AquAdvantage update

In Risk assessment and mitigation of AquAdvantage salmon I discussed exactly what Aqua Bounty was asking permission from the FDA to do, as well as the environmental, animal welfare, and human health concerns associated with the AquAvantage fish in comparison to non-transgenic farmed salmon.
The Center for Food Safety has a “new” document to bring to the discussion: an opinion (pdf) written by the National Marine Fisheries Service regarding a U.S. Army Corps of Engineers proposal about ocean net pens to raise finfish off the coast of Maine that was written in 2003. CFS talks about this letter in a blog post titled Newly Disclosed Government Documents Conclude GE Salmon Pose A Critical Threat To Marine Environments. Let’s just say there’s a few errors in the reasoning found in the blog post and indeed all over the GFS site about genetically engineered fish. Here, I’ll go over the blog post (I’ll let our excellent commenters take a look at the rest of the site) and discuss some of the errors.
The post opens with:

Adding a new twist to the controversy over genetically engineered (GE) salmon, the Center for Food Safety (CFS) revealed today that, in recent hearings on transgenic fish, the U.S. Food and Drug Administration (FDA) knowingly withheld a Federal Biological Opinion by the U.S. Fish and Wildlife Service (FWS) and National Oceanic and Atmospheric Administration (NOAA) prohibiting the use of transgenic salmon in open-water net pens pursuant to the U.S. Endangered Species Act (ESA).

Is this fish crying? Maybe she read the CFS blog post.

The problem is that the opinion wasn’t about genetically engineered salmon. It was about the risks of any ocean farmed salmon, with a fairly small amount of discussion of transgenic fish (less than 3 pages of a document totally 101 pages, with a full 61 pages of text). Is this opinion relevant to the application by Aqua Bounty to raise transgenic salmon in two very specific land based facilities? Perhaps. Here’s everything the report says about transgenic fish:

page 27 Transgenic salmonids are prohibited at these facilities [referring to a list of permitted ocean pen fish farms]. Transgenic salmonids are defined as species of the genera Salmo, Oncorhynchus and Salvelinus of the family Salmonidae and bearing, within their DNA, copies of novel genetic constructs introduced through, recombinant DNA technology using genetic material derived from a species different from the recipient, and including descendants of individuals so transfected. This prohibition does not apply to vaccines.
page 34-35 [at the very end of the section Disease Factors, Predators, and Competitors discussing concerns of farmed salmon] Atlantic salmon and rainbow trout produced by the aquaculture industry (including non-North American strains and potentially transgenics) that escape from hatcheries or net pens also compete with wild Atlantic salmon.
page 74-75 [under the heading Transgenics]
The potential use of transgenic salmonids in the aquaculture industry has recently been identified as a possible threat to wild Atlantic salmon populations. Transgenic salmonids include fish species of the genera Salmo, Oncorhynchus, or Salvelinus in the family Salmonidae that bear, within their DNA, copies of novel genetic constructs introduced through recombinant DNA technology using genetic material derived from a species different from the recipient, and descendants of any individuals so transfected. Escaped, reproductively viable transgenic salmon could interbreed with wild fish. Research to develop transgenic fish for aquaculture increased through the 1980s and had advanced to the extent that, by 1989, production of 14 species of transgenic fish, including Atlantic salmon, had been reported (Kapuscinski and Hallerman 1990).
Transgenic fish produced for culture in marine net pens must be selected to survive under nearly natural physical and chemical environmental conditions. If they escape, therefore, it is likely that. a portion of them will survive. In a study by Sheela et al. (1999), transgenes were inherited in many progeny from transformed fish, as determined through DNA analyses and through expression of the reporter gene. If an introduced construct can find its way onto or into a chromosome before the first cell division of a newly-fertilized egg, all the cells in the developing organism, including future germ cells, will contain copies (Lutz 2000). The transmission of novel genes to wild fish could lead to physiological and behavioral changes, and traits other than those targeted by the insert gene are likely to be affected. Ecological effects are expected to be greatest where transgenic fish exhibit substantial altered performance. Such fish could destabilize or change aquatic ecosystems (Kapuscinski and Hallerman 1990).
In a study by Cook et al. (2000), growth-enhanced transgenic Atlantic salmon exhibited a 2.62- to 2.85-fold greater rate of growth relative to non-transgenic salmon, over the body weight interval examined. This study found that the transgenic experimental subjects possessed the physiological plasticity necessary to accommodate acceleration in growth well beyond the normal range for this species, with few effects other than a greater appetite and a leaner body (Cook et al. 2000). Because aquatic ecosystems function through complex interactions involving transfers of energy, organisms, nutrients, and information, it is difficult to predict the community-level impacts of releasing transgenic fishes that exhibit one or more types of phenotypic change (Kapuscinski and Hallerman 1990). At this time, more research is needed to identify the impacts that escaped transgenic salmon would have on natural populations and their habitat before use for commercial aquaculture is considered.
Research and development efforts on transgenic forms of Atlantic salmon and rainbow trout are currently being directed toward their potential for sea pen aquaculture. Emphasis has been placed on enhancement of growth and low water temperature tolerance through the transfer of genetic material from other cold-tolerant species, such as flounder. In 2002, the Food and Drug Administration received an application for approval to sell and possibly grow transgenic salmon in the United States for use by the aquaculture industry.
The prohibition on the Use of transgenic salmonids at existing marine sites off the coast of Maine (Special Condition No. 2) will eliminate the potentially adverse disease and ecological risks posed by the use of transgenic salmonids in aquaculture. The risk posed by a transgenic salmonid to wild salmon would be greatly affected by the specific gene manipulation conducted. Anyone proposing the use of transgenic salmonids in aquaculture would need to provide information on the methods used and the potential for genetic, fish health and ecological impacts on wild stocks. This information would have to be evaluated to determine the level of risk posed to wild Atlantic salmon stocks and a decision would have to be made as to whether that level of risk was acceptable or not. The use of transgenic salmonids will be prohibited under Condition No. 2 until such time as these risks can be evaluated.

A slightly better than superficial reading of this discussion of transgenic salmon reveals that the National Marine Fisheries Service is strongly recommending a ban on transgenic salmon in ocean pens due to concerns that the transgene will make the fish more fit than non-transgenic fish and that such a transgene would spread through natural populations if the accidentally released transgenic fish were reproductively viable. Anyone wanting to use transgenic salmon in aquaculture would need to provide clear information about the specific risks they may pose to wild salmon (which is exactly what Aqua Bounty did). I’m not sure if this recommendation was codified – if anyone knows, please provide that information in the comments.
CFS concludes something a little different:

“This adds further evidence that in fact GE salmon pose a serious threat to marine environments and is another compelling reason for the FDA not to approve the fish for commercial use,” said Andrew Kimbrell, Executive Director of the Center for Food Safety.  “While the FDA applauded the company’s choice of land-based containment as responsible, it never revealed that it is illegal in the U.S. to grow genetically engineered salmon in open-water net pens.”

Is it actually illegal to raise transgenic salmon in open water pens? If it is illegal, is that relevant to a discussion of land based aquaculture? The differences between risks of ocean based compared to land based aquaculture are quite large, whether we’re discussing transgenic or non-transgenic fish. All ocean based aquaculture was determined by the same report to be quite risky to wild fish:

page 79 [Conclusion] Based on the close proximity of hundreds of fish pens to the GOM DPS [Gulf of Maine Distinct Population Segment] of Atlantic salmon, and the anticipated continued escapes, the best available scientific data and commercial information indicates that the continued operation of Maine aquaculture facilities poses a threat to individual wild salmon because escaped aquaculture salmon compete for food and habitat, disrupt redds, interbreed, thus disrupting breeding, feeding and sheltering of wild Atlantic salmon. Aquaculture facilities may also promote the transfer of disease and parasites to wild salmon, which may also adversely affect wild salmon.

The National Marine Fisheries Service thinks that the permit procedure and the special conditions the U.S. Army Corps of Engineers recommends will help mitigate the risk to wild fish. The special conditions (presumably applying to ocean pen aquaculture since that’s what the entire opinion is about) are:

(1) eliminating the use of non-North American strain Atlantic salmon; (2) developing containment management systems with loss control plans and audits; (3) marking aquaculture fish; (4) prohibiting the use of transgenic salmonids; and (5) requiring fish health certification before stocking alternative salmonids.

CFS thinks that this report means that transgenic fish are a great threat, but it’s clear that National Marine Fisheries Service thinks that all ocean pen aquaculture is a great threat. National Marine Fisheries Service seems to think that these conditions are enough to mitigate the risk, although I am skeptical. Anyway, the only thing that sets transgenic fish apart is that there are more unknowns, or at least there were at the time, when the literature indicated that fast-growing salmon would be better able to compete than salmon without a growth hormone transgene. Later studies have shown that the fast growing salmon have behavioral phenotypes that actually make them less likely to survive than non-transgenic salmon. For example, fast growing salmon are more fearless such that they are more likely to be eaten by predators.
An opinion (pdf) by the Environmental Protection Agency in 2001 on the same subject (whether there should be ocean pen fish farms allowed off the coast of Maine where there are a lot of wild salmon) says pretty much the same thing, with some of the text seemingly cut and pasted from the 2001 Environmental Protection Agency opinion to the 2003 National Marine Fisheries Service opinion.
Anyway, CFS thinks that since these two documents weren’t presented earlier, that must mean the FDA is keeping information from the public. Maybe, but it seems more like these documents weren’t relevant to the discussion of Aqua Bounty’s application for land based facilities rearing fish that are sterile 98% of the time or more (on average).
The CFS post concludes:

Conversations between NOAA and FWS staff in 2009 highlight a Swedish study that found that in simulated escapes, transgenic fish have a “considerably greater effect on the natural environment than hatchery-reared, non-transgenic fish when they escape.” The study further noted that genetically modified fish survive better when there is a shortage of food, benefit more than non-transgenic fish from increasing water temperatures, and can be more resistant to environmental toxins that may ultimately end up in consumers.

Why does’t anyone ever provide a proper citation? According to Web of Science, there were 2,044 papers about salmon published in 2009. Out of the subset of 28 papers that also included the word transgenic, I think the study they’re referring to is:
ResearchBlogging.orgL. Fredrik Sundström, Wendy E. Tymchuk, Mare Löhmus, & Robert H. Devlin (2009). Sustained predation effects of hatchery-reared transgenic coho salmon Oncorhynchus kisutch in semi-natural environments. Journal of Applied Ecology, 46, 762-769 : 10.1111/j.1365-2664.2009.01668.x
This study didn’t mention toxins at all, or temperatures, but did find that transgenic fish with a growth enhancing gene ate more than non-transgenic fish, at least at first. After about two months, all fish were the same size (not significantly different sizes), including: non-transgenic fish, transgenic fish that were fed an amount of food that restricted them to approximately the same size as non-transgenic, and transgenic fish that were allowed to eat as much as they wanted. The reduced swimming capacity of the transgenic fish that were allowed to eat as much as they wanted led to higher ability of prey to swim away, leaving those prey for other fish. It wasn’t apparent from this study that transgenic fish would have a greater effect on the environment than non-transgenic farmed fish.
Finally, there wasn’t any mention in the Environmental Protection Agency or National Marine Fisheries Service documents about  risks of fish bred for specific traits such as fast growth to wild fish. The natural variation in salmon populations for size, growth rate, etc is pretty wide. It’s very possible that a breeding program could develop super salmon without any genetic engineering and those super salmon could potentially be a threat to wild salmon, particularly if they were farmed as reproductively viable individuals in ocean pens near by wild salmon populations. Perhaps this is covered by special condition 1: “eliminating the use of non-North American strain Atlantic salmon”? This is unlikely to have any real positive effect, since the problem of ocean farmed salmon escaping is that they spread a) disease and b) genes that are far less diverse than those in wild populations even when they are of the same strain. I stand by my previous assertion that both ocean farmed non-transgenic salmon and fishing of wild fish are a greater risk to wild salmon than transgenic salmon in land based facilities.

Hat tip to Mark Bittman (@bittman) for creatively tweeting about the CFS blog post:

FDA hid evidence about threats posed by genetically engineered salmon. Your tax $ at work:

I’ve been a strong advocate of Bittman’s work. He advocates a diet that is mostly plant based  for environmental and health reasons but allows meat as an indulgence. I have a lot of respect for his stepping out with this rare practical viewpoint. I love his How to Cook Everything Vegetarian and recommend it to everyone, especially if you’re not an experienced cook. But, I don’t love uncritical tweets. Mark, if you happen to read this, please, please consider some critical thinking material such as the Skeptoid podcast where Brian Dunning takes the listener through the process of claim, evidence, evaluation of claim.


  1. Poppa – I believe Anastasia was bemoaning the lack of a citation to scientific literature, your link does absolutely nothing to remedy this.
    ScienceDaily != peer reviewed scientific literature

  2. Amusingly, I did consider using that article, especially because it makes my point very well:

    “One option is to farm the transgenic fish on land, which would make escape impossible. At least fertile fish should be kept in a closed system,” says Sundström.

    However, the article didn’t point to anything peer reviewed and made some sweeping conclusions without providing any evidence so I disregarded it. The article doesn’t even discuss details of any research.
    If you look at the paper I did use, you’ll notice that it is the same primary author.
    Ewan – that peer-reviewed article is certainly relevant but it isn’t from 2009 and CFS referred to a study from 2009.

  3. I read the Sciencedaily link as well. It seemed to support Anastasia’s analysis considering that it twice suggested that such fish be grown inland. It also discussed traits other than the one being considered such as resistance to toxins, and the CFS post cites uses it to say that people will be exposed to more toxins. So thanks to Poppa D poppin’ over here, we now know that the CFS has also used a different trait to mislead people about the trait under consideration.

  4. Science Daily is completely authoritative, if you believe in science-by-press-release.

  5. There is a strange contradiction in the GM salmon narrative which deserves explanation.
    It is claimed that, since the salmon are grown in tanks on dry land, they can be grown closer to consumer markets.
    Why, then, is one GM salmon farm in Panama, and the other in Canada? That’s really not much of an improvement over the status quo.
    Among all the advantages ascribed to GM salmon, I find proximity to consumer markets the most important. If you’ve never had fresh, non-frozen etc. salmon, you’ve never had salmon. Fresh salmon qualifies as a true delicacy.

  6. I haven’t seen anyone argue that GM salmon will allow for closer proximity to markets. Perhaps this was an argument for land-based fish farms in general? I’ve seen some nifty coverage of urban fish farms in gutted factories and such, but that’s a different subject.
    There aren’t two fish production facilities. The farm in Canada is for eggs and the farm in Panama is for growing those eggs to fish. The locations weren’t chosen for proximity to market but for their specific environmental conditions and other factors. I’m guessing that the proximity of the egg facility to the parent company probably was a factor as well.

  7. This question is explicitly addressed beginning on p 112 of the document linked by Poppa D. Basically, the company believes the initial facility in Panama would demonstrate that the fish can be safely cultured and successfully contained. That would set the stage for other facilities, each of which would need a new review and approval by FDA before they could begin farming the gmos.

  8. I am confused now.
    First, Aqua Bounty’s intent to have many smaller land based facilities isn’t mentioned on their website, any of the press I’ve seen, the reports for the FDA, or anywhere but this testimony – and I read a lot of stuff about GE salmon for my last post. I had assumed that eventually the AquAdvantage fish would be grown by other producers (after proper evaluation of the land based facilities, etc) but didn’t know it was the intent from the beginning.
    Second, why go through all the trouble of making separate egg and fish facilities when the intent is to have all in one facilities? It seems to me that they should have made a single facility in Panama that would have met all of their goals (as described by Ron Stotish of Aqua Bounty in response to a question by Alison Van Eenennaam on page 12 of the document that Poppa shared):

    We established the location that is listed in the environmental assessment in Panama as an initial production facility to demonstrate that, number one, you could grow this salmon outside its normal geographical range; number two, this fish could be grown safely in containment; and also to demonstrate that was a — not only an economic development opportunity for a lot of countries, including the United States, but that this fish can now be grown closer to those population centers, as I mentioned. Our view, and I started this talk by saying that we are a technology company, we are a technology and genetics company. We do not wish to be the next Marine Harvest. We do not want to be the world’s largest salmon producer. We want to supply technology and solutions to that industry. But we had to establish that the safe — and demonstrate the safety of this product in cultivation. We believe that we will be able to have facilities inspected and complete EAs and file applications to the FDA beyond the initial approval, should an approval be granted, that would allow the use of other facilities. And we believe that those sites, not unlike drug manufacturing sites, will be inspected and certified and acceptable and periodically inspected by the Agency.

    Perhaps the site in Canada already existed for their research so they decided to use it for egg production?

  9. Thank you, I hadn’t had a chance to look at this document. It has a lot of interesting material. I’m particularly pleased to learn about Aqua Bounty’s plans for continued genetic improvement of their fish, which starts on page 116. It’s a good reminder that, while genetic engineering can do a lot, breeding continues to be an essential part of developing desirable traits and moving those traits to new lines.

  10. Anastasia,
    I can only speculate. First, biotech companies are often coy about their long term business plans, if they think it will be detrimental to publicize them too soon. I don’t know if that’s the case here, but given the anti-GMO fervor, it wouldn’t surprise me. Perhaps they think if they can get one facility running and develop a good track record with no escapes, etc., it will reduce the (arguably irrational) opposition and make other facilities more politically platable.
    As for separate egg & fish facilities, I’m not sure why they made those separate to begin with, but I also don’t see where the quoted passages suggests they want to bring them together later. Couldn’t they supply multiple fish facilities from a single, separate egg facility? That would allow the fish to be raised near major population centers, making them cheaper and fresher for local residents, while still allowing high containment at a single egg facility. I assume shipping the eggs to multiple fish facilities would be relatively cheap.

  11. You’re right! Perhaps it would make more sense to have one egg facility, where Aqua Bounty can keep developing improved genetics, have control over the neomale and triploidization process, and maintain strong environmental containment. Then the eggs can be relatively cheaply shipped to growout facilities. Why not? That’s how we do seeds, right? Cool.

  12. Grist author Tom Laskawy has written a post about the CFS post: What the FDA doesn’t want you to know about GE salmon. I’ve commented there, referring to my post here. Just in case my comment disappears, I’m putting it here for posterity. Their commenting system sucks, so I actually had to post this as two comments since it kept randomly cutting parts of my comment out and screwing up the html.
    Hello Tom. It is a real problem that the regulatory system doesn’t have a built in requirement to seek relevant expertise in other agencies. It’s also a real problem that companies have the ability to request information be kept secret from the public, especially when the information from safety testing wouldn’t have any negative impact on a company’s intellectual property if released. I’d gladly join you in advocating for more inclusion of experts from relevant government agencies and more (if not full) disclosure of data when it comes to regulation of many products, not just biotech.
    However, you and the CFS are’t presenting the full picture here. The 2003 opinion (pdf) written by the National Marine Fisheries Service was actually about a proposal to raise non-GE finfish off the coast of Maine in net pens. It wasn’t, as the CFS states and you repeat, about GE salmon. There were a few paragraphs about GE salmon in there, as you can read in the opinion linked above. I’ve also pulled every section dealing with GE salmon out of the report and posted them for the reading convenience of persons such as yourself on Biofortified: AquAdvantage Update. The report concluded that any ocean pen fish farming was problematic for wild fish populations. The report isn’t really useful in discussion of AquAdvantage for a lot of reasons, many of which I lay out inRisk assessment and mitigation of AquAdvantage salmon, namely because this particular proposal for GE fish is for land based production only and has many layers of containment that does much to mitigate risk to wild fish (unlike current non-GE ocean pen fish farms).
    (continued from previous comment)
    Finally, this sentence “government scientists have apparently established that GE salmon would out-compete native species for food, may have adaptive advantages in warming waters, and might collect environmental toxins in their flesh at higher rates than native species” seems to refer to this part of the CFS post:

    Conversations between NOAA and FWS staff in 2009 highlight a Swedish study that found that in simulated escapes, transgenic fish have a “considerably greater effect on the natural environment than hatchery-reared, non-transgenic fish when they escape.” The study further noted that genetically modified fish survive better when there is a shortage of food, benefit more than non-transgenic fish from increasing water temperatures, and can be more resistant to environmental toxins that may ultimately end up in consumers.

    One Swedish study doesn’t quite = government scientists establishing something. I tried to find said Swedish study but was unsuccessful. Biofortified commenter Poppa D helpfully suggested that CFS was referring to a 2009 Science Daily article Risks Involved With Transgenic Fish that does indeed seem to be the source. Unfortunately, the article contains a lot of speculation but not much science. For example, the author speculates that fish genetically engineered to thrive in high toxin environments might have higher toxins. Something to consider if we were looking at toxin tolerant fish, but not relevant for AquAdvatage. The article does conclude that land-based facilities for GE fish are the way to go. Peer-reviewed articles from the same author conclude similarly. The only peer-reviewed article about transgenic salmon from 2009 that has a Swedish author is Sustained predation effects of hatchery-reared transgenic coho salmon Oncorhynchus kisutch in semi-natural environments, which found that salmon genetically engineered for faster growth didn’t have a greater impact on wild fish than non-GE farmed fish.
    This is a complex subject – when information is misrepresented or left out our ability to intelligently discuss it decreases quickly. Just because CFS does it doesn’t mean that we should follow their example.
    Disclaimer – I have no financial, emotional, whatever connection to Aqua Bounty or any other biotech company. I’m just a doctoral candidate studying genetics.

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