This week, the US Food and Drug Administration (FDA) made public its environmental assessment (EA) on the material submitted in support of a new animal drug application (NADA) for a genetically-modified Atlantic salmon, the AquAdvantage Salmon.
The FDA's "finding of no significant impact" (or FONSI) advances the process of ultimate approval for sale and human consumption of this genetically-modified salmon in the US. According to this article published in the Independent (in the UK) on December 24th, 2012, "The verdict clears one of the last remaining hurdles for GM salmon to be lawfully sold and eaten in the US and will put pressure on salmon producers in Britain and Europe to follow suit."
Oddly enough, that article notes that the FDA completed its assessment in May of 2012, but decided not to publish its findings at that time, deferring instead until December 21, 2012. That seems to be a strange choice of a date, coinciding as it does with the conclusion of the Maya Long Count and thus one of the most anciently-anticipated dates known, as well as one with a tremendous amount of popular apocalyptic hype, partially inflamed by sensationalist videos over the years (such as this one from National Geographic).
This recent article by Jon Entine of the Genetic Literacy Project suggests that the delay by the FDA was due to the anticipation of the 2012 presidential election, and fears of alienating the voters in the incumbent's base, who generally oppose genetically-modified food in plant form and probably would not be too thrilled about the approval of the first genetically-modified animal for human consumption, as well as the potential impact on the natural ecosystems and existing salmon populations should genetically-modified salmon somehow escape into the wild.
Note that the Genetic Literacy Project is a non-profit organization dedicated to advancing the public acceptance of and increased use of genetically-modified organisms; the organization's website declares in its mission statement the assertion that "genetics is our future" because genetic modification can be "a source of dramatic innovations to improve food security, the environment and public health." They also state that they exist to combat the ignorance of "people who don’t understand risk and complexity" (that would appear to be anyone who doubts that "genetics is our future" or who don't believe that the potential risks of genetically-modifying living organisms using the rDNA of other organisms are necessarily outweighed by the supposed gains in "food security, the environment and public health").
Several previous posts have argued that the question of genetic modification of organisms is far more problematic than the "fear and misunderstanding" that arises among "people who don't understand risk and complexity," and that there may be excellent reasons to be very concerned about the creation and consumption of genetically modified foods. At the very least, it is an area that demands extensive analysis and the realization that there are many arguments on both sides that are worth hearing, rather than simply calling names and demeaning anyone who opposes your position on the subject.
Previous posts on this topic include:
- "Genetically-modified food"
- "Genetically-modified sugar beets, food labeling, and related issues"
- "Prop 37, genetically-modified food labeling, burritos, and stir-fry"
- "Straw-man arguments against Proposition 37, and a trip to the grocery store reveals . . ."
- "Why would anyone oppose the labeling of foods containing genetically-modified organisms?"
The FDA's recently-published examination of the merits of genetically-modified salmon for human consumption explain that the AquAdvantage salmon (which is referred to as "the construct") is created by introducing the recombinant DNA (rDNA) of three organisms into an Atlantic salmon: the anti-freeze protein gene (AFP) of the ocean pout, the coding sequence (cDNA) of the growth hormone (GH) of the Chinook salmon found in its pituitary gland, and two synthetic DNAs introduced as "synthetic linkers" (pages 18-19).
The FDA's literature confirms that these genetic modifications cause the construct to grow at rates that are from 2- to 6-fold the growth rates of a natural Atlantic salmon. Not only do they grow faster, but the introduction of the foreign DNA causes them to grow in cold waters, whereas normal Atlantic salmon only turn on their growth hormone in warm waters. The average size after an equal number of "degrees celsius days" of the construct versus a control group was 261.0 grams versus 72.6 grams! That's a big difference. At the end of that same period, only 4.9% of the control population had reached the 100 gram threshold, while 98.6% of the construct population had met or exceeded that size! (See page 41 of this FDA document).
The same FDA document explains that recently-issued changes to US Dietary Guidelines (published in 2010) "specifically recommend that Americans increase the amount and variety of seafood consumed by choosing seafood in place of some meat and poultry" and that "these recommendations are expected to further contribute to increased demands for seafood in the future" (page 20).
Putting aside the question of the advisability of having governments telling people what to eat (there is evidence that this advice has been quite harmful and often may have been based on completely erroneous analysis in the relatively short period of time since governments began interfering in the diet of the citizenry), does it necessarily follow that just because demand for seafood is expected to increase, it is advisable to introduce the DNA of other fish (along with synthetic DNA) into Atlantic salmon, and then to sell the meat of such "constructs" to satisfy the demand for seafood?
This article from the New York Times raises the question of whether increased levels of hormones in food animals might be linked to increased cancer risk in those who consume those animals. The article notes that some studies appear to indicate such a link.
There is also the question of the ethics of creating these genetic "construct" organisms, and the possible negative repercussions for the fish themselves. The FDA's recently-released study indicates that farm-raised salmon (and trout) appear to suffer from numerous ailments at much higher rates than their wild cousins. In a footnote beginning on page 27 of this FDA document and continuing onto the bottom of page 28, the FDA writes:
Morphologic irregularities do occur in non-transgenic salmonids, most commonly affecting cartilaginous and boney structures (Brown and Nunez, 1998), and are often associated with the development of new commercial lines or husbandry techniques and culture conditions. Developmental malformations of cartilage and bone have been observed quite commonly in association with intensive commercial farming of salmon (Salmo) and trout (Oncorhynchus) species [. . .]. These malformations include irregularities of the head, jaw, and operculum, and twisting or compression of the spine. [. . .] Veterinary field studies have identified the periodic occurrence of spinal compression (humpback) in 70% of salmon in Norwegian farming operations (Kvellestad et al., 2000), and jaw malformation in 80% of salmon at commercial sites in Chile (Roberts et al., 2001).
The report indicates that these irregularities appear to be caused by "suboptimal culture condition (e.g., nutrition, water quality, and environmental stressors)." It also notes that about 69% of salmon currently consumed in the US is farmed.
These are very sad statistics and should raise some ethical questions about farmed salmon, let alone about the creation of new "constructs" of salmon to be farmed (the genetically-modified constructs will be grown from eggs in Canada and then shipped to heavily-secured farm pens in the highlands of Panama, to prevent their escape into the wild, and they will be designed to be all-female and "triploid" or having triple the genes of a fertile female salmon, so that they will be infertile just in case one or more do escape).
The conditions described above also bring to mind the two previous posts (here and here) which examined two texts by the ancient author (and priest of Apollo) Plutarch, entitled "On the eating of flesh." In those essays, Plutarch asks "what madness, what frenzy drives you to the pollution of shedding blood, you who have such a superfluity of necessities?" He argues that, when so many plants grow for our nourishment and enjoyment, we cannot justify the slaughter of other creatures merely for taste. He further argues that the fear that the increase of the earth cannot feed us indicates a lack of faith in the divinities that provide the food (he names Demeter and Dionysus in his essays). His final argument is that animals are conscious beings, and there is the added possibility of the survival and reincarnation of the consciousness, which should tip the scales against the horrible mistreatment of animals that are kept for slaughter and consumption.
These arguments should be carefully considered before humanity rushes to begin creating and consuming genetically-modified animals on a mass scale, starting with salmon.