Fast-growing genetically engineered salmon approved

genetically engineered salmon could make sushi more sustainable

Developers of the fast-growing genetically engineered salmon first started the approval process with the United States (US) Food and Drug Administration (FDA) in 1995. In 2019, we are a bit closer to having the option of buying this fish for ourselves, as the FDA clears the final regulatory hurdle to allow sale of AquAdvantage salmon.

In this article, learn how the salmon was created, what regulatory steps were completed, and about the health and environmental impacts of fast-growing genetically engineered salmon.

genetically engineered salmon could make sushi more sustainable
Genetically engineered salmon could make foods like this salmon nigiri more sustainable and affordable.

How were fast-growing GMO salmon created?

"Salmoneggskils" by en:User:Kils - en:Image:Salmoneggskils.jpg. Licensed under CC BY-SA 3.0 via Commons.
Atlantic salmon eggs by Hoenny via Wikipedia.

Canadian researchers created the fast-growing genetically engineered salmon with a growth hormone gene from Chinook salmon and a gene promoter from ocean pout. They microinjected the transgene into fertilized eggs of wild Atlantic salmon, and characterized the insertion.

The resulting genetically engineered fish are ~99.99986% Atlantic salmon, with the addition of just 4,205 base pairs in a genome of 2.97 billion bases. Further, the growth hormone proteins from Chinook and Atlantic salmon are 95% identical. This leaves the ocean pout promoter as the only “new” element. The developers chose this promoter because genes it controls are continually expressing – always on – as opposed to the salmon promoter for growth hormone, which is only on in certain environmental conditions.

Even though the inserted growth hormone gene is always on, it doesn’t have much of an effect unless the fish have access to food. When allowed to eat as much as they want (fed to satiation), juvenile AquAdvantage salmon can grow nearly 3 times longer than conventional juvenile Atlantic salmon. But in a simulated natural environment with limited food, juvenile AquAdvantage salmon grew only a little larger than juvenile conventional salmon.

While AquAdvantage salmon grow faster, they do not grow larger overall – adult AquAdvantage salmon and adult conventional Atlantic salmon are the same size. The genetically engineered fish just get to that size faster and with less feed. As FDA describes, “the overall total amount of feed required to produce the same fish biomass was reduced by 25%” for AquAdvantage salmon.

fast-growing genetically engineered salmon
Juvenile AquAdvantage salmon and juvenile wild salmon raised under different conditions. Image from Gene-environment interactions influence ecological consequences of transgenic animals.

Farmed fish are the future

There will always be a place for wild-caught fish on our plates, just as there is a place for other speciality products like heirloom pork, wild mushrooms, and so many other wonderful things. But in a world with a growing population and a growing demand for nutritious fish like salmon, we can not rely only on wild stocks. Aquaculture is a necessity.

Wild-caught Pacific salmon are not able to meet demand, in part due to vulnerability to higher water temperatures related to climate change. In 2018, US west coast salmon fisheries along Washington, Oregon, and California requested fishery disaster assistance from the Department of Commerce due to commercial fishery failures in 2015, 2016, and 2017.

Even as wild fisheries decline, demand for salmon is increasing. In 2016, the US imported ~339,000 metric tons of salmon, mostly farmed Atlantic salmon raised in cages in the ocean, as Richard Martin reports in Genetically engineered fish is not a matter of “if” but “when”. In 2018, the US imported 403,107 metric tons of all types of salmon, with a value of over $4.1 billion, (327,116 metric tons and $3.4 billion of Atlantic salmon alone) according to the National Marine Fisheries Service.

The Monterey Bay Aquarium Seafood Watch rates indoor farmed salmon (raised the way genetically engineered salmon would be raised) as a “Best Choice.” Fish that grow faster will consume less feed, take less energy, decrease prices for consumers, and potentially provide a product with fewer parasites than ocean-raised fish. All this, with the potential to create jobs in the US with additional rearing facility locations, and to decrease reliance on ocean-based farms and open-air ponds that pose known risks to ecosystems.

Screenshot from Monterey Bay Aquarium Seafood Watch.

How were GMO salmon regulated?

In the US, AquAdvantage salmon required two assessments: one to determine safety of a new animal drug that would be entering the food supply (under the Coordinated Framework for Regulation of Biotechnology, new genes and gene products in genetically engineered animals are regulated as animal drugs by the FDA), and one for potential risk to the environment (as required under the National Environmental Policy Act).

In Canada, AquAdvantage salmon required three assessments: one for safety and nutrition of the salmon for use as food, one for safety and nutrition of the salmon for use as a livestock feed, and one for potential risk to the environment.

AquAdvantage salmon regulation
View more detailed timeline information and download the full size infographic: AquAdvantage Salmon Regulatory Timeline

Is genetically engineered salmon safe?

The regulatory process may have been lengthy, but one benefit is that we can be confident that the salmon is safe to eat and safe for the environment. We have two independent sets of regulatory processes to consider, one in Canada and one in the United States. While there are similarities in what the regulatory agencies are looking for, the laws and regulations were developed independently and the people in the agencies themselves are different, under different types of internal and external influences.

The agencies in both the United States and Canada independently found fast-growing genetically engineered salmon to be safe to eat and safe for the environment. A summary of the safety findings from the regulatory agencies is below.

GMO salmon for food and feed

The regulators considered three main types of issues with regard to using AquAdvantage for food and feed: nutrients, hormones, and allergenicity.

Protein, fats, vitamins, and other components of fish and other foods can vary widely due to the variety of the plant or animal, the place it was raised, the weather while it was growing, and many other factors. Because there is so much variation within each food type, a simple comparison between genetically engineered and non-genetically engineered doesn’t make sense. Instead, scientists and regulators look at a range of values.

For example, a Consensus Document for maize reports that protein in field corn ranges from 6% to 12.7% of dry weight. Therefore, in testing the protein of corn with genetically engineered traits, we’d need to take a second look at any values that fall outside of that range.

genetically engineered salmon
Fast-growing genetically engineered salmon could make nutritious and delicious dishes like this more sustainable and affordable.

Nutrients in GMO salmon

Both FDA and Health Canada determined that fast-growing genetically engineered salmon is safe for humans and animals to eat. Both agencies found that there were no substantial changes in the protein and fat (including omega-3 fatty acids) profiles of AquAdvantage salmon compared to expected ranges.

For diploid AquAdvantage salmon, the niacin level was higher than expected ranges, but the level is not of nutritional concern. The majority of AquAdvantage salmon salmon (more than 99%) are triploid, and triploid salmon had niacin levels within expected ranges.

Hormones in GMO salmon

Specific concerns with AquAdvantage salmon include increased hormone content in the edible parts of the fish. Both FDA and Health Canada concluded that there is no health risk to humans or livestock associated with hormones in AquAdvantage salmon.

First, the growth hormone produced by AquAdvantage salmon is from Chinook salmon. Chinook salmon are commonly consumed and have a safe history of use, with no concerns about toxicity. Second, the amount of growth hormone (and associated regulatory hormones) in muscle and skin of adult (market weight) AquAdvantage salmon was not distinguishable from conventional salmon. People who eat AquAdvantage salmon would not be exposed to any more growth hormone than people who eat conventional salmon or other animal-sourced foods.

Health Canada points out that “the scientific literature has consistently shown that dietary growth hormones from various animal species have very poor bioavailability in mammals and humans.” This means that growth hormones consumed in the diets are primarily digested, not absorbed intact. Any tiny amount of the Chinook salmon growth hormone that might be absorbed would have a limited effect in humans “due to the species specificity exhibited by the human [growth hormone] receptor.”

Allergens in GMO salmon

Fish, including salmon, is a major food allergen. Of course, people who are allergic to salmon will also be allergic to AquAdvantage salmon. Still, the regulatory agencies investigated whether AquAdvantage salmon would have more fish allergens than conventional salmon. Analysis showed that allergens in triploid AquAdvantage salmon were within the normal range found in conventional salmon.

Diploid AquAdvantage salmon (less than 1% of AquAdvantage salmon) did have statistically higher levels of allergen content, but experts concluded that there would be no impact on non-allergic consumers, and no change in allergenicity for allergic consumers.

GMO salmon in the environment

If reproductive-capable, fast-growing salmon were to escape captivity, they could theoretically breed with nearby salmon or trout and spread the gene for fast-growth. This could have negative consequences for the salmon population, their food sources, competing fish species, and other parts of the ecosystem.

When AquaBounty requested FDA approval of their AquAdvantage salmon, they were very specific about how and where the fish would be raised. The request was for one egg production facility in Prince Edward Island, Canada and one fish production facility in Panama. AquaBounty later requested that a fish production facility in Indiana be added. FDA’s approval is for these locations only, and additional approval would be needed for more locations.

AquaBounty selected (and FDA approved) these locations to have many overlapping ways to prevent release of GMO salmon into the environment. The containment methods include biological, physical, and environmental aspects.

genetically engineered salmon
AquAdvantage salmon will not be raised in an environment where they can exhibit this leaping behavior.

Biological containment

Part of biological containment is Atlantic salmon’s own biology. Atlantic salmon reproduction requires fresh running water over a gravel bed. Salmon have complex mating and nesting behavior, and a sexually compatible male must be present when the female spawns. In the waters near the egg and fish rearing facilities, there are no males or gravel beds. Even if a female were to spawn, the eggs would not be fertilized. In addition, spawning takes so much energy that 60% or more female salmon die after spawning.

Another part of biological containment is that AquAdvantage salmon can not breed – they are sterile. AquaBounty pressure treats salmon eggs to induce triploidy (3 sets of chromosomes instead of 2 sets). Since a small percentage of triploid males can reproduce, AquaBounty adds another layer of biological containment by only using female fish. A 2018 study, Comparisons of reproductive function and fatty acid fillet quality between triploid and diploid farm Atlantic salmon, confirmed that “escaped triploid farm salmon are very unlikely to reproduce in the wild.”

If you eat fish, you’ve likely already dined on triploid fish. Triploid fish of many species, including salmon, trout, and carp, have been used around the world for decades. They are used in commercial fisheries and recreational fishing areas to prevent farmed or stocked fish from breeding with wild fish. Triploid fish grow to a larger body size and have higher quality meat because the animals do not undergo the stress of reproduction. Other triploids that we eat include bananas and watermelon.

Lastly, the fast-growth trait serves as a sort of biological containment as well. Fast-growing fish (whether resulting through breeding or biotechnology) and triploid fish have some changes relative to conventional diploid salmon that could decrease survival in the wild. Changes that may affect AquAdvantage salmon survival in the wild include: increased metabolism causing smaller energy reserves, higher oxygen consumption, decreased tolerance to stress, increased appetite, increased aggression, and reduced response to predators.

Physical containment

Because a small percentage of AquAdvantage salmon could be capable of reproduction, additional containment methods are necessary to ensure eggs or fish do not escape. Their facilities use numerous layers of filters, screens, and nets. Chlorine is used in drains to kill eggs or fry that might somehow slip through. Facilities are inspected daily and standard operating procedures are in place for every process in each facility.

AquaBounty also has security to protect against human sabotage. Facilities have security cameras (the Panama facility has guard dogs) and fencing around each property (fencing is topped with barbed wire at the Panama and Indiana locations) among other measures.

Security cameras are part of the physical security measures used by AquaBounty at their facilities.

Environmental containment

In the highly unlikely case that a fertile AquAdvantage salmon could escape, the local environment near each facility would make it nearly impossible for any escapee to survive to adulthood, find a sexually compatible male fish, and reproduce.

The egg production facility is located in Prince Edward Island, Canada. The biological and physical containment measures mean it is nearly impossible that a fertile egg would make it past the filters and chlorine. Any that did would not find a good place to grow into adult fish. The eggs are raised in fresh water, so the salinity in the nearby river reduces likelihood of survival. In the winter, water near the facility is too cold for salmon. Any escaped eggs that somehow managed to grow into adult female fish would not find a male to mate with. Atlantic salmon previously lived in this area, but overfishing, barriers to migration, and acid rain have made them locally extinct.

The fish production facility in Panama is located at a high altitude near a river that drains to the Pacific ocean. Much of the river water is used for power generation, and canals that control water flow are not suitable for salmon. Dams provide a physical barrier to movement downstream. If any fish escaped and they managed to get past the barriers, they could potentially survive in the river closest to the facility, but they would not find any males to mate with. If they tried to move out to sea, high temperatures in the lower lower parts of the river would kill the salmon.

The fish production facility in Indiana includes a series of ponds that will be seeded with wetland plants to help clean effluent before it drains away from the facility. Effluent from the ponds must pass through a screen before reaching a drainage ditch that ultimately drains into the Mississinewa River. The ditch is dry except during wet weather. Even with the effluent from the facility, the water levels in the ditch are expected to be only 1-2 inches near the facility. If fish somehow managed to get out of the facility, past the ponds with screen, and past the ditch into the Upper Mississinewa watershed, they may find conditions where they could survive during some times of the year. However, the watershed is too warm with too little oxygen and too much dissolved solids for salmon and related species like trout. A survey of the watershed found no species of trout or other cold-water salmonids at any of the 35 sampling sites, so any escaped females would not find a male with which to mate. There is also a dam downstream of the facility that would prevent movement of fish, if they were to somehow survive.

The FDA states that “at full capacity, the [Indiana] facility will harvest approximately [90 metric tons] of AquAdvantage Salmon per month.” This will meet only ~0.27% of US demand for salmon (403,107 metric tons in 2018). If there is reasonable consumer acceptance of AquAdvantage salmon, AquaBounty may request approval for more facilities from the FDA. Those facilities will be regulated and inspected by FDA and appropriate agencies in the state in which they are located, continuing to keep appropriate environmental containment of the fast-growing genetically engineered salmon.

Editors’ note: Parts of this post previously appeared in Risk assessment and mitigation of AquAdvantage salmon and in Preventing escape of GMO salmon.

Biotechnology regulation update

cow with horns

There are two upcoming opportunities to learn about the US regulatory system for biotechnology. Both have web-based options so you can attend from anywhere in the world. Check out the topics below and be sure to register! One is next week, on November 7th, and one is on December 3rd.

Biotechnology Regulatory Service

The USDA-APHIS-Biotechnology Regulatory Service (BRS) is holding their annual Stakeholder Meeting on Wednesday, November 7th,10:00 am to 3:30 pm Eastern. Register for the Stakeholder Meeting in advance, and select the webcast option. If you are in the Washington DC area, there is also an option to attend in person.
During the morning session, BRS will “discuss implementation of business process improvements; review biotechnology research, education, and outreach”. During the afternoon session, they will present the new APHIS eFile system. The afternoon session will be of particular interest to any researchers whose work (movement or field trials of certain genetically engineered organisms) is regulated by BRS; you will need to use the new eFile system in 2019.
BRS will provide opportunities for questions. It will be interesting to see if they discuss the FDA’s Plan (below). Another potential topic of interest not on their agenda is whether they will propose regulatory changes in 2019 “to respond to advances in genetic engineering” aka gene editing, regulate GE organisms that present a possible noxious weed risk, and respond to Office of the Inspector General audits, among other issues. Note that if you have questions about the USDA’s proposed Bioengineered label, BRS is not the agency to ask. Labeling is handled by the Agricultural Marketing Service (AMS).

Food and Drug Administration

The Food and Drug Administration (FDA) announced on October 30th their new Plant and Animal Biotechnology Innovation Action Plan. They are holding a webinar on Monday, December 3rd, 12:00 pm to 2:00 pm Central. Register for the Genome Editing in Animals meeting in advance. This meeting is webinar only, with no in-person option.
During this meeting, FDA’s Center for Veterinary Medicine (CVM) and Center for Biologics Evaluation and Research (CBER) will discuss risks and benefits of gene editing in animals. FDA will also discuss “CVM’s flexible, risk-based approach to the regulation of intentional genomic alterations in animals and address common misconceptions associated with the regulation of these products”.
When you register, there is an option to “submit any questions that you have regarding genome editing in animals and CVM’s regulation of animal biotechnology.” Definitely use these three boxes to submit your questions in advance, and help show the FDA what types of concerns the regulated community has on their mind. Note that while FDA does regulate genetically engineered plants, they specify the “webinar will not cover genome editing in plants for human and/or animal food”.
As you consider questions to ask FDA, it may help to think about gene editing like a text editing program – it can delete, replace, and insert, among other functions. Many gene edited organisms will have no new proteins, and potentially no new DNA at all. How will FDA treat each of these different results? What will the regulatory trigger be? How will FDA regulate gene edited animals with no transgenic DNA, or animals where gene editing was used only to delete DNA?

Gene edited animals

cow with hornsOne example of a gene edited animal is hornless dairy cow. While horns are useful in the wild, you can imagine that horns can be dangerous for cows and for the humans that tend them. There are naturally hornless cattle but they lack other traits that are important for dairy cows.
Researchers used gene editing to replace a gene in horned cattle with one from hornless cattle. The result? Hornless dairy cows that don’t need to go through a potentially painful de-horning process. Depending on how the FDA decides to regulate gene edited animals, that little piece of cow DNA, which is already in the food supply anyway, could be regulated as an animal drug.
In addition to cattle, gene edited animals include pigs, sheep, goat, tilapia, carp, and chicken. Edits have been made for improving agricultural traits, for medical research, and even for making fancier pets. Each of these different animals will need to be evaluated differently before they can be released either into the food supply or otherwise out of the laboratory.
Need some background in gene editing? Check out highlights from a 2018 symposium about gene editing hosted by the Crop Bioengineering Center at Iowa State University, which include what gene editing is, what it can do, how it is regulated, and consumer acceptance of new technology in food.

Comment TODAY on edible cottonseed deregulation

The fate of cottonseed rests in your hands.

More than eight years ago, we wrote about a project at Texas A&M University led by Dr. Keerti Rathore to create edible cottonseed. If determined to be safe for food and the environment, this has the potential to make large amounts of protein and calories available that would normally be locked up in the seed. This trait is undergoing deregulation with USDA-APHIS right now, and we encourage our readers to submit comments before the deadline at the end of the day today.

Background

Cotton plants produce a potent defense compound called gossypol, which is toxic to many animals, including humans. Gossypol is produced by special glands throughout the plant, from leaves to seeds, and protects the plants from insect pests and diseases. Some varieties of cotton are glandless and do not produce toxic levels of gossypol, making the seeds and leaves edible. However, because these glandless cotton varieties have lost the protective benefits in their leaves, they are more susceptible to insect damage and are not commonly grown.

Gossypol. Source: Wikimedia Commons


Using RNAi, Dr. Rathore’s team at TAMU created a variety they call TAM66274 that “silences” the production of gossypol just in the seeds, producing a plant that defends itself against pests in the leaves, but produces seeds that have ultra-low levels of gossypol in the seeds, making them safe to eat. If applied on a large scale, it could allow humans and many other animals access to the protein contained in cottonseed. According to the data they collected for their application, the composition of the cottonseed was otherwise unchanged, the plants performed the same in the field, and there were very minor changes in the length of the fibers, which they suggest will not be an issue when the trait is bred into “elite” cotton varieties.

The impacts of this trait could be far-reaching. Some estimates suggest that the amount of protein produced in cottonseed worldwide could satisfy the needs of 500 million people. Ruminant animals are able to tolerate some gossypol in their diets, so this trait could create greater flexibility in the animal feed supply. This would turn cottonseed into a valuable co-product of cotton production that could benefit cotton farmers at every scale, producing more food without using more land. Read more about how this trait works and its potential impacts on agriculture in Cotton like Candy.

What APHIS wants to hear from you

Open comment periods for federal regulations are often misunderstood. Some organizations use them to gather signatures (and email addresses) of supporters for their political causes, or set up form letters to mass-send the same talking points over and over to regulators. These actually do nothing more than single letters from one person that say the same thing – because the regulators are looking for public input to identify issues that they should look into during the process – not to count the number of people who think one action or another is a good idea. Back when the FDA was looking for input on biotechnology outreach, there were many opponents and supporters of biotechnology saying “don’t do it” and “do it”, when that was not even a question. It was mandated by Congress, so the question was how should it be done?

Cotton field, by Kimberlykv

Similarly, when the USDA-APHIS is reviewing a genetically engineered crop, they are not going to count how many people say “yes” or “no” to the question of whether to de-regulate (approve) a crop, they want to know what issues related to the economic and environmental impacts they should be aware of when they do the review. Will the crop become a pest on farms? Will it help control pests? Will it benefit the bottom lines of farmers, or reduce the ability of other farmers to farm the way they want to? This is your chance as members of the public, as knowledgeable scientists and science enthusiasts, and as people who think deeply about far-reaching impacts of biotechnological applications, to inform the USDA about data, ideas, and concerns that you have that they can look into when evaluating the crop.
Here it is in their words:

We are advising the public that the Animal and Plant Health Inspection Service has received a petition from Texas A&M AgriLife Research seeking a determination of nonregulated status of cotton designated as event TAM66274, which has been genetically engineered for ultra-low gossypol levels in the cottonseed. The petition has been submitted in accordance with our regulations concerning the introduction of certain genetically engineered organisms and products. We are making the Texas A&M AgriLife Research petition available for review and comment to help us identify potential environmental and interrelated economic issues and impacts that the Animal and Plant Health Inspection Service may determine should be considered in our evaluation of the petition.

Comments are due today at midnight Eastern Time. Since there is not much time left to comment, you can keep your comments brief, but if you have input to give our regulators, please do! There are only 39 comments showing at the time of writing, so you could have an impact. Take a look at the documents prepared by the TAMU research team, and tell the USDA-APHIS what you think. Join me in submitting a public comment on low-gossypol cotton!

We will be following this trait as it moves along, while thinking about how we can improve our own alerts to help mobilize scientists, farmers, and the rest of you to prepare impactful submissions that can help strengthen the regulatory process.

Advisory committees for biotech

The White House, by Matt Wade via Wikimedia Commons.
The White House, by Matt Wade via Wikimedia Commons.

What creative ideas do you have for the US biotechnology regulatory agencies? With the White House call for comments closing on November 13th, now is the opportunity to share. In this post, I’ll talk about one idea that will be in Biology Fortified’s comment – feel free to take it and run with it!
We’ve made it easy for everyone to provide comments to the White House, and you can learn more at our post: You can improve US biotechnology regulation
There are tons of advisory committees across the US government. Why isn’t there one (or more) for biotechnology regulation? Let’s take a look at just a few advisory committees and see what they do. Continue reading “Advisory committees for biotech”

US biotech regulation public comments

October 30, 2015 was the first of three public meetings to collect ideas about how to improve US biotech regulation and how the agencies conduct public outreach. You can get updates from the White House, and get notified about the next meeting. This post describes why comments matter and who should comment.
We’ve made it easy for everyone to provide comments to the White House, and you can learn more at our post: You can improve US biotechnology regulation Continue reading “US biotech regulation public comments”

You can improve US biotechnology regulation

We invite you to provide your comments to the White House on how to improve US regulation of biotechnology. Learn more below, and add your voice to our letter to the White House.
The White House Office of Science & Technology Policy (OSTP) has announced a major effort to update the Coordinated Framework for the Regulation of Biotechnology. OSTP is seeking comments to inform the revisions. They especially need feedback from scientists, but comments from everyone are welcome. Continue reading “You can improve US biotechnology regulation”

A look at GMO policies in different nations

In the debate surrounding GMOs, a statement that is often made is that many countries have banned transgenic crops, which suggests that they are not safe. Here’s an example from the Non-GMO Project’s website:

Most developed nations do not consider GMOs to be safe. In more than 60 countries around the world, including Australia, Japan, and all of the countries in the European Union, there are significant restrictions or outright bans on the production and sale of GMOs.”

All countries have laws and regulations surrounding biotech crops, including the United States, which is why you can’t develop a transgenic crop and have it sold in stores the following season. Very few countries have an outright ban, where GMOs can neither be grown nor imported. According to GMOAnswers.com, only Kenya falls in this category, but I also found that Peru has a 10-year ban on the use and import of GMO seeds.
Continue reading “A look at GMO policies in different nations”

The inconvenient truth about GMO labeling

GMO-label-shutterstock

Over the past few months, there have been several big stories on the labeling of GMOs: Chipotle, a chain of restaurants popular in the United States declared that they were going to eliminate GMOs from their menu. A perhaps more interesting story is that the USDA stated that they would  start providing a verification program for companies whose products are non-GMO.

In writing and researching GMO labeling bills proposed in different states and nations as well as looking into companies that have decided to take the non-GMO plunge, the one factor that stands out more than any other is what each of these entities choose to define as “GMO”. I use the word “choose”, because that’s what it boils down to. There’s no single definition on what is or is not a GMO, so companies and legislators get to decide how to define it. From a molecular biology perspective, a transgenic animal or crop is one where a gene from an unrelated species is added to another. But the term “GMO” as used in the current debate doesn’t have a clear definition.

For example, is milk derived from a cow that is fed GM-grain a GMO? According to the Non-GMO Project, an organization that certifies ingredients as non-GMO, milk from a cow fed GM-grain cannot be certified as non-GMO. GMO Inside, one of the organizations leading efforts to label, also abides by this definition. The USDA’s Organic label also adheres to these standards. The Food Babe used the same criteria in her campaign against “Monsanto Milk” in Starbucks beverages. However, Ben & Jerry’s, an ice cream company and one of the first large organizations to declare that it was going GMO-free and supports labelingsources its milk from cows fed GM-grain. Ben & Jerry’s website explains their criteria for GMOs by stating “if you eat a corn chip containing GMO corn, it doesn’t make you a genetically modified human.”

Saccharose2.svg
Sucrose from any source tastes just as sweet

What about sugar that is derived from a GM-beet? As Dr Kevin Folta outlines in this graphic, sugar is sugar. There’s no protein and no DNA in what we buy at the store. As such, it cannot be distinguished from sugar derived from non-GM beet. To obtain Non-GMO Project certification, this is resolved by looking at the supply chain (see bullet 2.6.1.1.4). But Australia and New Zealand labeling standards define a GM-ingredient as one that contains novel DNA or protein, so sugar from GM-beet would be exempt from labeling.

The definition even changes from one state to the next. In Vermont, the labeling bill states that you don’t need to label if the amount of GM material makes up less than 0.9% of the total weight of processed food, but in California‘s proposed (and failed) bill the cutoff was set at 0.5%. Perhaps GMOs have more GMOiness in California so the state can’t handle as much of it. Colorado’s proposed (and failed) bill stated that chewing gum was exempt from labeling. In Colorado, Vermont, and California, alcoholic beverages were exempt, but I could find no such exemption in the bill from Connecticut.

Some may argue that it’s better that we just start somewhere. Anywhere. They will argue that any form of labeling is better than none. But the immediate consequence of a labeling bill that does not meet everyone’s requirements is the fact that the number of labels and verification-criteria will explode. Certifiers will try to sell consumers on the purity of their criteria and benefits of their definition of a GMO. Here’s an example: as you may know, the USDA’s organic label excludes GMOs and is often used by those who wish to avoid GMOs in their diet. However, according to GMO-awareness.com, the USDA’s organic label isn’t stringent enough because there are a handful of exemptions, so the organization embraces the Non-GMO Verified seal.

Personally, I like Australia and New Zealand’s criteria. The difference between a GMO and a non-GMO crop is the DNA for the gene that has been added and the protein(s) that it produces. So if the very thing that make a crop a GMO cannot be detected in a food product, then it shouldn’t be labeled. Australia and New Zealand extend their labeling criteria to foods that are designed to be different from their non-GMO counterparts, such as high oleic soy or the Innate potato: these must be labeled as genetically engineered.

But that’s my personal opinion, and it probably would not meet the demands of most GMO-labeling proponents. Since there’s no hard rule each person can have their own criteria, which will probably lead to a bureaucratic nightmare where lobbying groups for different foods and ingredients will argue as to why their product should or should not qualify as a GMO. And who’s to say they’re wrong?Here’s a list of common ingredients whose classification as “GMO” is debatable:

Here’s a list of common ingredients whose classification as “GMO” is debatable:

  • Vitamin and nutritional additives produced through genetic engineering, commonly used in fortified foods. Vitamin C, for example, can be made through fermentation of corn (which could be a GMO). Riboflavin can be synthesized by a GM-bacteria.
  • Oils, sugars, and starches, which have no trace of protein or DNA
  • Animal products from animals fed GMO grain (i.e. eggs, milk, meat, etc).
  • Animal products from animals who have received GE vaccines
  • Cheese, yogurt, and other dairy products whose production may use GE bacteria
110 car trains combine grain from many farms. The commodity food system for grains makes 0.0% admixture unachievable.

There’s also the all important topic of “cut-off”. How much GMO is acceptable in a product? Some would argue that it should be 0.0%, but that’s not realistic considering the fact that equipment is often shared in the supply chain. How do we decide whether it is 0.5% (California’s criteria) or 0.9% (Vermont’s criteria) that makes a food item a GMO? There’s no scientific answer, so again, it will have to be decided via politics and lobbying.

I don’t have an answer here, and I write this only to highlight the many nuances that are perhaps ignored, and the bureaucratic disaster that a poorly designed federal, or worse yet state-level, labeling bill could turn into. Feel free to comment on what ingredients you think should be labeled in a federal voluntary or mandatory labeling law.

Comment Today on the next Genetically Engineered Potato

Innate Potato next to a conventional one
Innate Potato next to a conventional one

There’s always a little catch-up to do when coming out of the Holiday season. Back in December, the USDA public comment period opened up for a next-generation transgenic potato variety developed by Simplot. The previous Simplot “Generation 1 Innate” potato, which reduced browning, acrylamide, and bruising, was approved by the USDA in November last year. Back in 2013, we conducted an interview with Haven Baker at Simplot to find out answers to your questions about the potato and its new traits. Now they have another potato variety with more traits – Generation 2 Innate – which takes the traits of Generation 1 and adds late blight resistance and further reduces the acrylamide-generating potential of the tubers when you fry them.
There is a lot to discuss about this new variety and its traits, however, the first public comment period for USDA regulations ends today! I wanted to inform our readers about this deadline in case you wanted to submit a comment to this round, and I was able to obtain some more information about the traits from Erik Gonring, who manages Industry Affairs at Simplot. There will be more opportunities in the future to do an interview as we have done before, and feel free to start a discussion below. Indeed, there will be a public comment period for the EPA’s review of the second Innate potato. Continue reading “Comment Today on the next Genetically Engineered Potato”

Learn about regulation of GMOs

Anyone interested in how genetically engineered organisms are regulated in the US should check out the Stakeholder meeting presented by the USDA’s Biotechnology Regulatory Services (BRS) happening on November 19 from 8:30am to 12:00pm EST. You can find registration information for the webinar and the agenda at the BRS website.
The agenda includes highlights such as “Coexistence of Agricultural Sectors: A USDA Perspective” and “Global Trade and Acceptance of GE Crops”. There’ll also be a panel discussion about how BRS’s parent organization, the Animal and Plant Health Inspection Service (APHIS) interfaces with the EPA and FDA.
For more biotech news from BRS, you can view their news page or sign up for emails through their Stakeholder Registry.