of genetic contamination and competition with naturalized, fast-growing GMO salmon could wipe out wild salmon populations within just a few dozen generations.
None of these biological and pollution impacts were seriously considered by the FDA, which is limited in its mandate to considering just immediate human food safety issues, not ecosystem impacts.
What?s for Dinner?
Here it useful to state that GMOs potentially hold a great deal of promise for addressing food security in a world where food shortages are expected to become critical as a result of population growth, growing prosperity in the developing world causing a change in diets, and climate change disruption to food production. Genetically engineering a plant, for example, to contain more nutrients, or be drought or heat resistant could be beneficial. The example of “golden rice” is often trotted out by GMO proponents as to why genetically-engineered foods are needed.
The reality of GMO foods, however, is that they’re not being developed for nutrition or climate conditions, but to allow a few big biotech companies to hold the patents on seeds and, in the case of plants such as Monsanto’s “Roundup Ready” corn and soy, to make the plants more tolerant to heavy doses of Monsanto’s glyphosate herbicide “Roundup.”
Nearly all GMO crops currently in production have been either genetically modified to be herbicide resistant or developed to produce an internal pesticide. What this means is that the herbicides being sprayed on these crops — because of heavier usage — are more likely to get into the environment, including waterways where they can affect fish health. For those manufactured to produce an internal insecticide, it means that whatever eats that plant — human or animal — will be getting an extra dose of that insecticide.
Increased crop production of herbicide resistant plants has led to more herbicide use. Making matters worse, the heavy use of “Roundup” has now created a type of “superweed” resistant to the herbicide. This has now led the chemical companies to begin development of new plants resistant to other herbicides; at the top of that list are those resistant to 2,4-D, similar in make-up to other phenoxy herbicides — 2,4,5-T, Silvex, and Agent Orange (remember Vietnam?). These are the same chemicals PCFFA fought in the late 1970’s when they were being sprayed over salmon streams in forested watersheds for “conifer release.” They are highly toxic to fish.
With the justifiable clamor to eliminate wild fish (e.g., sardine, anchovy, herring) for use as aquaculture feed, there has been increased interest in substituting current animal-based feeds with those made from plants. Unfortunately, rather than focus on invasive plants and animals as a possible feed source, as well as fish offal, the aquaculture operators are focused primarily on soy as the alternative feed. And, most all of that is GMO. So if consumers are feeling safe avoiding GMO fish, they actually aren’t if they’re still getting GMOs that were fed to the fish.
One salmon farmer — Verlasso, a joint venture between AquaChile and chemical manufacturer Dupont — is already feeding its fish on a diet of genetically-engineered yeast. And, anxious to demonstrate its support for fish farmers using alternative feeds, Monterey Bay Aquarium’s “Seafood Choices” questionably put these farmed fish into their yellow category as “best choice,” the same as Pacific Coast wild-caught Chinook. But rearing in open-water net pens and feeding them this GMO concoction is hardly sustainable — more like the bride of Frankenfish.
Actions by the Numbers
For the fishing fleet, what all this means is the need to be prepared to act on multiple fronts. This includes:
- Opposition to any approval of GMO salmon;
- Support for Congressional legislation to require consumer labeling of GMO fish, such as the bi-partisan measure introduced by the Alaskan delegation;
- Opposition to any attempt to certify open ocean net pen, or GMO-fed farmed fish as either “organic” or “sustainably-produced”;
- Support for mandating that all finfish aquaculture be restricted to onshore, closed recirculating water systems;
- Support for development of sustainable, non-GMO feed sources, including those made from fish offal and invasive species, for fish farming;
- Opposition to development of GMO crops that introduce chemical poisons into the environment (e.g., “2,4-D Ready” corn and soy);
- Support for stricter restrictions on GMO development except for engineering for increased nutrition or drought resistance, and finally;
- Support the naming of a federal lead agency for aquaculture development charged with, among other things, the protection of the natural environment, the protection of wild fish and capture fisheries, and the development and approval of only environmentally-sustainable forms of aquaculture.
Our year and more of waiting may be over. Frankenfish and its potential landing on the U.S. market has garnered its share of headlines over the past few years and we’re likely to be faced with an FDA approval this year. We’ve got to fight it.
But amidst all the clamor created by Frankenfish, let’s not lose sight of some equally odious GMO issues that may be an even greater threat than anything Mary Shelley conceived or AquaBounty developed.
Zeke Grader is PCFFA Executive Director, and can be reached at PCFFA’s SF Office at PO Box 29370, (415)561-5080 x 224, Email: firstname.lastname@example.org. Glen Spain is PCFFA NW Regional Director and can be reached at PO Box 11170, Eugene, OR 97440-3370, (541)689-2000, Email: email@example.com.