Q: Do `frankenfish' threaten to wipe out native salmon stocks in North America?
YES: For the sake of a quick buck, some biotech engineers are playing ecological roulette and we likely all are losers.
BY ANDREW KIMBRELL
Kimbrell is a public-interest attorney, activist, author and founder of the Washington-based Center for Food Safety. He has been involved in public-interest legal activity in numerous areas of technology, human health and the environment. Kimbrell established the International Center for Technology Assessment in 1994 and the Center for Food Safety in 1997.
It is a truism of free societies: One's freedom to extend one's arm ends at anyone else's nose. The role of government in a free society should be to restrict arm movement only in so far as it results in bloody noses. Unfortunately, government consistently fails to grasp this simple idea. Often it restricts perfectly harmless activities while simultaneously failing to halt individuals whose exercise of self-interest means potential disaster for the rest of us.
A compelling example of this kind of government malfeasance is the current controversy over the commercialization of genetically engineered salmon and other fish species. For decades sportsmen's and conservationist organizations have spent endless time and resources to protect native salmon and trout species. These magnificent creatures have become food and outdoor recreation staples and have come to symbolize the wild.
Many efforts to protect these fish have been success stories. Rivers have been saved and cleaned up. Many formerly depleted Pacific salmon and trout ecosystems are thriving. The continuing efforts to save the Atlantic salmon have met with more-sporadic results. The survival of that species still hangs in the balance. Its numbers continue to decrease, and it has been declared an endangered species in the Northeast.
In the midst of this widespread and remarkable effort of so many to preserve the Atlantic salmon and other fish species comes a Canadian company called Aqua Bounty Farms. The company has applied to the U.S. government for approval to commercialize genetically engineered Atlantic salmon, otherwise dubbed as "frankenfish." These fish have been genetically altered to contain a growth-hormone gene from a Chinook salmon and an antifreeze protein gene promoter from an ocean pout that keeps the growth hormone active. Due to the continuous production of the growth-hormone gene, these fish grow as much as 10 to 30 times faster than normal salmon.
So what's wrong with faster-growing, super Atlantic salmon? Does it represent a threat to our already-fragile Atlantic salmon populations? Does it ever. Studies by scientists at Purdue University, as well as several other researchers in the United States, Canada and Europe, have shown that frankenfish, due to their larger size, have a significant mating advantage over native fish. However, the offspring of frankenfish have a one-third greater mortality rate because of the impact of the added growth genes and other genetic material.
Frankenfish stand Darwin on his head. The gene-altered fish have an advantage in mating, but their offspring are dying at a far greater rate than the nonengineered fish. The Purdue scientists worked out the math and revealed that the escape of only 60 engineered fish into a native population of 60,000 would lead to extinction in just 40 generations. This catastrophic result has led scientists to call the new growth genes, engineered into the fish by Aqua Bounty, "Trojan genes." Just as the faux horse of old led to the destruction of Troy, so these Trojan genes will lead inevitably to the extinction of salmon and other fish species.
These findings on genetically engineered fish recently were acknowledged in a report by the National Academy of Sciences (NAS). The NAS recognized that genetically engineered fish inevitably will escape net pens and, once these fish escape, they easily will outcompete their wild cousins and drive the wild population to extinction. The same NAS report also cautioned that frankenfish could introduce new allergens into the food supply.
It is important to remember that the environmental threat posed by frankenfish is called biological pollution or "living" pollution. When most people think of environmental pollution they probably envision a spewing smokestack, a car emitting exhaust or a sewage pipe emptying sludge into a river. This is chemical pollution, a "contamination" model of pollution; as toxic chemicals pollute air, water, our soil or food. The biological pollution brought to us by frankenfish is a "disease" model of pollution; the invasion of a living organism into our environment or ourselves. The most familiar paradigm of biological pollution is how most of us become ill--a bacteria or virus invades our system. We also may recall the devastation caused by the Asian fungi that were brought to our shores and proceeded virtually to eradicate our magnificent elm and chestnut trees.
Obviously, biological pollution creates some very different risks than chemical pollution. Chemical contamination, whether an oil spill or factory exhaust, generally becomes diluted and less concentrated over time. Biological pollution lasts forever. It does not dissipate, and it cannot be controlled or recalled. Whether chestnut blight or frankenfish, this form of pollution will reproduce, travel and mutate as it wishes. Once the frankenfish are released or escape into the wild, neither Aqua Bounty nor any government or scientist can recall them or stop the resulting eradication of native salmon. Each use of these fish will be a dangerous game of ecological roulette where the only certainty is that we and the salmon will be the ultimate losers w all so one company can make a quick buck.
Any sensible corporation would realize that there is a dangerous and fundamental design problem with their product and go back to the drawing board. Not Aqua Bounty. Instead the company has asked the Food and Drug Administration (FDA) to approve its dangerously flawed frankenfish. They want permission to grow unlimited numbers of these fish in net pens in open waters and to sell them in our supermarkets (though they do not want the fish labeled). As for the Trojan-gene problem, the company says not to worry: It will sterilize all the fish it produces so that they cannot reproduce and destroy native salmon populations.
This sterilization proposal does not pass the laugh test. Imagine, our taxpayer dollars going to fund leagues of FDA bureaucrats who faithfully will inspect untold thousands of fish, one by one, to make sure they actually are sterile and safe for release and consumption. Unfortunately, far from laughing the FDA actually is considering approving these fish. Once again any sensible government would tell the company to go back and make a product that would not destroy species and require thousands of new federal jobs. But not the FDA; they are predicting approval of these fish as "new-animals drags." FDA officials also have refused to disclose what environmental or human health and safety tests they are demanding of the company.
So here we have government at its worst. A single company is threatening to make Atlantic salmon and other fish species extinct, permanently undoing the work of thousands of organizations and individuals and destroying one of our most treasured species. And the FDA response so far to this biological-pollution nightmare is to give a green light to the company while keeping the rest of us in the dark. Even the pro-biotechnology Pew Initiative recently criticized the FDA's regulation of frankenfish. Its new report, Future Fish: Issues in Science and Regulation of Transgenic Fish, states that: "The proposed regulation of transgenic fish does not reflect a unified federal strategy to address the risks of genetically modified fish in a transparent manner that provides public confidence that these risks will be adequately considered and addressed."
Fortunately, there is some hope that the U.S. government is coming to its senses. My organization, along with a number of conservation and consumers groups, has filed legal actions with five different federal agencies to force adequate regulation of frankenfish. We have demanded that these frankenfish never be allowed in open waters, including net pens, and that there be an indefinite moratorium on their approval until all environmental and health issues have been completely resolved.
Legal pressure has produced some progress. The National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service have reacted to the commercialization of genetically engineered fish by advising the Environmental Protection Agency and the U.S. Army Corps of Engineers not to allow the fish into net pens in Maine due to Atlantic salmon being listed as endangered there. The agencies are concerned about the effects the fish may have on dwindling fish populations and, as a result, also have directed FDA to consult with them pursuant to the Endangered Species Act prior to any approval of the fish. Additionally NMFS officially has recognized the "legitimate concerns relative to food safety and potential environmental impacts that should be addressed prior to approval" of genetically engineered fish and committed the agency to participating in the review process with the FDA prior to the issuance of any approvals of genetically engineered fish.
States also have begun to act. Maryland, Oregon and Washington state passed laws that restrict the use of genetically engineered fish within their boundaries. Former Maryland Gov. Parris N. Glendening signed into law a bill that prohibits release of genetically engineered fish into any state waterway connected to another body of water. Oregon considers releases of genetically engineered fish a serious risk to wild populations. Under the Oregon Department of Fish and Wildlife role, the department does not authorize the release of genetically engineered fish into locations where such fish may gain access to wild-fish populations. Washington state, with the most recent ruling on genetically engineered fish, prohibits growers from using transgenic fish in their operations. California also introduced three bills that would ban or restrict the use of frankenfish.
Hopefully with enough pressure sanity will prevail, and the U.S. government will just say no to Aqua Bounty. But that will not be the end for the biological-pollution threat of frankenfish. More than 35 species of genetically engineered fish now are being developed. Pacific salmon, rainbow and brown trout, striped bass, largemouth and small mouth bass, carp, tilapia and many others now are being engineered with novel genes. Whether you love to catch, eat or just look at these wonderful creatures they now are under biological attack by a handful of companies and researchers.
Remember, once these frankenfish are released there is no way to get them back; the damage will be done. So it's time to act. As the Aqua Bounty saga reveals, we obviously can't trust government to look out for our interests unless we get involved and make them listen.
Recently hundreds of prominent chefs signed a pledge not to serve frankenfish until they adequately were regulated and there was a permanent ban on their release into open waters. Unlike Aqua Bounty, they seem to understand the simple rules of a free society.
NO: Sterile `transgenic' fish pose no danger to native salmon and will help meet a growing demand for fish without exhausting over-fished, coastal fisheries.
BY JOSEPH McGONIGLE
McGonigle is an agricultural economist and vice president of business development at Aqua Bounty Farms. He has been a legislative aide and is a former executive director of the Maine Aquaculture Association. He serves on the US. delegation to the North Atlantic Salmon Conservation Organization and is an adviser to the New England Fisheries Management Council.
If only fanned salmon could sue for relief from hate speech. Critics of aquaculture and of biotechnology have joined forces to oppose the commercial introduction of genetically modified, or "transgenic," salmon, maligned by some ecologically minded Luddites as "frankenfish." Transgenic salmon are so named because they inherit a trait for rapid growth that is controlled by an extra growth-hormone gene inserted into the parental generation. The extra gene uses a "molecular switch" from an ocean pout to turn on the growth-hormone gene from a Chinook salmon. The extra gene allows the salmon to produce its native growth hormone during the winter as well as the summer months.
Some bashers of the new fish claim that transgenic salmon grow 10 to 30 times faster than conventional salmon, that they are more aggressive and eat more food, that they would cannibalize juvenile wild salmon or that they will attract more mates and ultimately drive the wild species to extinction. Some activists even have claimed that transgenic salmon will grow to 1,100 pounds, or about the size of a shark.
These claims are wrong on the facts and are based on illegitimate extrapolations or misused research focused on other species offish. Aqua Bounty's transgenic salmon do grow faster, but are no larger than conventional salmon at sexual maturity. As very young juveniles they grow four to six times faster than conventional salmon but, over their entire life cycle, they grow only twice as fast. There is no evidence that transgenic salmon are particularly aggressive; one study of transgenic coho salmon found them about twice as likely to take a food pellet ahead of a conventional salmon.
This eagerness to feed, however, has a significant downside: When transgenic and conventional salmon are fed in the presence of a predator, the conventional salmon hide, but the transgenics continue to feed: Although transgenic salmon feed eagerly, they don't eat more food than conventional salmon over time. In fact, their feeding efficiency is 10 to 30 percent greater than farmed salmon, so they eat only 70 to 90 percent as much feed to reach a comparable size.
The most significant criticism of transgenic fish to date is the "Trojan-gene" hypothesis of Bill Muir and Richard Howard, Purdue University professors who built what they call "a screening device" to identify transgenic animals that might cause a risk in the environment. Muir and Howard discovered that a fish with, for example, a strong mating advantage but with low juvenile viability could succeed in transmitting its genes to an entire population. This hypothetical fish might be supersuccessful at reproduction but, because of the high mortality rate in juveniles, the population as a whole could disappear in as few as 40 generations--for salmon, about 250 years.
Muir and Howard's hypothetical model, however, is not and was never intended to be a predictor of any actual risk that might be associated with transgenic fish in the real world, especially transgenic salmon. In fact, they didn't study salmon at all to build their computer model of the possible consequences of gene flow; they studied medaka, a small, freshwater fish that matures in 56 days and mates every day for the next 100. They bred a line of transgenic medaka characterized by oversized males but less-hardy juveniles. The large male medaka gain a mating advantage from their size, guaranteeing the spread of their genes throughout the population. Because the juveniles were less likely to survive, however, the computer model predicted the population would become extinct in 40 generations. They also found that, without a mating advantage in big males, the transgene would be purged from the wild population very quickly and would disappear in three to four generations.
For three good reasons, Muir and Howard's work on medaka cannot be extrapolated directly to salmon because of the significant differences in the life histories of the two fish. First, medaka mature in two months, whereas salmon take three to five years to reach maturity. Second, medaka mate daily and in the same habitat where they matured. Most salmon spawn only once in their lifetimes; even those that survive won't spawn again for two to three years. Salmon begin maturing in the ocean and must migrate hundreds and even thousands of miles to spawn. Third, although large male medaka are preferred by females in mating, salmon gain no mating advantage from size. In fact, six-inch "precocious parr" father some 20 percent of all salmon in the wild.
Most importantly, a significant base of evidence now is emerging that suggests Muir and Howard's "purge scenario" is what's actually happening with farmed salmon in nature. During the last five years, several researchers have reported that seagoing salmon populations are highly resilient and resist interbreeding with other groups of salmon. Salmon species have been moved around the world for more than 100 years by governments and sportsmen. In recent years, farmed salmon have escaped and interbred with wild fish but, in virtually every location where biologists have looked at successive generations of crossbred fish, the farmed-salmon genes vanish within a few generations.
In Maine, for example, where more than 100 million Canadian salmon were stocked in local rivers, the National Academy of Sciences found that the native salmon retained their genetic makeup through more than a century of supplemental stocking. In Ireland, 26,000 salmon escaped from a farm and entered a river with only 2,000 wild fish. After three generations, nearly all evidence of the fish with the farmed genotype had disappeared.
At the end of the day any environmental questions about transgenic salmon will have to be answered before the Food and Drag Administration will approve them for sale. Aqua Bounty's FDA application stipulates that our transgenic salmon would be sold only as sterile fish: They would be unable to reproduce themselves, hybridize with wild fish or colonize wild habitat. And because sterile male salmon still indulge in "mock spawning" that could preempt the opportunity of a wild female to mate, Aqua Bounty's FDA application also stipulates that we will sell only female fish. Sterile females don't mature or return to freshwater, posing no threat to juvenile salmon, their habitat or to-local food webs, predatorprey dynamics or ecosystems.
While some critics claim that no sterilization technique is 100 percent effective, our experience--and 20 years worth of scientific literature--suggest that complete sterilization can be routinely achieved. In trial after trial, we have been able to achieve complete sterilization, and the effectiveness of our technique can be verified by observing either embryonic cells from the egg or blood cells from young fry under flow cytometry. We believe that a quality-assured sterilization procedure, full reporting of our efficacy trials and verification of sterility in every batch of fish produced will appropriately guarantee the environmental safety of our transgenic salmon.
Far from posing environmental risks, the rapid production cycle associated with transgenic salmon actually allows for improved environmental performance in the existing farmed-salmon industry. Just by making it affordable for farmers to grow sterile fish, transgenic salmon could eliminate the most important side effect of aquaculture--interbreeding between farm escapes and wild fish. Sterilization slows the growth rate and increases the mortality rate of salmon introduced to saltwater. In conventional salmon, these drawbacks make it economically impossible to grow sterile fish. But with transgenics, the rapid growth wait far outweighs the slowdown produced by sterilization.
Salmon growers "fallow" their farms between crops to improve water quality, manage nutrient loads and control marine microbes. Fallowing is the single most important--and effective--environmental-management technique available on water farms. After three to six months in fallow, virtually all evidence of fanning activity disappears from the marine environment. With the faster production cycle available using transgenic fish, farms can lie fallow twice as often as they do today. If transgenic salmon offer environmental benefits without increasing environmental risks, what is the real reason behind the environmental lobby' s attack? I'd like to suggest three related reasons.
First, many of the large, mainstream, environmental organizations have adopted the antibiotech posture that extremists and organic-food enthusiasts have been flogging for years in their crusade against transgenic corn, soybeans and cotton. The views of an antiaquaculture fringe associated with the Pacific salmon fleet also have percolated up through the environmental lobby. Between 1999 and 2002, for example, the California-based David and Lucile Packard Foundation funded $30 million worth of antiaquaculture propaganda, while the British Columbia-based Suzuki Foundation spent more than $5 million attacking aquaculture in the Pacific Northwest. Second, if biotechnological innovations such as aquaculture are adopted, the PC solutions--organic production, local vs. global supply lines and "small is beautiful" farm-steads--will return to the dustbin of history where they have languished since the Great Depression. Third, it may be argued that the real target of the antiglobal and anticapitalist greens is the corporate model of agriculture itself. These groups are driven as much by a pastoral fantasy as their concern for pesticides and pollution.
Transgenic fish will allow us to expand fish supplies with reduced environmental impact and with much less demand for space on our valuable coastlines. By producing twice as much food on the same amount of space, transgenic fish will help us preserve the wildlife, the habitat and the traditional coastal activities now threatened by overfishing, overcrowding and the increasingly urgent demands of a hungry world.
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