By Gabriel Scott
I've read some poorly crafted Environmental Assessments in my time, and seen more than a few ill-considered decisions, but this one might just take the cake.
Over the holidays the veterinarians at the Food and Drug Administration decided to approve an application to grow and sell genetically engineered salmon, a King/ Atlantic salmon cross with a sprinkle of eel pout, that grows twice as fast. This is the first time ever, in any country, that a genetically engineered animal would be approved for human consumption.
The decision is based on FDA’s preposterous conclusion that there is no difference between AquaBounty Technologies Inc.’s Frankenfish, and natural salmon, and no risk whatever of any environmental impacts. The decision is unleashing a firestorm of grassroots opposition. Objections span the ideological spectrum:
- Health advocates say GE Fish pose higher risk of allergic reactions, contain larger quantities of cancer-causing chemicals, and offer fewer health benefits than natural fish;
- Commercial fishing organizations and economists fear the economic and social consequences of flooding the market with cheap, unlabeled GE fish;
- Consumer advocates object to the lack of labeling (they’d be sold as “Atlantic Salmon”);
- Environmentalists fear escaped GE Fish could interbreed with wild salmon, , decimating populations and unleashing a cascade of harmful ecological interactions;
- Moral objections are raised by those who see genetic engineering of animals as the ultimate human hubris;
- Cultural objections are raised by indigenous peoples, for whom Atlantic and King salmon are sacred.
- Policy-makers and academics point out the current regulatory system (it falls under “new animal drug” regulations so decisions are made by veterinarians) is totally ill-equipped to handle GE fish.
All of these are good reasons to deny the application. In this post I’d like to raise what I think is the fundamental mistake FDA is making – they are making the decision blind.
It’s one thing to carefully weigh the pros and cons, and decide the risks are worth the reward. I’m not such a luddite as to think there is no room for debate on the merits of genetic engineering. But it’s another thing entirely when such a monumentally important decision is made on auto-pilot, without thinking it through and without stringent safeguards.
The Draft Environmental Assessment released over the holidays is all gimmick.
Here’s one example, a tricky legal maneuver to avoid even considering the economic and social effects. The gambit goes like this. Court cases suggest agencies don’t have to consider social, economic or cultural effects of a decision unless there are also physical environmental effects. Other cases suggest agencies don’t have to consider physical environmental effects outside the United States. Therefore, AquaBounty cleverly proposed to build their first batches of eggs in Canada, and to grow them out in Panama. Because the proposal takes place entirely overseas, and accepting the company’s claim that it is impossible even one fish would ever escape into U.S. waters, FDA claims there are no direct physical effects in the U.S., and, therefore, social, economic and cultural effects are ignored.
But as the economist Nicolaas Mink, PhD, explains in a recent article, these economic and social effects are a very big deal.
Here’s another. FDA doesn’t consider what escaped frankenfish might do to wild salmon runs, based on AquaBounty’s assertion that nothing could go wrong and fish could never escape. Truth is, all kinds of things could go wrong. Storms and floods could breach containment and release fish (the eggs will be built mere yards from the Atlantic Ocean). Eggs could be lost or stolen. Eggs could be sold on foreign markets, entirely beyond U.S. jurisdiction, where they could be grown under who-knows-what conditions. Without any jurisdiction in Canada or Panama, the FDA would be unable to monitor or enforce the many promises AquaBounty has made.
Accidents aside, everyone knows this is only the beginning. FDA pretends it's a routine decision on a “new animal drug,” affecting only a couple of ponds in Canada and Panama. That’s just silly. This decision is all about the precedent. The venture capitalists behind AquaBounty didn’t spend tens of millions of dollars to grow a few fish in the mountains of Panama. The decision is being closely watched all over the world. If this goes forward, there will be little to stop GE fish from being raised in ocean net pens in the United States, Canada or elsewhere—or perhaps even set loose from hatcheries.
Making such a monumental decision on the premise that nothing could possibly go wrong, ever, is flat stupid. How many times have we been down this road? They said farmed fish in net pens can’t escape, but they do. They said GE crops wouldn’t cross-pollinate, but they do. They said hatchery fish wouldn’t stray, but they do. Machines always work perfectly, until they don’t.
The really important question then is: what are the consequences of failure? The FDA studiously refuses to study it, but we can make educated guesses. AquaBounty’s GE salmon act like a person hopped up on steroids and high on crack. They are aggressive, live on junk food, are fearless of predators, and grow freakishly fast. A study in Proceedings of the National Academy of Sciences found that just 60 GE salmon in a population of 60,000 could result in extinction of the wild run in fewer than 40 generations.
If we come together and make our voices heard, we CAN stop this. We have allies. Lots of them. Back when he was just a candidate with a funny name, Barak Obama said GE foods should be labeled. Oddly, the President abandoned even that moderate position, leaving conservative congress-critters to take up the fight. Senators Begich (D-AK) and Murkowski (R-AK) have promised to “fight tooth and nail.”
But the best expression I’ve heard yet comes from Don Young (R-AK), as conservative a guy as you’ll ever want to meet. This may be the first time we’ve found ourselves fighting alongside Mr. Young, but he expressed my feelings perfectly the other day when he growled: “You keep those damn fish out of my waters.”
Couldn’t have said it better.
To submit a comment to FDA, click here.