175 responses

  1. Anastasia Bodnar
    October 16, 2010

    This comment is in response to a question by Gavin Venn, who goes by morethanorganic on Twitter:

    @geneticmaize, “no difference in animal health and welfare between AquAdvantage and wild type salmon” {judged on what criteria?}

    Here’s what I said about it in the post:

    Aqua Bounty Technologies, Inc. has submitted to the FDA’s Center for Veterinary Medicine (7) ten years of data indicating no difference in animal health and welfare between AquAdvantage and wild type salmon, but that information is not publically available.

    It was admittedly too short of a statement on the subject but frankly this article was already getting really long.I apologize, Biofortified’s readers (and readers of ISB reports) deserve better. So here goes…

    Reference 7 is the Environmental assessment for AquAdvantage salmon written by Aqua Bounty for the FDA Center for Veterinary Medicine to review. The FDA also got a lot of additional information that isn’t publicly available.

    Some of the data in the Environmental Assessment is considered confidential to protect the intellectual property of the companies submitting the data. Is this right? I don’t know. I don’t like it. I mean, I’m sure that the people evaluating the report and the accompanying data are doing a good job, but I’m the kind of person who likes to see things for myself. What to do about the lack of data? There are 3 options that I can think of: 1) change the regulations to prohibit confidential data from being used for risk assessment so all data in risk assessments will have to be available to the public. This doesn’t help right now, but I think it is a potential long term solution. 2) Sue for the data? I don’t know what the grounds would be but it could be an option. 3) Press Aqua Bounty for the data. This would be nice but they are under no legal obligation to provide the information. Since they haven’t provided it yet, I don’t think they’re going to.

    Anyway, the FDA Center for Veterinary Medicine discusses the EA and the data in the Briefing Packet on AquAdvantage Salmon. The word welfare isn’t used in the Briefing Packet but they do make conclusions based on their analysis of various aspects of the fishery process and the transgene on fish health. It’s worth a read if you are interested in the subject.

    One of the things discussed in the Packet, extensively, is culling. Farmers in all sorts of animal agriculture have a normal practice of taking small, deformed, abnormal, etc. animals out of the herd, school, etc. and euthanizing them. The practice is called culling. Fisheries are no exception, especially since farmed fish are prone to abnormalities, as I mentioned in this post. AquaBounty failed to count and describe the culled fish in their different populations of fish. So the data they gave to the FDA is incomplete, counting and describing abnormalities post culling. We don’t know if there were more juvenile fish culled in the diploid vs triploid populations or in the transgenic vs non-transgenic populations. The FDA assumes that culling rates were similar, but there is no evidence to support this assumption, which does make me uncomfortable as a scientist.

    The AquAdvantage fish coming out of the facility (post culling) don’t have any more abnormalities than wild-type fish. So, their health and welfare can be accurately described as similar. There may be more abnormal juveniles, though I do think we can assume that there aren’t so many more that it’s more expensive to grow them compared to wild-type fish.

    • Eric Baumholder
      October 17, 2010

      Anastasia,

      That information is confidential because after the relevant patents lapse, the company will still control the technology through control of the confidential information.

      So, after Aqua Bounty’s patents lapse into the public domain, a company wishing to use the technology would have to ‘license’ the confidential information from AquaBounty, or repeat all of the testing all over again.

      Those who believe there are virtues inherent in the patent system will of course find these ‘confidentiality’ shenanigans to be quite awful.

      As do I.

      • Ewan R
        October 18, 2010

        Actually given that the patent contains all the information to do the invention companies wishing to use the technology would only have to do testing which would be required anyway – if you create new events then you categorically should be doing all the required testing to prove safety and efficacy of those events – if you are utilizing the same exact events then no further testing would be required, your GMO-salmon would be covered under the same regulatory approvals as the original – the only issues would arise when regulatory approval falls by the wayside, however as the regulatory bodies would already have the initial information in their hands on the commercialized events this wouldn’t (or at least shouldn’t as far as I can see) be problematic at all in terms of confidentiality.

        I’d be interested as to which confidential material you’d view as being a block to commercialization of an off patent GMO (and what types of off patent GMOs they’d be a block to – same events or new events)

        RR1 in soy going off patent stands to be the test case for a GMO going off patent, and as things stand things look pretty rosy (to me at least, which may not be a shocking admission) right up until the point that regulatory approval is no longer covered (and here one hopes either the seed industry in general, or the USDA or such, can work something out)

      • Eric Baumholder
        October 18, 2010

        Ewan,

        It’s hard to say what exactly the confidential information is, since it’s confidential. But it would be truthful to say that it’s test data which were used to persuade regulators of a GM crop’s human and environmental health and safety.

        How valuable are the registration data?

        International regulatory approvals for biotechnology products are important for farmers because much of the grain they produce and sell is exported. Monsanto estimates it costs between $1 million and $2 million a year to keep up the registrations. That’s for registration data on first-generation RR soybeans, which are soon to go off-patent. [1]

        Thus, we can conclude that the cost for a license to the registration data of an off-patent GMO is “between $1 million and $2 million a year”. And we can conclude that the cost of the registration data will closely resemble what was spent initially to gain regulatory approval. The ultimate price of the license will also reflect the cost of doing the tests all over again. All of which, I submit, would be in the neighborhood of $1 million and $2 million.

        This is something like a patent granted by government agencies, except there’s no disclosure and they don’t expire. Neat-O, huh?

        ——

        1. http://www.reuters.com/article/idUSN0824689420100709

      • Ewan R
        October 18, 2010

        Eric – I’m not sure what the $1-2M p/a remark has to do with whether or not confidential information is released – if the regulatory body has the confidential info then you wouldn’t have to resubmit the same info, they’d have it (assuming you’re using the same events, which if you’re not makes the whole discussion moot) – if it’s testing which has to be repeated on a yearly basis then whether or not there is confidential information is meaningless – you’d be told exactly what data you need to generate and to what standards – generics will, imo, require widespread industry cooperation to maintain regulatory approval (short of there being a lifting of the requirement for reg approval on off-patent GMOs – really there should be) – given the cash under discussion a $1-$2M p/a cost of reregistration is pretty small when spread across the whole seed manufacturing industry (and when divided between the various regulatory agencies – one wonders what this breaks down to in cost per agency) and in terms of non-expiring patents I’d argue that if this was the case the whole RR1 expiration would be set up such that registration expired within days of patent expiry rather than 5+ years later.

      • Anastasia Bodnar
        October 18, 2010

        I don’t understand how safety testing has anything to do with the intellectual property. The important info is already out there – the construct, the transformation process, the method of inducing triploidy, etc. If I wanted to make AquAdvantage salmon, I could do it, given the right equipment. The patent is needed to protect the invention because it is relatively easy to make – once you know what genes to use!

        I think the tests used to determine substantial equivalence don’t have anything to do with the intellectual property. Releasing the data would only help Aqua Bounty prove the fish are healthy and safe.

      • Eric Baumholder
        October 18, 2010

        Let’s us think about history. In agro biotech, time passes roughly ten times faster than the rest of the world.

        Monsanto and other players around the world have spent countle$$ dollar$ to have courts block efforts to release results of human and environmental safety studies to be released to the public.

        We’re talking about literally untold thousands of tests which were conducted to achieve approval for a GM crop.

        Now, you would think, the agro biotech corporations would be motivated to release all the data that they give to the governments of the world, a deluge of data which would prove conclusively that their seed products were not only safe, but beneficial as well.

        Their motivations go the other way. The corporations are far more worried about their competition than they are about the consumer. Even though wholesale data on feeding studies, etc. would completely overwhelm claims made by “consumer advocates” such as Greenpeace. Like a tsunami.

        And, they can demand royalties from their competitors after demise of the basic patents.

        This is actually not unusual. Pharmaceutical companies do business the same way.

      • Ewan R
        October 18, 2010

        And, they can demand royalties from their competitors after demise of the basic patents.

        This is absolutely counter to the reality of the upcoming expiry of the RR1 patent.

        The regulatory bodies already have the ‘secret’ data pertaining to various transgenic events, it is a complete fallacy to suggest that this data would have to be regenerated for generic versions of the same event – new data would only be required for absolutely new events – which isn’t how it appears that generic GMOs are going to pan out (in the case of RR1 Monsanto has already stated it will not invoke variety patents to anyone breeding the RR1 gene out of their prorietary germplasm into another line)

      • Karl Haro von Mogel
        October 18, 2010

        Ewan, do you have a link to the Monsanto statement about breeding the RR1 gene out of proprietary germplasm? I remember a statement about the RR1 patent expiration that seemed to indicate that although the transgene patent will run out, the variety patents would still exist and impact breeding. But they may have revised it.

      • Ewan R
        October 23, 2010

        Actually it appears my understanding is totally wrong in this instance – you can’t breed it out of proprietary germplasm (unless you’re using it on your own farm only – I think that’s what had me confused – farmers will not have variety patents invoked for saved seeds on own farm)

        linky

        Has the rules – so in essence the RR1 trait will be out of Monsanto’s control (as it already exists in non-Monsanto varieties) however whether or not you can breed it out of these varieties is down to the owners of that germplasm – the fact University programs have the trait here is I think the biggest boon to getting RR1 out and about.

        I do however apologize for being so spectacularly off – rose tinted spectacles and all that!

  2. gavin venn
    October 17, 2010

    Anastasia, thanks for your response.

    As you know, like most of the public interested in this subject, i’m not a scientist. My interest is in understanding what is being done to these fish, why, and what will result. Your article is useful in helping me understand the genetic science and the facts being presented by AquaAdvantage.

    As i understand it, the idea behind the gmo salmon is that they grow much faster than other farmed salmon – this extra growth speed is due to the combined conditions resulting from the inserted genes.

    “The AquAdvantage fish coming out of the facility (post culling) don’t have any more abnormalities than wild-type fish. So, their health and welfare can be accurately described as similar.”

    What do AquaAdvantage believe “abnormalities” to be?

    The insertion of the new genes have specific actions. The increased release of growth hormone and resulting IGF1, act specifically on tissue receptor sites. Looking at the effects of excessive growth hormone production in humans, imbalanced development such as acromegaly can result. Is it not the case, that when one hormone is amplified, without consideration of the interdependency with other hormones and conditions, we have the potential for imbalanced development?

    Aquadvantage’s view of abnormalities is just that – their view, and I’m not sure what that view is based on? Are they simply looking for external irregular body development? If that is the case, surely they cannot base their view of abnormality on that alone?

    There is no ground to suggest based on a Aquaadvantage’s visual take of abnormalities that “their health and welfare can be accurately described as similar.”

    Wild fish are free and live interdependently in biodiverse environments. Their evolution over millions of years is intimately connected with the biodiversity of this planet. Wild fish are free to act on their natural insticts and grow at their natural rate – based on their interdependence with other living living creatures and systems. GMO farmed salmon are isolated from other biodiverse systems, in human managed systems and forced to grow twice as quickly. How can their health and welfare be said to be ‘similar’ to wild slamon?

    • Anastasia Bodnar
      October 17, 2010

      Hello Gavin. Thanks for stopping by. I hope I can help clear a few things up.

      The fish have only one inserted gene construct, as seen in figure 1, not multiple inserted genes. The promoter, coding sequence, and termination sequence (not terminator – that’s something else entirely, this is just a bit of code that tells the DNA to protein translation machinery that it can stop translating) make up one gene.

      The types of abnormalities are described in this post in the section titled Animal growth, health, and welfare. They are described in more detail in the two reports I listed earlier: Environmental assessment for AquAdvantage salmon written by Aqua Bounty and the Briefing Packet on AquAdvantage Salmon written by the FDA Center for Veterinary Medicine.

      Body abnormalities are one thing that can be observed, but not the only one. Behavior is another. Another is hormone content along with vitamins and other components of fish flesh, which was discussed in this post. There were only two differences found between the AquAdvantage and wild type salmon: Vitamin B6 (0.77 and 0.72 milligram per gram tissue, respectively) and IGF-1 (10.26 and 7.34 ng per gram tissue, respectively). I discussed the meaning and significance (or lack thereof) of these findings extensively in this post, in the section titled Human Health. All of the data adds up to us knowing that AquAdvantage fish are not significantly different than genetically similar fish. Saying that there is “no ground” equates to ignoring all the data.

      AquAdvantage fish are not expected to be similar to wild fish. They are expected to be similar to genetically wild type farmed fish (wild type means non-genetically engineered, it does not mean wild as in out in a natural ecosystem without human interference). Non-genetically engineered farmed fish are not normal compared to wild fish, which I address briefly in the section titled Conclusions. Farmed fish have all sorts of issues that wild fish do not have. These should be considered for animal welfare reasons and other reasons, but the important part here is that the concerns with farmed fish are not unique to genetically engineered fish. Blaming all the problems of fish farming on Aqua Bounty (the company that created AquAdvantage salmon) is exactly as if someone came up with a new breed of pig and we said “no, you can’t farm those pigs because some types of pig farming are inhumane and cause environmental damage”. We should look at how fish (or pigs) can be farmed sustainably and with as little stress to the animals as possible, no matter what kind of fish (or pigs) they are.

      • gavin venn
        October 17, 2010

        Hello, yes, the use of ‘wild type’ salmon to refer to NON-gmo farmed salmon was confusing. I’ve no doubt that non-gmo farmed salmon also have many issues.

        So not two seperate genes, but the gene ‘construct’ created by Aqua Bounty, takes regulatory sequences from an Ocean Pout, and a growth hormone gene with regulatory sequences from a Chinook Salmon. So traits are taken from two seperate creatures?

        from the briefing packet:

        “Nine internal organs were examined post-mortem in the animal safety study. These organs and structures were determined to be either normal or abnormal, and samples were taken for histopathology and other microscopic testing of abnormal findings.”

        – I couldn’t locate the findings of these tests?

        Thanks, gavin.

      • Anastasia Bodnar
        October 18, 2010

        I’m sorry Gavin. Despite my best efforts to leave out unexplained jargon, it creeps in. Wild-type is a term commonly used by geneticists to describe a non-mutant version of a gene and is also used to describe the absence of a genetically engineered gene.

        Any gene (natural or otherwise) has a main part termed the coding sequence, plus a promoter at the beginning that tells the organism’s gene translation machinery when and where to express that gene, plus an end sequence that tells the gene translation machinery to stop translating (there’s other optional gene parts but these are the big 3). These 3 parts = 1 gene. When creating an artificial gene, also known as a gene construct or just construct, these same 3 parts are needed.

        The easiest way to make a gene that will work in an organism is to just use promoters, coding sequences, and termination sequences that are from the species itself or a closely related species (like fish to fish). Once you know what sequences you want to use, it’s basically cut and paste but instead of scissors and glue we use enzymes that are naturally produced by different types of bacteria.

        As I described in this article, the construct used with AquAdvantage has a promoter and termination sequence from ocean pout. They used this promoter from ocean pout because it is always on. The regular promoter for fish growth hormone is only on during certain times of year. They could have used any promoter that works in fish that is always on, but I think they just used this promoter from pout because it was already characterized and it was expensive to characterize genes back then.

        AquAdvantage gene also has the coding sequence for growth hormone from Chinook salmon. I don’t know why they used the coding sequence from Chinook salmon instead of just getting it from Atlantic salmon, but it really doesn’t matter. The two coding sequences are extremely similar (90% identical nucleotides in the coding sequence and 98% identical amino acids in the resulting protein)

        10 years ago, this was the best technology. Now, there’s more sophisticated options being research that are almost ready to be used in real products. If someone wanted to make AquAdvantage today, there are emerging technologies that would allow a replacement of the normal promoter for Atlantic salmon with an Atlantic salmon promoter that is always on. Instead of being an insertion of a new gene, it would just be a replacement. The resulting fish would have no possibility of unintended genetic changes and 100% DNA from Atlantic salmon. The scientific difference between results of the old and new methods is tiny but I think maybe public perception would be better.

        To put it in terms of writing, the way that was used is like inserting a new sentence into an already existing book (and not a small book, either). The new way would be like replacing a word in an existing sentence in a book. The important thing to remember in both cases is that the grand majority of the sentences in the book are still the same. To bring it back to the salmon – these salmon may have a promoter sequence and a termination sequence from pout but that doesn’t make them into pout – they’re still salmon.

        As for those organ examinations, I’m not sure. Hopefully I’ll have some time to look at the reports again soon.

  3. andre
    October 17, 2010

    I have two words to add to this post: BRA VO.

    • Anastasia Bodnar
      October 18, 2010

      Thanks, Andre! I’m very glad that my work is appreciated :)

  4. gavin venn
    October 18, 2010

    Anastasia, hello.

    Thanks for your reply above – ive got more questions concerning the health of the gmo salmon, … but i wondered what you make of request for a moratorium on gmo salmon, by the genetic professor at university in Peru -based on there being inadequate protocol for the commercialisation of gmo fish.

    thanks, gavin

    • Anastasia Bodnar
      October 18, 2010

      This link Gavin shared is to a video presentation by Greenpeace titled Genetically Modified Fish : Latest Developments and Challenges.

      It is clear from the beginning that the 1st speaker doesn’t know what she’s talking about. She says that the fish will escape and breed with native fish thus reducing biodiversity. As I discussed in this post, the escape is unlikely due to many layers of containment. It might happen, but if it does it will happen at a very low rate so competition with native fish won’t even be an issue. If a fish survives to adulthood and finds a mate, the 1/2 of her offspring that have the AquAdvantage gene will be at a disadvantage to wild-type fish. This means that the gene won’t move through the population of native fish, instead the ones with the gene will die at greater rates than the native fish. Finally, how the heck is biodiversity reduced by adding a gene? Biodiversity is reduced when there is a large influx of genetically similar fish that reduce the genetic diversity of the native population – which is what happens with regular ocean based fish farming, not with the Aqua Bounty system.

      The second speaker says that risk = harm x liklihood. She says that even if the liklihood is small, we have to look at the harm, and if the harm is large then we have to consider the risk, which I totally agree with. She goes on to talk about all the problems with containing fish on fish farms and how so many fish have escaped from fish farms, which I don’t disagree with – escape of farmed fish has been a major problem and will continue to be a problem unless better containment methods are used.

      I just stopped listening at this point because it is obvious she wants to take all ills of fish farming and say they are problems of genetically engineered fish – but they are really problems of certain types of fish farming! Aqua Bounty has been very clear, let me repeat, very clear, that they do not intend to use sea pens or any other ocean based fish farming methods. The particular type of fish farming proposed by Aqua Bounty is far far far more safe for wild fish than any ocean based farming methods.

      The other issue that was brought up when I was still listening was a claim that companies were trying to force their genetically engineered fish into African countries that don’t have effective regulatory systems, so African countries won’t be able to protect their native fish stocks. I think the implication was that even though an elaborate containment system is the only way AquAdvantage will be produced in North America, the fish would just be released willy nilly in Africa. I find this claim to be highly unlikely, for one, and for two, this is a strong argument for good science-based risk assessment at some sort of centralized level with additional consideration for certain conditions local to the release of the organism. It is not a good argument for preventing African countries from using products of biotechnology if they want to.

      These two women are either 1) uninformed or 2) informed and purposefully putting out incorrect information. I will assume they are just misinformed and not purposefully spreading falsehoods. But I don’t think misinformed people are a good source for what should or should not be done with anything, and even more so for something that is technically complex.

      Frankly, I’m tired of people who don’t read anything, over generalize like crazy, and then want to be everyone else’s parent because think they know better. I don’t want to be rude, but come on. People who say they know what they’re talking about should actually know what they are talking about.

      • Karl Haro von Mogel
        October 18, 2010

        People who say they know what they’re talking about should actually know what they are talking about.

        Bare minimum, IMO.

      • andre
        October 18, 2010

        Anastasia,

        I have a lot of sympathy for your feelings. You write, you are tired; this systematic negative attitude from opponents makes me very angry…

        I took your very detailed post to mean two things: one, there is new Atlantic salmon which differs from the ordinary (farmed) salmon (which itself already differs from the wild salmon, having been the subject of breeding and selection) by the over-expression of a growth hormone; second, it is proposed to farm that salmon under conditions of extreme confinement.

        My guess is growth hormone over-expression happens in nature, and has been selected within certain species that are raised for consumption or pleasure of the eyes. So there is nothing sensational here.

        What changes, however, is that extensive studies are required because the fish is transgenic (a good thing as long as one does not request the impossible or unreasonable), and that confinement measures are proposed to be taken, this when the studies show that problems with escapes are most unlikely.

        And now come these people who paint us the apocalypse in an attempt to stop development. We humans have moved around species wilfully or by accident around the world, and are still doing so, taking risks (risk = harm x likelihood) that are far greater. We have also seen benefits. But when you say “transgenic”, the word “benefit” does not exist…

        The greatest threat to fish biodiversity is overfishing. Whether GM fish allow us to produce more effectively (something that still needs to be proven) and reduce the pressure on wild stocks is not a consideration in safety assessments. But if the applicant cannot prove beyond doubt that a GM salmon will mate with a wild one, you must impose a moratorium. Distressing.

        If I am not mistaken, you North Americans (and Chileans) raise Atlantic salmon on the Pacific coast and the salmon has not established itself because it has no natal stream to spawn. That would presumably also hold true for the GM version.

        More generally, I have not seen anything about a (negative) effect of farmed fish that have escaped on the genetic diversity of the wild fish within their own species. Once again, the domesticated animals are not well equipped to survive and prosper in the wild.

        I listened to the video. Appalling.

      • Anastasia Bodnar
        October 18, 2010

        I try to not get frustrated, but the frustrating stuff is overwhelming sometimes!

        Growth hormone overexpression does happen without genetic engineering. I remember reading that farmed fish have been bred for higher growth hormone expression (accidentally, they were really bred for increased size and growth rate) but I don’t recall the source, unfortunately.

        There is a negative effect on wild fish from escaped fish due to a decrease in genetic diversity – if there are a lot of escapees. If it’s just a few, then it’s not a big deal. This is because the farmed fish are more genetically similar to each other than wild fish in a population are. I found this reference that was pretty interesting:

        Fraser DJ, Houde AL, Debes PV, O’Reilly P, Eddington JD, & Hutchings JA (2010). Consequences of farmed-wild hybridization across divergent wild populations and multiple traits in salmon. Ecological applications : a publication of the Ecological Society of America, 20 (4), 935-53 PMID: 20597281

        I agree – the biggest risk to wild fish is overfishing. Anything we can do to feed human demand for fish flesh that reduces demand for ocean caught fish would help. Regulations on fishing haven’t worked for the most part, because at least some fishermen are willing to break the rules. Land based fish production would help serve demand and could potentially reduce prices so it’s not so lucrative to break the rules to fish anymore. I’d prefer tilapia over salmon because tilapia are easier to feed, but people don’t want tilapia, they want salmon and tuna. I see these photos of prize winning triploid fish and wonder why we aren’t farming these things on land like crazy.

  5. David Edwards
    October 18, 2010

    Very nice explanation of the science behind the GE salmon. I do appreciate the explanation of questions that might arise and whether the data available support an answer to the questions. The message that can sometimes be hard to communicate is to look at all of the data as a whole and how this adds up to a risk assessment. You have done a nice job of merging the analyses and looking at the whole picture.

    One technical note is that the FDA process of “approval” of a new animal drug application uses slightly different terminology than the “deregulation” process at USDA. This also means that post-approval monitoring is built into the approval process, so the FDA has the authority to continue to inspect the production facilities (fish farms) of the company. Additionally, each new farm that the company would like to have raise fish would require a new supplementary approval process by the FDA.

    Great job communicating this complex subject.

    • Anastasia Bodnar
      October 18, 2010

      Thanks, David. I appreciate the clarification about approval vs deregulation. I’m really a plant person, so I don’t know much yet about the animal or drug regulations, although I’m learning. It’s interesting that monitoring is built into the approval process. That means that, in the long term, AquAdvantage fish farming is even much safer than I thought, definitely safer than ocean pen fish farms when it comes to environmental safety for wild fish.

  6. gavin venn
    October 19, 2010

    Hello Anastasia, is it not prudent to consider all views here?

    One of the speakers from the video is a genetic science professor from a university in Peru, who, like yourself, works with gmo corn. This speaker is clearly, like yourself, highly experienced with gmo technology, as that is also her life work. Her view seems to be that it is unwise to proceed with the commercialization of gmo fish, until there is adequate international protocol in place to manage it safely.

    I’d also like to point out that like yourself, this professor, who works with gmo corn, is being called upon to comment / advise on gmo fish. Are we not hearing from professors focused on gmo fish because there are none? Surely the area warrants long term, dedicated high level scientific focus before we can approach the question of risk?

    There is already an argument that escaping NON-gmo, FARMED salmon, affect stocks of wild salmon in natural ecosystems, as their behaviour is different. As you know, salmon in natural eco systems like to move about as part of their life cycle: at the moment we don’t understand how contamination with gmo salmon would affect the multitude of biodiversity in natural ecosystems.

    So until we have a clear understanding of that, and international protocol in place to not only prevent it happening, but also ensure how it is effectively managed if / when it does happen, surely it would be unwise to proceed with commercialization?

    Proceeding without such protocol in place, would (in the opinion of this simple peasant farmer) present an unacceptable risk to international biodiversity, and possibly connected human rights.

    • andre
      October 19, 2010

      Ideally, it would indeed be prudent to consider all views and to have an international protocol in place. But then what to do with those views that are clearly out of order, and those that only serve to block the decision? And how to reach a protocol in the current ideological and political environment? I am writing from Europe, where this problem is really acute.

      The vicious circle is that in order to have a clear understanding of the issues, and subsequently a protocol, you need a larger scale experimentation, and to get that one those who have apprehensions want a clearer understanding.

      There is also a clear bias in the scientific production. It is my observation that many studies do not address the real issue, that sophisticated laboratory tests are preferred to grass-root observations. Moreover, ‘science’ must report problems (if you want to publish); if you have not found any problem, you have not conducted good research (the exception here is where somebody has reported a problem; then others came jump in, as for example with Bt and monarque; or GM and local maize populations in Mexico or Peru). The problems get media attention, more and more at the initiative of the researchers themselves. And policy decisions are shaped by media hype rather than hard science.

      Where does that lead us with salmon? I have not yet found anything serious on what really happens in nature, except that two million fish escape per year in the North Atlantic and that “hybridisation phenomena have been observed”. I’m frustrated!

      Here is another reference:

      http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1691531/pdf/14667333.pdf
      Fitness reduction and potential extinction of wild populations of Atlantic salmon, Salmo salar, as a result of interactions with escaped farm salmon
      Philip McGinnity, Paulo Prodöhl, Andy Ferguson, Rosaleen Hynes, Niall O Maoiléidigh, Natalie Baker, Deirdre Cotter, Brendan O’Hea, Declan Cooke, Ger Rogan, John Taggart, and Tom Cross

      From the paper: “In the experimental conditions where parr emigrants survived, farm salmon had an estimated lifetime success of 2% relative to wild fishes.” And: “In addition to direct genetic effects, offspring of escaped farm fishes may also reduce the size of the wild population due to competition. Although overall survival of farm and ‘hybrid’ fish was lower in the experiment, due to their larger size, surviving fish resulted in competitive displacement of wild parr.”

      Given that the GM salmon is reported to be less fit than its normal farm counterpart, it may well be that it would be an improvement in terms of genetic diversity and biodiversity concerns.

      We do not know a lot of things about salmon; and what we know has not been put together in a systematic way. Yet we farm salmon. Ironically, with the advent of a GM, we will know more. Anastasia has already dealt us a lot to enlighten us.

      By the way, the question of escapes spawning has been raised in the Greenpeace non-event (at around 71) – by one of the presenters, which shows their level of understanding… – but the thing got lost in her gobbledegook. Previously (at 59), an Argentinian said that escapes had not colonised Argentinian fresh waters.

      Of course, I am not underestimating the criticism levelled at fish farming. But most of it appears to originate from farming itself, irrespective of the genetic constitution of the farmed fish (e.g. issues of parasitism).

    • Anastasia Bodnar
      October 19, 2010

      Considering all views is important…. but… when the views completely go against known science, I think we can start to shave off a few. There are a lot of views out there that are based on completely confused and non-science views of reality. Should we consider those?

      Arguments that vaccines cause autism, for example, persist despite a decent heap of evidence that it doesn’t and the fact that the few studies that found a link were complete crap. When considering public policy having to do with vaccines, should we consider those views? I hope not.

      Anyway, with genetic engineering, I understand where they’re coming from and what their concerns are – but they’re taking those concerns and making illogical arguments.

      With the transgenic fish, these people have a non-science based view that sterile, genetically engineered fish in a land based fish production facility somehow have greater risk to wild fish than farmed fish (that have in many cases been bred for traits not common to wild fish like increased growth rate) in sea pens. I’d be a lot more willing to listen to them if they were at least consistent. Banning all ocean-based fish farming would have a greater positive effect on wild fish than banning genetically engineered fish (unless you consider the increased fishing of wild fish that would result if we removed farmed fish from the market). The view they have is a knee jerk against a technology, not a science-based analysis.

      They’re also arguing that lack of regulation in Africa and elsewhere means that no one else should be able to use the technology. Does that really make sense to anyone? Instead, they should argue for regulation to be developed in those countries or maybe for a universal international regulatory framework.

      Maybe it’s a language thing? I think they are smart and they care about what they are talking about – so how do they end up with such bad conclusions?

  7. andre
    October 19, 2010

    There has been quite a discussion in the initial comments on, let us say, intellectual property. Since this a response and a supplement to several comments, I am posting this as a new one.

    There is a legal system, with fairly broad variations around the world, called protection of undisclosed information or, in short, data protection or data exclusivity. Article 39 of the TRIPs (Trade-Related Aspects of Intellectual Property Rights) Agreement (under the WTO) says:

    1. In the course of ensuring effective protection against unfair competition as provided in Article 10bis of the Paris Convention (1967), Members shall protect undisclosed information in accordance with paragraph 2 and data submitted to governments or governmental agencies in accordance with paragraph 3.

    2. Natural and legal persons shall have the possibility of preventing information lawfully within their control from being disclosed to, acquired by, or used by others without their consent in a manner contrary to honest commercial practices (10) so long as such information:

    (a) is secret in the sense that it is not, as a body or in the precise configuration and assembly of its components, generally known among or readily accessible to persons within the circles that normally deal with the kind of information in question;

    (b) has commercial value because it is secret; and

    (c) has been subject to reasonable steps under the circumstances, by the person lawfully in control of the information, to keep it secret.

    3. Members, when requiring, as a condition of approving the marketing of pharmaceutical or of agricultural chemical products which utilize new chemical entities, the submission of undisclosed test or other data, the origination of which involves a considerable effort, shall protect such data against unfair commercial use. In addition, Members shall protect such data against disclosure, except where necessary to protect the public, or unless steps are taken to ensure that the data are protected against unfair commercial use.

    The devil, for innovative companies, is in “except where necessary to protect the public”. The legal regimes thus range from full confidentiality to full disclosure. It is on the basis of a constitutional disclosure requirement, enforced through court in Germany, that Séralini was for instance able to statistically rehash Monsanto’s data for for NK 603, MON 810 and MON 863 in “A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health” (1).

    Protection of undisclosed data against unfair commercial use means in particular that a competitor, for instance for a medicine, would not be able to rely on the originator’s safety and efficacy data resulting from pharmacological and toxicological tests and clinical trials for a given number of years. This is irrespective of the existence of a patent pertaining to the medicine. In the United States, the duration of data exclusivity is five years for new chemical entities, and three years for other pharmaceutical products. In its negotiations with other countries for free trade agreements, the US advocates five years. In Europe, the duration basically is ten years. Producers of generics usually do not have to produce fresh safety and efficacy data after the expiration of data exclusivity for the originator, but only product equivalence.

    “How to Calculate Standard Patent Expiry Dates and Data Exclusivity in Key Territories” (2), though somewhat antiquated may be consulted by those interested in this legal maze.

    I have not looked into the scenarios applying to GM varieties. My guess is this has not yet been fully explored. Circumstances are different from those in fine chemistry. If we take the GM salmon, the competitor might base his activities on fish from the originator (legally or illegally obtained) or on newly modified fish.

    It is interesting to note that, at least in Europe, the marketing authorisations for GM are granted for ten years and have to be renewed “on application to the Commission by the authorisation-holder”. How will this work when the authorisation holder has gone bust, is no longer interested contrary to competitors, is no longer alone on the market having lost intellectual property protection… enough to ruminate in sleepless nights. Similar question for post-authorisation monitoring.

    (1) http://www.biolsci.org/v05p0706.htm

    (2) http://www.genericsweb.com/How_to_Calculate_Standard_Patent_Expiry_Dates_and_Data_Exclusivity.pdf

  8. gavin venn
    October 19, 2010

    Hello Anastasia,

    You seem to have ignored my comments here about the professor of genetic engineering, at Peru university, who is clearly not against science, and is equally as qualified as yourself to comment on the science around this subject.

    “Maybe it’s a language thing? I think they are smart and they care about what they are talking about – so how do they end up with such bad conclusions?”

    Who are you referring to with “they”??

    • Anastasia Bodnar
      October 19, 2010

      By “they” I meant the two women in the video who spoke before I gave up and stopped listening.

      Please tell me what is the professor’s name. There isn’t any Peru University that I could find. If there is such a university and she is a professor there in a relevant field (population genetics would be best), then she’s actually more qualified than I am to talk about these things. I don’t have my PhD yet and I study corn, not fish, and I don’t have practical experience in wild population genetics. Still, being a professor doesn’t automatically mean that you know what you’re talking about, either. We have to judge statements by their merits, not by who is saying the statements, so the who doesn’t really matter to me.

      The woman in the video is making the following arguments:

      1) ocean fish farms have problems, particularly escape of farmed fish
      2) we should ban genetically engineered fish (even if they are sterile and farmed on land) until we can determine the effects of escaped fish on wild fish

      but 2 does not follow from 1 at all. Her argument is fatally flawed.

      If she said:

      1) ocean fish farms have problems, particularly the escape of farmed fish
      2) we should ban ocean fish farming until we can determine the effects of escaped fish on wild fish, including a ban on land based fish farms because they are unlikely to be 100% effective in keeping fish from escaping

      then I would say, she has a point, there has been relatively little study of the effects of escape of farmed fish on wild fish. And then I would counter by asking if we can compare the effects of the following:

      1) the potential risk = harm x likelihood of escape of ocean farmed fish
      2) the potential risk = harm x likelihood of escape of land farmed fish
      3) the potential risk = harm x likelihood of escape of land farmed genetically engineered fish
      4) the potential risk = harm x likelihood of stopping fish farming

      on wild fish populations. Perhaps the potential risk of the various options for fish farming are greater than the risk of over fishing leading to extinction. Perhaps not. This is something we can discuss.

      We can also discuss the risk of escape from the land based facilities. Perhaps call for a mandate of testing of likelihood of escape with non-genetically engineered fish. Aqua Bounty could start producing wild-type salmon in their facilities and nets or something could monitor how many fish escape.

      There are other valid, useful things to discuss. But saying that genetically engineered fish should be banned or put on moratorium or whatever because ocean farmed fish can escape doesn’t make any sense.

      • Karl Haro von Mogel
        October 19, 2010

        Calculations of risk have to take into account both sides of the risk equation. It seems like people are arguing that even if the chance of a catastrophic collapse of fish populations is extremely miniscule, that when you multiply that low chance by the high amount of damage, that no matter what, you are compelled to avoid this activity (genetic engineering) that could potentially lead to that catastrophic collapse. However, this risk calculation is imbalanced because it only takes into account the risk to wild fish if the GE fish are raised – and not the risk if GE fish are NOT raised. I think we can all agree that the oceans are overfished in one place or another to feed the huge human demand for fish. Let’s say that this inland-raised salmon produces a huge amount of fish to meet some of that demand, thereby lifting some of that pressure from wild fisheries. If the fish grows twice as fast, it could mean something like twice as many fish per year in the same facility. The converse argument follows that if we do not raise the GE fish, there will be a continued (and rising) demand for wild (and ocean-farmed) fish, which makes the collapse of ocean fish populations ALSO likely.
        I don’t buy the near-zero risk of catastrophe argument against doing something. In simple terms, it is possible (although the chances are near zero) that if you get up tomorrow morning, that a chain of events could be started that leads to the world being destroyed by nuclear weapons. Maybe you would have accidentally pissed off a terrorist who was going to push the button. Does that mean that you should not get up in the morning because of that tiny chance of complete and utter incineration of the surface of the Earth? No, because there is also a tiny tiny chance that you staying home tomorrow can lead to the same thing. Maybe you will inspire the person to pursue a career in intelligence who eventually prevents the terrorist from succeeding.

    • Charles M. Rader
      October 19, 2010

      Gavin, I started to look at the video link Anastasia posted. I’ll tell you exactly where I stopped, and why. It was when the speaker brought up a study which she said showed that as few as sixty escaped fish in a population of sixty thousand would lead to total extinction of the population.

      I stopped because I am familiar with that work, by W. H. Muir of Purdue. It is irrelevant to discussing transgenic Aqua Bounty salmon.

      The study was a computer simulation. The model fish simulated was a fish medaka, not salmon. Male medaka breed constantly. In the study model, there were transgenic males which were larger than the wild males and they were modeled as having a competitive advantage in mating, but a disadvantage in fertility. The transgenic females were modeled as more fertile. Not surprisingly, this led, in the study, to fewer and fewer offspring each generation, and a higher and higher percentage of them having the transgenic male characteristics.

      A study for the Aqua Bounty salmon would have 180 degree differences. Most important, the medaka study had transgenic males and the transgenic salmon are females. Besides that, medaka breed constantly but salmon breed only once, and almost always the salmon ready to breed make a long journey and selectively seek the stream where they were spawned, which the transgenic females will have a hard time finding. The presenter has to have known this. She was engaged in deception.

      • Anastasia Bodnar
        October 19, 2010

        It is very frustrating that people are using this computer simulation as “proof” that AquAdvantage salmon will breed wild salmon out of existence. The differences between the simulation and the reality of AquAdvantage are so wide that the simulation isn’t useful at all.

        Now, if someone was planning to release into the wild lots of fertile transgenic fish where the transgene was in males and it was a trait that made the fish better able to survive in the wild and the reproduction rate was high – then yes, the transgene would be in a large percentage of the population very quickly – and we might refer to this simulation as evidence. However, this hypothetical situation in the simulation would never come up, because it would never be approved for hopefully obvious reasons.

        I don’t know that much about population genetics, so I might be reaching here but I do have a question about the medaka study. The author claimed that the fish would go extinct, but I find that unlikely. The reduced fitness due to having the transgene would be balanced out by the increased reproduction rate at least some of the time, wouldn’t it? Unfortunately I can’t access the paper at the moment, my school library’s website is being temperamental – but I do wonder how many iterations the simulation ran for and what percentage of those runs resulted in extinction or other outcomes.

  9. gavin venn
    October 19, 2010

    Anastasia,

    Just to clarify, the professor I refer to is the 3rd main speaker in the video (not including the female presenter at the beginning)

    I’ve asked Greenpeace, for the details of the female professor – and will provide when I get them. As far as I can tell from the video, the institute is:

    La Molina National Agrarian University, Peru.

    As I understand it, this professor is also working with gmo corn – hence my question about the lack of high level academics focusing on gmo fish.

    • Anastasia Bodnar
      October 19, 2010

      Gavin, I appreciate your work to get people to look at this video, but I must reiterate. It doesn’t matter who’s talking if the arguments aren’t sound. At what time point does the 3rd speaker start? I’ll try to listen to it if you say where to start from, but I’m sorry I just don’t want to sit through any more of it than I have to.

      Just look at the slides alongside the video. There is missing information and wrong information. If the person/people making the slides couldn’t bother themselves to find readily available information that I could find, then why should I bother listening to their arguments? I’m sorry, but if any of the people in the video are going to claim to know what they are talking about then they should have done a little research before going before the camera.

      It took me a week to write this article due to all the research and reading necessary to present what isn’t even a full picture of the AquAdvantage salmon. For someone to go up in front of a camera saying they know all about it and expect people to listen to them when they couldn’t even do the same amount of research that I did is preposterous. Sadly, I know there are probably tons of people who have watched this and just nodded their heads, assuming they are telling the whole story.

      Oh, and the slides say a lot. They cite a Canadian Royal Society report that discusses genetically engineered fish, lamenting that it hasn’t been ratified and saying that it has been ignored by the Canadian government. But their own slides show that this report recommends “that approval for commercial production of transgenic fish be conditional on the rearing of fish in land-based facility only”, which is EXACTLY what Aqua Bounty is asking for.

    • Anastasia Bodnar
      October 19, 2010

      I don’t know if it matters, Gavin, but I just wanted to clarify – I have no horse in this race. I don’t personally care if genetically engineered salmon is approved or not. Regardless of what happens I will not eat salmon (or any other animal). I don’t have any financial or philosophical ties to the genetically engineered fish or the idea of genetically engineered fish.

      I just don’t like it when people are intellectually dishonest, which is what a lot of opponents of the fish seem to be. Why aren’t they doing their homework before writing or speaking on the subject? Or if they are, why are they leaving so much information out and/or misusing information?

      It’s not just opponents of genetic engineering that deserve an examination. I’m not selective as to who I turn my skeptical eye on, and I don’t think a lot of the frequent commenters here are either. For example, see a recent post by David Tribe on the recent study that claimed Bt corn had a positive effect on non-Bt corn near by. Other than Eric B., everyone was interested in what the study said but still looked at the data skeptically, wondering if the science really supported the claims that were made, even if the claims supported the general idea that genetic engineering can be useful.

  10. gavin venn
    October 20, 2010

    Hello again Anastasia,

    The professor from Peru, begins talking around 28.50 into video.

    I think possibly, you havn’t seen her yet – she is saying much of what you are saying, and she is certainly not anti- gmo. I’m sure she isn’t intellectually dishonest either – please listen to what she says. The two of you would benefit the future of gmo technology by developing a dialogue :)

    That’s really what i’m interested in Anastasia – dialogue. You know i’m anti gmo – but i’m not so short sighted to believe that every one sees things like I do, or that the world will somehow fall into line with my ideas. And I’d like to think that respected scientists’ like yourself are not so short sighted to believe that your individual interpretation of some data is the correct or only view. We need a deeper understanding than that – we need dialogue to determine what data needs to be captured (& by who), to approach risk analysis on a case by case basis. This process needs to be approached in an open / transparent way.

    best wishes, gavin

    • Anastasia Bodnar
      October 21, 2010

      It sounds like the person who introduced her said “Antonietta Cartera at the University of Peru” but later Antonietta said she worked at National Agronomy University, I think. I couldn’t find her with a Google search or a Google Scholar search but that’s probably because I’m spelling her name wrong. I’ll try to transcribe what she says. I’m sorry if I didn’t get everything. I’m not good at transcribing and I can’t really understand a lot of what she says due to background noise, and her accent. I apologize. Here it is:

      There are different kinds of transgenic fishes and that the technology is very well known in many countries. An example is ornamental fishes – no one knows if they are transgenic or not. Other fish that are for human consumption like tilapia, carp, and salmon are transgenic. Transgenes now-a-days are placed on fishes. That means we have to know the molecular approach just to read case by case when we are faced with one or another transgenic fish. There is a lot of literature and it is important to have in our country people who know about transgenic animals. We can’t really be excellent in many topics (plant, animal, bacteria). When we are using some specific case we have to think what are the impacts because this is our tropical room, what are the physical impacts these organisms will show in our environment with other organisms and biodiversity. We also have to look at whether the character you are introducing will have pleiotropic effects on other genes. Also specific issues related to patenting. Some specific characteristics when we are trying to proof transgenic animals are physical and biological. We don’t want to have a very high effect on biodiversity. Triploids are produced naturally without transgenic fishes. We know what is the behavior of those triploids. We have to know if the triploids are 100% sterile or not. We don’t have transgenic fish companies in our countries. Instead we produce aquatic organisms naturally. Nonetheless, last November we had something happen that made us realize how difficult it is to react to and understand a situation. We have a fishery faculty at my university. A man came to my office to talk about a proposal he had from a private company that wanted to have an experiment on transgenic salmon. The proposal doesn’t have much information. He gave a report to his boss but his boss didn’t understand the report so he thinks his boss will start the experiments. The man went to different professors but they didn’t want to help him. She told him that she is not finished with her corn research that many people are talking about. But if no one will help him then she felt that she had to help him. She gave him information that she got from her friends. She realized she had to organize the National Authority on how to differentiate between different fish. They didn’t realize there were transgenic fish in the country. With transgenic corn she could react immediately but with all kinds of animals it is different and we don’t have the protocols. We have international laws but international companies don’t have to follow the laws. Now the transgenic salmon is in the way to be accepted for human consumption after they come to places like our country. We need a technical group to be the guide for transgenic animals to use a a scientific paper in countries where companies are asking to introduce transgenic animals. My conclusions are that there are a lot of information available on transgenic fish, specifically salmon, but that infoamrion is not possible to extrapolate from one situation to another. Growing salmon in the highlands in Peru is totally different from growing it in Canada or Panama. We have to show the industry that transparency is important. In Peru, we would have never known about that if the man had not come to my office. The companies are not taking into account our laws. The use of modern biotechnology especially in developing countries brings many concerns, not only related to environment and health but also socioeconomic relations and intellectual property rights also related to the implementation of our rules. For that reason I appeal to all of you to think about that. It is not only political things it is only allowed how far we are to face the biotechnology we now face in our country.

      Then the moderator asked if the company in Peru that the man talked about was Aqua Bounty and Antonietta said yes.

      I won’t nitpick about little things like “Transgenes now-a-days are placed on fishes” because probably that’s either transcription error due to my bad ears or a translation problem as a native Spanish speaker is speaking in English. I’m sure that even if I was as good at Spanish as Antonietta is at English I’d make similar mistakes. Still, I have some responses to Antonietta.

      First, the claim that Aqua Bounty tried to do transgenic fish experiments without government permission is very serious. As in lawsuits and fines and big trouble for the company like bankruptcy serious. More information, preferably in document form, that Aqua Bounty really did mean to do this is needed. Was Aqua Bounty just entering into initial discussions for creating a safe facility like the one in Panama that would eventually turn into government requests for permission to use transgenic animals, or was Aqua Bounty really intending to release transgenic salmon in Peru without any safeguards? Antonietta doesn’t specifically say either way, but she implies that Aqua Bounty was going behind the government’s back and totally disregarding Peru’s laws and regulations. Very serious claims require very serious proof.

      Second, the triploid induced salmon are not 100% sterile. The process is 98.9% effective, on average. That’s why all the other biological, physical, chemical, environmental, and climatic (temperature) containment methods are used.

      Third, yes, the use of biotechnology in developing countries does have many concerns, including ecological, socio-econmic, and intellectual property. So does the introduction of any other technology or any other different way of doing things.

      I agree that potential ecological impact must be evaluated and mitigated for any technology before it is introduced to a country and there probably are problems with assuming that developing countries have the capability of doing this for themselves. Technologies and changes that could cause harm are many. From mines to power plants to clear cutting forests to grow cash crops to diluted natural gene pools from introduced varieties of sexually compatible species… so many things. I’d love to see the UN, World Bank, or other international group be given a little more power and funding so they can properly evaluate things like new coal mines and new transgenic fish egg production facilities being built in developing countries.

      As for socio-economic impact, sure. It would be nice to have some sort of country by country rules or maybe even international standards. But what would this mean in reality, outside of the realm of theory? Let’s look at clothing factories in developing countries in Asia. Have these had socio-economic effects? Undoubtedly. I think a strong argument can be made showing that building of factories in cities in Asia pulled people out of the countryside and now there are too many people in the cities which have huge slums for the factory workers and they aren’t paid enough to live in decent housing or to buy decent food. Perhaps those people would have been better off in the rural areas. I don’t know – but there wasn’t any socio-economic evaluation before the sweatshops sorry I mean factories moved in. Do transgenic plants or animals deserve more socio-economic analysis than factories?

      As for intellectual property, well, that’s complicated. Patents exist on many things and often those patents are ignored in developing countries. For example, medicines that are patented in developing counties are counterfeited in developing countries (the same thing happens with transgenic traits, actually). If we’re going to worry about intellectual property concerns for transgenic plants and animals we wouldn’t be very consistent if we didn’t also consider intellectual property concerns with everything else.

      Antonietta didn’t really say anything surprising. She seemed fairly reasonable overall except for her claim about Aqua Bounty. I would love to know her position about socio-economic and intellectual property concerns for all new things and processes entering her country besides transgenic fish.

    • Anastasia Bodnar
      October 21, 2010

      Just for clarification, risk analysis for genetically engineered plants and animals is done in the US on a case by case basis. I don’t know that much about other countries.

  11. gavin venn
    October 20, 2010

    …sorry to drone on, but perhaps people could consider changing the idea of ‘risk analysis’ into something that encompasses a much broader range of coverage.

    Thank’s for the dialogue

    • Anastasia Bodnar
      October 21, 2010

      What exactly do you think should be encompassed into the idea of risk analysis and what should be included in the practice of conducting a risk analysis?

      I am also wondering what you think about including the risk of not doing anything in risk analysis.

      • gavin venn
        October 22, 2010

        hello Anastasia,

        it would be reasonable to understand:

        *what we are were dealing with in case of contamination – effects on natural eco systems of introducing an invasive species. Here, we’re not only concerned with direct effects on wild salmon, but also other life in those eco systems. And how these effects of contamination impact people who depend on these natural ecosystems – across all affected Nations.

        *effects on humans from eating gmo salmon.

        I’m sure there are many more interested people that could suggest further areas of study: my knowledge is limited.

        It would be sensible to involve experts (which i am not), from all connected areas to give their input on what should go into a satisfactory risk assesment – and involve them in capturing the relevant data.

        The transparent creation and delivery of risk assesment is essential: let’s not forget, the present limited risk assesment is being derived from Aqua Bounty’s data.

        “I am also wondering what you think about including the risk of not doing anything in risk analysis?”

        not sure what you mean here? do you mean the ‘risk’ of not commercializing gmo salmon?

        thanks, gavin

      • Anastasia Bodnar
        October 22, 2010

        Gavin, did you read the Briefing Packet on AquAdvantage Salmon written by the FDA Center for Veterinary Medicine? It details all the aspects of risk assessment that were considered, including potential effects on human health, as I discussed in this post. As for ecological risk, I discussed that in detail in this post as well. Long story short, the ecological risk is extremely small due to low probability of escape and low harm for the few fish that might escape. There could always be more data, as I discuss in the conclusion of this post, but the risk assessment is pretty strong as is. The risk assessment did include much data from Aqua Bounty but also included examination of other research that was relevant to the situation. It included experts from a variety of fields (see the FDA Center for Veterinary Medicine website for details of who is on the Veterinary Medicine Advisory Committee). I suppose more people could be included from even more areas but at what point do we say enough is enough?

        Yes, I do mean that we should consider the risk of not allowing Aqua Bounty to grow and market AquAdvantage salmon. Wild salmon are threatened by overfishing, by ocean-based fish farms, by climate change warming the oceans, by human-caused and natural changes to freshwater breeding grounds, and so on. Alaska fishery groups might want us to believe that everything’s hunky dory but without a doubt we can not supply demand for salmon without harming the fish populations to the point that they will not recover. Salmon, like most other fish people like to eat, are going to go extinct or at minimum reduce in numbers so much that they may as well be extinct. Fish farming is a necessity to provide enough fish flesh to consumers so maybe we can leave the wild ones alone enough so their populations can recover – except we know that ocean based fish farms are harmful to wild fish. Raising fish on land isn’t happening very much because the cost is too high to justify doing it. Bring in fast-growing fish which Aqua Bounty apparently thinks will offset the high cost of building and operating specialized facilities. Perhaps, if the first facilities prove to be economically viable, other facilities could be built, eventually supplying a large amount of the total salmon demand. If it becomes more profitable to raise salmon Aqua Bounty style than it is to catch wild salmon (perhaps with some assistance from regulation that reduces catch sizes so more wild fish go free) then the wild populations might have the opportunity to recover and the populations of predators that depend on salmon will also recover. This is a whole lot of maybes and hopefullys but they are based on real predictions based on economics, population genetics, ecology, and everything we know about ocean based fish farming.

        There are risks to acting but there are risks to inaction. We must consider both.

      • gavin venn
        October 22, 2010

        hello,

        yes, on your advice i already read the FDA briefing packet.

        “As for ecological risk, I discussed that in detail in this post as well. Long story short, the ecological risk is extremely small due to low probability of escape and low harm for the few fish that might escape.”

        a small risk is a risk – no matter how the probability is calculated. with no international protocol in place to manage risk, a small risk very quickly becomes a large one.

        And we don’t know or can prove how these gmo salmon will affect natural eco systems: we’re hearing your view and those of the FDA based on the data you’re analysing.

        I dont see fish experts on FDA panel and try as i might, i cant find any GMO fish experts either.

        I’ll come back to talk about your view of gmo salmon being a useful food later.

        thanks, gavin

      • Anastasia Bodnar
        October 22, 2010

        This application is for the egg facility in Panama and the fish facility in Canada ONLY. It is not an application for release in whatever country they want. If Aqua Bounty wanted to have any other facilities, they’d have to get permission from the country the facility was to be built in and from the country they plan to sell the salmon in. An international protocol is not only unnecessary, it is impossible. Just look at the EU. They were unable to create an EU wide regulatory agency.

        A small risk is still a risk but the risk to wild salmon and their ecosystems from the AquAdvantage salmon is arguably much smaller than the risk of ocean pen farmed salmon and other fish. Can we guarantee 0% chance of an unanticipated result or 0% chance of anything bad happening? No. But we can be reasonably sure based on the evidence. AquAdvantage is subject to a huge amount of scrutiny that no other animal farm operation and no other animal sourced food product is subject to. We have to put things in perspective.

        There isn’t a fish expert on the panel right now. The members of the panel rotate, so perhaps there was a fish expert in the past and there might be in the future. However, we can expect that the other members of the panel, while they don’t work on fish themselves, will have a reasonably ability to understand the data collected by Aqua Bounty and the other references needed to complete a risk assessment. That’s the way peer review works as well. Papers are frequently reviewed by people who work in a similar but not exactly the same field as the paper’s subject. The reviewers are able to understand the paper even if they don’t work on the same thing.

        Whether transgenic salmon is a useful food or not? I am hoping you have clarifications. We can talk about whether anything is a useful food or not. We could all satisfy our nutritional needs most efficiently with some sort of paste or drink or something perfectly formulated to meet our dietary needs. This would put less stress on the environment for sure as well as eliminating diet-related diseases like obesity and eliminating nutrient deficiency. The paste could be allergen free and perfectly formulated for digestibility, reducing solid human waste. Are Big Macs useful? Are apples useful? Depends on your definition of useful.

        So, we’ve been talking abstract a lot. Just in case anyone cares, here’s a little of my personal philosophy so you can know more about the biases that drive my reasoning. I won’t eat salmon or any other animal whether it is transgenic or not simply because I prefer to eat lower on the food chain. This is more efficient and less wasteful, thus protecting natural resources far more effectively than the majority of food animal production methods ever could. But that doesn’t mean I can stick my head in the sand and forget that wild salmon populations are being reduced in size little by little every day. I think there is an intrinsic value to wild animals, wild plants, and the ecosystems they live in. I think humans, if we are to be ethical, should try to meet our needs while taking as little toll on the natural world as possible. Ideally, there would be less people so we would need to use less of the world’s resources. But that’s not happening, instead we just have more and more people every day. We could try farming ecologically and harvesting wild when possible, but when we get down to it those aren’t going to produce enough food, at least not enough of the food people want to eat. So what do we do? I say that we need to try to farm as efficiently and ecologically as possible, balancing yield and quality with damage done to the environment. Something like AquAdvantage salmon, as I described in my previous comment, will provide salmon for the lowest possible environmental harm in a cost effective way. I’d rather people just not eat salmon at all, but that’s a pretty futile wish.

      • gavin venn
        October 23, 2010

        hello again Anastasia,

        “This application is for the egg facility in Panama and the fish facility in Canada ONLY”

        thought it was egg production in Canada, & shipping to Panama, to raise & process the gmo salmon – for sale in USA?

        “It is not an application for release in whatever country they want.”

        lifecycle of wild salmon involves mobility that doesn’t respect human geographical boundaries. So with risk of contamination to natural eco systems in one Nation, we have risk to multiple Nations.

        “There isn’t a fish expert on the panel right now. The members of the panel rotate, so perhaps there was a fish expert in the past and there might be in the future.”

        thought you said the FDA, is considering GMO applications on a case by case basis? what use is a rotating panel? we need fish experts for fish applications, corn experts for corn applications etc.

        “However, we can expect that the other members of the panel, while they don’t work on fish themselves, will have a reasonably ability to understand the data collected by Aqua Bounty and the other references needed to complete a risk assessment.”

        ..again, data provided by Aqua Bounty.

        If FDA is serious about judging these applications on individual basis, i’d expect (as a matter of course) their judges would have more than a “reasonable ability” to understand the data collected.

        “These salmon have the potential benefit of providing high-quality animal protein without putting additional pressure on declining wild fish stocks.”

        is there a lack of high quality animal protein in USA? As i understand it, the USA, is the largest over-consumer of animal protein in this world. If the USA, were to cease all consumption of all fish, they would still have an over-supply of available animal protein.

        The FDA (and your) assurance that gmo salmon is fit for human consumption is based on Aqua Bounty’s data. Without
        a much deeper study, involving independent experts, as i’ve suggested, there are clearly no guarantees about safety here.

        If you’re interested in my view of useful foods in relation to high quality animal protein for USA – i’d be thinking free range, organic dairy. & i’d see amaranth as a particularly useful cereal.

      • Anastasia Bodnar
        October 23, 2010

        Yes, Gavin, I apologize – I switched the facility locations accidentally. Ironically, the locations of the facilities is very important for consideration of potential impact of ecosystems near and far.

        As I described in this post, the egg facility has environmental conditions nearby that make it inhospitable to salmon. Attempts to introduce salmon to the area have failed. If a non-sterile female egg escaped containment and somehow managed to survive to reproductive age, she would not find a mate. The fish facility has environmental conditions near by that are lethal to Atlantic salmon, plus have no salmon, plus have physical barriers to the ocean, which has lethal temperatures anyway. Sure, the containment isn’t 100% perfect. And the sterility process isn’t 100% effective. Maybe somehow by a miracle an egg or fish would escape, survive the inhospitable conditions (in the case of eggs) or lethal conditions (in the case of fish) and morph into a male and mate with another escaped fish, or something. It’s possible, I guess. Any escape that led to successful reproduction would be rare indeed. Then we have to consider what the actual harm would be if the progeny of such an unlikely union managed to find a sexually compatible wild population. Based on what we know about population genetics, not much harm at all.

        Transgenic plants are evaluated by the USDA. If they contain a protein or other biological molecule that acts as a pesticide they are also evaluated by the EPA. Transgenic animals are evaluated by the FDA – specifically the Veterinary Medicine Advisory Committee who reports to the Center for Veterinary Medicine which is part of the FDA. I know that’s sort of confusing. I wish the regulatory system was more straightforward, but the experts in various subjects are all spread out in different agencies so these systems are set up to make sure the right people are evaluating the applications.

        The people on Veterinary Medicine Advisory Committee are very carefully chosen, based on their expertise and ability to make sound decisions on the science in order to ensure safety to humans and animals of the drugs (and genes) they are considering. The lack of a fish expert is a red herring (something that seems important but really isn’t). These professionals are perfectly capable of evaluating AquAdvantage fish.

        I’ll let someone else discuss supply and demand. Briefly – people want to eat salmon. They will buy salmon, fishermen will catch salmon – even if it means the end of salmon. There could be all the free range cows you want but that’s not going to change demand for salmon.

        Are you saying that Aqua Bounty is making up data? Because that’s a pretty serious accusation. The data collection on meat and skin composition was actually done by two independent laboratories, as it said in the report you said you read. If Aqua Bounty made up the data instead of using what the independent laboratories provided, surely those independent laboratories would speak up. If you’re saying that there should be more independent testing, that’s fine, but who should pay for it? Aqua Bounty already paid for independent testing. Should the American taxpayer pay for it? That doesn’t seem right.

        I really feel like we’re talking past each other and repeating ourselves here, with no single issues being resolved. How can we make that better? This is important and I really want to understand and make a connection. Maybe if we take one issue at a time instead of having a ton of issues in the same thread? I don’t know.

  12. Andre
    October 22, 2010

    The speaker is/was Dr. Antonietta Gutiérrez Rosati, principal professor at the National Agrarian University – La Molina – UNALM, Director of the Genetic Resources, Biotechnology and Biosafety Research Center – CIRGEBB – and Technical Director of the NGO Desarrollo Medio Ambiental Sustentable – ASDMAS.

    She made a presentation on transgenic fish in Nagoya, in a conference organised by ENSSER* (http://www.ensser.org/activities/events/biosafety-conference-nagoya/). She obviously recycled her presentation (http://www.ensser.org/uploads/pics/1.4_Guitierrez.pdf) at the Greenpeace event. The presentation is a useful one on the transformation of fish and particularly on the production of triploid females. It is of little relevance as to the biosafety aspects; but the little she put on the screens provides you with an understanding of her state of mind (if speaking for Greenpeace et al. was not sufficient a pointer).

    Note that neither the abstract of her paper nor the presentation says anything about this “story” of somebody popping into her office, after having done so, almost randomly, with other professors.

    You already know Ms. Gutiérrez very well: she is the one who sued for defamation Ernesto Bustamante Donayre, who had dared to challenge her on her finding of evidence of transgenic maize crops in the valley of Barranca.

    _________________

    * ENSSER is the European Network of Scientists for Social and Environmental Responsibility. It gathers researchers and friends who claim to be “independent”.

    • Anastasia Bodnar
      October 22, 2010

      Oh! I didn’t know she was the one in that lawsuit. The old “we want independent science but we don’t want anyone to question our science” bit. Thanks for the background!

      Looking at the pdf of her ENSSER presentation provides a lot more information than what we got in the Greenpeace talk on what exactly happened with AquaBounty in Peru. According to Dr. Gutiérrez’s slides, AquaBounty approached the Peruvian government with a proposal (probably for the same facility that ended up being built in Panama). There wasn’t any backdoor under the radar deals as she implied in the Greenpeace talk. Interesting.

      She’s not really saying anything of substance, just that there should be more transparency and that risk assessment needs to conducted for each specific ecosystem where transgenic fish might be introduced. I agree with both of these things.

      One thing she’s not saying is that Atlantic salmon would not survive in Peru (or Panama) ever because it is too hot. That’s the whole reason why Aqua Bounty is using those facilities for egg production. If an egg somehow gets out it would die.

      She said Aqua Bounty was also interested in transgenic Tilapia production. This is of far greater concern than salmon because tilapia are warm water fish that might survive in Peru if they escaped. Containment would have to be even more extreme – unless there was ample evidence that the transgenic fish wouldn’t do more harm than non transgenic fish in case of escape. But I guess she didn’t want to talk details, despite all the pretty pictures.

    • Karl Haro von Mogel
      October 22, 2010

      Yes I didn’t know that she was the one who sued her critic. That is important information – it tells us that she is more concerned about her reputation than scientific accuracy. The idea that anti-GE people don’t want to speak up for fear of getting silenced/sued/defamed is ignoring that the same is happening to people who are not anti-GE (or are pro-GE) who speak up against anti-GE people. This has to stop across the board, or the very nature of scientific criticism is put in jeopardy.

      • gavin venn
        October 22, 2010

        i’d like to suggest your talking ‘about’ this person and not her perspective isn’t constructive. At the very least, you could involve her in the discussion :)

      • Anastasia Bodnar
        October 22, 2010

        Gavin, you are right. Usually, talking about the person isn’t useful – like I said before, we can judge ideas on their merits, not on the person providing the idea.

        However, there are things that we can learn about a person that will let us know if their ideas are biased or not. Are their ideas based on logic and evidence or are their ideas based on some other preconceived notions that may or may not be true?

        Here, we have someone who is calling for a moratorium on genetically engineered fish. She is a maize researcher who actually sued another scientist who dared say that her conclusions were not correct. Does her past behavior indicate anything to us? Yes. It indicates to me that she doesn’t want to have her ideas challenged, which goes against an important principle of science, that ideas have to be tested again and again so we can start to know what is really true. If she really cared about the truth, she would welcome other people to test her ideas. Does Dr. Gutiérrez care about what’s really true? Or does she just care about her reputation, as Karl said?

      • gavin venn
        October 22, 2010

        Anastasia,

        It really depends on what you’re interested in achieving from the dialogue thats being created here. Please remember that many people reading this (i hope) are not in some sort of scientists club – and that is the impression you are giving – that you’re closing ranks.

        “Yes. It indicates to me that she doesn’t want to have her ideas challenged, which goes against an important principle of science, that ideas have to be tested again and again so we can start to know what is really true.”

        the point? again this is your view. I dont know either you or the scientist from Peru and neither do most of your readers.

        If you want to talk about her – invite her into the discussion. Otherwise, just comment on her view – as you did earlier.

      • Anastasia Bodnar
        October 22, 2010

        Gavin, I appreciate your viewpoint. I certainly don’t want it to seem like a scientists’ club or that we’re closing ranks. That’s definitely not what’s happening or what I want it to seem like.

        Still, what does it look like when one scientist sues another just because of a science-based disagreement? It looks like the person suing doesn’t care about the science, doesn’t care about knowing the truth. So that person might, even subconsciously, be willing to let science slide in order to promote what she thinks is right, even when it’s not right. Motivations do matter.

        Think about how people respond when a study comes out that was funded by Monsanto or if the researcher previously worked for Bayer or whatever. The study is immediately dismissed by many people, not on the quality of science, but because of the possibility of bias. We also see some people with preconceived notions accepting research that is obviously flawed. They are blinded to the flaws because of their bias. Bias can affect the way research is done and the way that we interpret things. I wish we could all be more rational, but we’re human and emotion is expected. I provided a little bit of my own bias above so people like you :) might get some perspective into how I interpret things.

        Here, no one is suggesting that Dr. Gutiérrez’s professional opinions be thrown out just because of the lawsuit. That would be wrong. But it is useful to gain insight into what her understanding of science is which could color how she interprets things like research on transgenic fish.

      • Karl Haro von Mogel
        October 22, 2010

        Well, I was not the first person to bring up the reputation of the person we were discussing. That was you, Gavin. You brought up her credentials and experience as a point in favor of hearing her out on her arguments. Ideally, a person’s background education and experience, etc, does not tell you whether or not they are right, but it does tell you a bit about the likelihood of it. But right off the bat she misrepresented a computer modeling study on fish in her talk, dashing away hope that mere education and reputation can carry her arguments. Instead, wWe have to consider those opinions that are supported by evidence directly.

        The context in which I was talking about her suing another scientist depends upon having been part of another conversation on Grist. The issue of anti-GE scientists being unwilling to speak up for fear of personal attacks was brought up, and I countered that the extremes on both sides engage in that sort of behavior. In this comment thread I was in part expressing my surprise that we’re seeing the same person in these two instances. On one hand, suing a scientist over academic criticism, and on this hand, expecting to be taken seriously.

      • Anastasia Bodnar
        October 22, 2010

        Point of information – Karl, I may be mistaken, but I don’t think Dr. Gutiérrez brought up the fish model study. Her talk (assuming we’re all talking about the same person!) was actually really vague, I don’t think she mentioned any specific studies. I’m speaking of the person who was introduced at about 28.5 minutes into the video.

      • Karl Haro von Mogel
        October 22, 2010

        Ah, thanks for pointing that out, I thought both were the same person.

      • qetzal
        October 23, 2010

        gavin,

        You’ve noted several times that much of the data supporting the safety of these salmon comes from the company that stands to profit from them. Obviously, that introduces a risk that their data is biased. That’s a very fair point.

        But you can’t have it both ways. If it’s true that the Peruvian scientist sued another scientist simply for disagreeing, that suggests possible bias on her part as well. It’s just as fair a point for her as it is for Aqua Bounty.

      • Anastasia Bodnar
        October 23, 2010

        Yep, it’s true.

        Antonietta Ornella Gutiérrez Rosati, a biologist at the La Molina National Agricultural University in Lima, claimed to have identified a P34S promoter and NK603 and BT11 transgenes in 14 of 42 maize samples from the Barranca region. Her findings were not submitted to a peer-reviewed journal, but she did send them along to El Comercio, Peru’s leading newspaper and called for a moratorium on the introduction of biotech crops.

        Ernesto Bustamente, the vice president of the Peruvian College of Biologists, disputed her findings, arguing (translation via Wayne Parrott) in his regular newspaper column

        Notice the lack of peer review – Dr. Gutiérrez just went straight to the popular media. Later,

        scientists at the Peruvian National Institute for Agrarian Innovation have done their own study and found no biotech corn “contamination.” The Institute checked samples from 134 different fields for the presence of genes that might have come from cross-breeding with biotech varieties and found none.

        Sources: Biotech Defamation Case May Send Peruvian Biologist to Jail, Peruvian Franken-Corn Defamation Case Update, and from Nature Biotechnology Peruvian GM advocate faces criminal charges.

      • gavin venn
        October 24, 2010

        hello qetzal,

        “But you can’t have it both ways. If it’s true that the Peruvian scientist sued another scientist simply for disagreeing, that suggests possible bias on her part as well. It’s just as fair a point for her as it is for Aqua Bounty.”

        want it both ways?

        the reason i mentioned the Peruvian scientist, is because she is a scientist! And scientists seem more inclined to listen to other scientists – clearly that was a shallow assumption of mine.

        Now, in introducing her view, I was introducing what I had heard from her own mounth. It was relevant to bring that view into this conversation.

        At no point did I talk about the past history of this scientist or suggest that her science is flawed. What I did say is that if you’re going to do that, then at least invite her into the conversation to defend her position. Otherwise we have a dialogue that turns into gossip about a person not present to defend herself. That is destructive for everyone.

  13. Andre
    October 23, 2010

    Here is some background to the defamation case which also enlightens us on the situation in Peru.

    Antonietta Gutiérrez claimed to have found a P34S promoter and NK603 and BT11 transgenes in 14 of 42 maize samples from the Barranca region. She sent summaries of her findings to both the National Agricultural Research Institute and El Comercio newspaper in 2007, calling for a moratorium on transgenic crops until biosafety regulations were in place.

    Ernesto Bustamante’s main criticism was: she had made her results public before any vetting by peers; there were breaches of most elementary scientific publication standards; there were gross methodological and technical errors; there were severe personal and institutional shortcomings (ineptitudes). He also described the alleged simultaneous detection of three transgenic events from two firms, in 30 per cent of the samples, as “absurdly improbable”.

    He went very far, writing:

    “I do not know whether transgenic maize is being grown in Peru; may be, may be not. It is also possible that Space-men live in the Barranca area; may be, may be not. What is sure is that nobody has proven that there are transgenic crops in Barranca or elsewhere in Peru (except for testing fields). So far there aren’t any.”

    In his conclusion, obviously against the background of a fight between ministries, he stated that this was a clear example of why the ministry to be in charge of environment protection should be free of political influence, and depend on scientists of a free mind who can evaluate, from a strict technical view point, the environmental impact of development projects.

    Original text at http://elcomercio.pe/edicionimpresa/html/2008-01-23/ya-cultivan-transgenicos-nuestro-pais.html.

    Frankly, and that may come as a surprise to those who have followed my comments, I have sympathy for both sides. From a legal point of view (I also have quite some experience in this), I would side with Ms. Gutiérrez, the defamation case being well founded; freedom of scientific expression and critique has its limits. From a scientific point of view, I concur with Mr. Bustamante; and I understand fully his outburst of anger and, consequently, feel that she really deserved it.

    In actual fact, it is also Peru which deserved it as a necessary wake-up call to call to order the people who claim that they are not against GMOs but then place impossible conditions on their approval. I’d wish Europe would have researchers of the Bustamante caliber…

    But back to Peru. Subsequent investigations found no trace of transgenics in Barranca. The report, peer-reviewed by a panel of international scientists, should have been published in September (I have not seen anything about it).

    Yet the website of the CIRGEBB (http://www.lamolina.edu.pe/cirgebb/) still includes a pdf of Ms.Gutiérrez’ article in El Comercio (she is the director of the CIRGEBB). There is also, by way of introduction after the institutional and self-promotional stuff, a section entitled “the threats of transgenics” which says that “reports appear every day from reputed international scientists who warn with ever greater force about their impropriety. A recent report from Russian researchers proves that hamsters fed with transgenic soybean turned sterile after the third generation.”

    • Anastasia Bodnar
      October 23, 2010

      Thank you, Andre. I also feel some empathy for both sides. What Dr. Bustamante said in the paper was really socially inappropriate. But then again, what Dr. Gutiérrez did was really scientifically inappropriate. In the end, I tend to side with Dr. Bustamante, who might be brash in his speech but is at least fighting for science.

      Regarding those Russian hamsters – I still can’t find any publication about this. You wouldn’t happen to know where I might find it, would you?

      • Karl Haro von Mogel
        October 23, 2010

        Sure there’s a publication – it’s on the Huffington Post! >:)

  14. qetzal
    October 24, 2010

    gavin,

    Perhaps I’m misreading some of your comments. You made a point that the data purporting to show the safety of these salmon was provided by Aqua Bounty. I took that to be a reminder that Aqua Bounty has an economic incentive to bias the data in their favor. As I said, I think that’s a very reasonably point, but if that wasn’t what you meant, then I misunderstood and I apologize.

    I don’t know if you realize it, but the people who did those studies for Aqua Bounty are scientists, too!

    As for the Peruvian scientist, if transgenics are her field, then sure, her opinions may be worth considering. However, it’s also worth considering any evidence of bias on her part. The challenge is to avoid getting into a gossip fest, and you’re right to warn us about that.

    I’m not sure what to make of your comment about a shallow assumption. Anastasia already addressed the substance of the woman’s talk.

  15. gavin venn
    October 24, 2010

    hello again Anastasia,

    “I really feel like we’re talking past each other and repeating ourselves here, with no single issues being resolved. How can we make that better? This is important and I really want to understand and make a connection. Maybe if we take one issue at a time instead of having a ton of issues in the same thread? I don’t know.”

    Good point – thanks for raising it. We are going round in circles since we disagree on a few main points:

    1. I see a need for a more transparent and deeper risk assesment – that needs to be created by various stakeholders coming together – and carried out in a transparent way.

    2. I don’t trust Aqua Bounty’s data. Transparency and openess would help :)

    3. I can’t see that gmo salmon is proven safe for human consumption.

    4. I can’t see it proven that these gmo salmon will live out their lives as healthy and well fish.

    5. I see the risk of contamination to natural eco systems as highly important – even if that risk is predicted (on assurance of Aqua Bounty) to be small.

    6. Contamination is not a local concern – but potentially affects multiple Nations.

    And, you might not know it, but i’m not alone (on some of the points at least): this quote is taken from Common Ground

    ‘Dr. Michael Hansen, Senior Scientist at Consumers Union in the US, testified before the Veterinary Medicine Advisory Committee on September 20, saying, “The data are too superficial and of insufficient scientific quality to warrant approval.” Having examined the summary of AquaBounty’s science, he says, “The FDA is relying on woefully inadequate data. There is sloppy science, small sample sizes and questionable practices.”’

    Now back to Anastasia’s comments:

    “The data collection on meat and skin composition was actually done by two independent laboratories, as it said in the report you said you read. If Aqua Bounty made up the data instead of using what the independent laboratories provided, surely those independent laboratories would speak up.”

    surpised to hear that the gmo salmon skin did not show up different results. As you know growth hormone attaches to receptors in skin tissue, and with excessive growth hormone and IGF1, i’d expect there would be a good chance of thickening of the skin and possibly increased odour.

    Did the independent labs themselves trap and remove the specimens or was it AB?

    Also, i never found results of the tissue samples done in the FDA briefing pack.

    “Are you saying that Aqua Bounty is making up data? Because that’s a pretty serious accusation.”

    I’m saying I DONT TRUST AQUA BOUNTY.

    with what’s at stake here and the lack of transparency around the whole process, i’d say it’s a sensible approach to take.

    just a note, but you make like to rethink using phrases like “that’s a pretty serious accusation” – if you’re interested in developing an atmosphere of openess for people to talk around these issues.

    “I’ll let someone else discuss supply and demand. Briefly – people want to eat salmon. They will buy salmon, fishermen will catch salmon – even if it means the end of salmon.”

    I’m really very interested in your idea that genetically changing fish to suit our endless human desire of continuing to eat whatever we want, without any regard for biodiversity and natural ecosystems, can somehow benefit the conservation of wild salmon. I’ve looked on Aqua Bounty’s web site and they make no mention of this idea.

    Have you considered the idea that when consumers’ know that their farmed salmon includes gmo salmon, they may well switch to eating MORE wild salmon?

    Rather that genetically change the fish to suit our needs, it would be much more useful to educate people in over-consuming countries, about the importance of conserving wild fish and considering alternative protein sources. The USA already vastly over consumes animal protein. Only with this involvement and commitment from people, can we really begin to reverse human made problems that threaten the biodiversity of this planet. Providing an alternative source of supply only encourages people to consume, and offers no real long term solution.

    If you’d like to develop this particualar side of the conversation – to put the merits of gmo forward, i’d appreciate being able to do it on my own web site, where it would fit in well with some other themes.

    Possibly, i’ve taken this risk assesment, text based conversation as far as i can. My peasant farmer knowledge is limited, and i dont want to stop more knowledgeable people getting involved here. Also, i don’t think text based dialogue is any replacement for meeting and developing dialogue in person. That said, I think this dialogue has been useful, if only to show that different people place different emphasis on different areas, and individual views are influenced by many things. Thank you for your work.

    best wishes, gavin

    • Ewan R
      October 25, 2010

      1. I see a need for a more transparent and deeper risk assesment – that needs to be created by various stakeholders coming together – and carried out in a transparent way.

      How deep of a risk assessment would you require? I’d agree that transparency is a good thing, but IP lawyers probably tend not to agree (they’re a suspicious bunch and always want to hold on to as much as they possibly can – there is always suspicion amongst IP lawyers that there’s a data point in your experiment, somewhere, that may be patentable, somehow (therein lies the biggest downside of working in corporate research – you can pretty much only publish once things are on a commercial track, and you can only present a veneer of what you actually do for fear of falling foul of your own IP lawyers – none of this is really a great excuse, but is an explanation (seriously – we (as in corporate researchers) don’t hide data to make stuff look safer, or better – any data that isn’t released isn’t released because it might be patentable later, at least in my experience – you release enough data to satisfy the regulatory bodies and that is about that)

      2. I don’t trust Aqua Bounty’s data. Transparency and openess would help

      Therein lies the issue a lot of people will have with any corporate science – the IP/transparency dichotomy tied up with distrust of the profit motive – I always see the profit motive as a big driver for good data (shareholders will not be happy if you make up data and your product flops or ends up being dangerous costing them hundreds of millions)

      3. I can’t see that gmo salmon is proven safe for human consumption.

      How much proof do you require? I personally can’t see that the techniques used would pose any great risk – and the numbers on growth hormone levels provided above certainly don’t appear to be cause for any concern

      5. I see the risk of contamination to natural eco systems as highly important – even if that risk is predicted (on assurance of Aqua Bounty) to be small.

      It’s an important concern, however given the multiple levels of containment provided I think it’s been addressed pretty well (personally I don’t see that having a GMO salmon escape to the wild would be risky to natural populations even if all individuals were sexually viable – the life history of salmon combined with what would clearly be a disadvantageous alteration in terms of fitness are enough in my mind)

      6. Contamination is not a local concern – but potentially affects multiple Nations.

      It also potentially affects nobody at all – I’m pretty much on that side of the fence here, you have the massive unliklihood of escape in the first place, combined with the spectacularly low chance that any escapees are reproductively viable, combined with the low chance of actually being able to breed should the first two hurdles be leapt – and on top of that there is good reason to assume that the progeny of any succesful matings would be so unfit as to be major evolutionary losers (unlikely they’d make it to the next generation)

      surpised to hear that the gmo salmon skin did not show up different results. As you know growth hormone attaches to receptors in skin tissue, and with excessive growth hormone and IGF1, i’d expect there would be a good chance of thickening of the skin and possibly increased odour.

      Depends how one defines excessive – from the text above the growth hormone differences were actually undetectable, and IGF1 was only increased

      The growth hormone content in AquAdvantage salmon and non-genetically engineered control salmon were both below the lower limit of quantitation (10.40 ng/g of tissue), while amounts of estradiol, testosterone, 17- ketotestosterone, T3, and T4 were not significantly different in the two groups. The only statistically different concentration was for insulin-like growth factor 1 (IGF-1), with a mean of 7.34 ng/g in the control group and 10.26 ng/g in the test group (11).

      so an increase of ~3ng/g – which really isnt that much if you consider things (unless you seriously believe you incur a risk eating 140g of salmon at a signle sitting as compared to eating 100g of salmon at a single sitting)

      I’m really very interested in your idea that genetically changing fish to suit our endless human desire of continuing to eat whatever we want, without any regard for biodiversity and natural ecosystems, can somehow benefit the conservation of wild salmon.

      I assume the hope here is that more abundant, cheaper, farmed salmon makes wild caught salmon less appealing to consumers and therefore reduces the demand which causes less fishing – bit of a stretch here to be fair – the flavor differences between wild and farmed salmon probably play a far bigger role (when’s someone gonna GM a salmon that tastes like it’s roamed free and avoided bears (which is where all the flavor comes from! (obviously))) in supply and demand – plus the general disdain for anything that is farmed cf the wild version thereof.

      Rather that genetically change the fish to suit our needs, it would be much more useful to educate people in over-consuming countries, about the importance of conserving wild fish and considering alternative protein sources. The USA already vastly over consumes animal protein. Only with this involvement and commitment from people, can we really begin to reverse human made problems that threaten the biodiversity of this planet. Providing an alternative source of supply only encourages people to consume, and offers no real long term solution.

      If only wishes were fishes – pushing for a reduction in consumption of meat (of all types) is a noble cause but not one I see getting anywhere soon (hopefully in a generation or two, but with the rate at which China and India increase their meat consumption I fear any gains in the West will be swamped (not that we shouldn’t try anyway)) – as such developing methods to produce more with less in parallel with attempting to decrease overall consumption is in my opinion a more realistic route forward (I think of it somewhat akin to gas useage and cars – with more fuel efficient vehicles taking the role of GMOs here – sure the world would be better off if everyone just stopped bloody driving everywhere, but realistically that isn’t going to happen in the short term so making it less impactful is a better route forward than just using everything up and forcing everyone’s hand)

      • Anastasia Bodnar
        October 25, 2010

        Thank you Ewan. This is almost exactly the response I would have given on these subjects.

      • gavin venn
        October 26, 2010

        hello Ewan,

        “How deep of a risk assessment would you require?”

        ive already given some hints as to what i see as useful – Anastasia asked this same question earlier.

        “(seriously – we (as in corporate researchers) don’t hide data to make stuff look safer, or better – any data that isn’t released isn’t released because it might be patentable later, at least in my experience – you release enough data to satisfy the regulatory bodies and that is about that)”

        you’re suggesting the public just accept lack of openness & transparency because that’s how corporate IP lawyers see the world? My view would be that corporates’ are hanging themselves if that is their stance – public trust will not come without transparency. Further, we are entering a time when transparency will become the accepted norm – corporates can choose to embrace that or not.

        “I always see the profit motive as a big driver for good data (shareholders will not be happy if you make up data and your product flops or ends up being dangerous costing them hundreds of millions)”

        share holders, like corporates are in this for profit. if corporates are prepared to stand by their technology and how that effects others, then they have nothing to fear from transparency.

        “Depends how one defines excessive – from the text above the growth hormone differences were actually undetectable, and IGF1 was only increased”

        a fish that grows twice as fast as normal, and if left to grow will achieve up to three times the size of it’s non gmo farmed counterpart – and all that’s been noted (in terms of GH) are slightly higher IGF1 levels? This is why i’m interested in the results on skin and tissue samples – all these organs must be affected.

        Amplifying one hormone without considering it’s interdependence with other hormones and process within the fish, must have a high chance of resulting in an imbalance based on what that GH affects. In other words, you’re tuning the engine, with no consideration of the chassis of the vehicle. And yes, i’ve seen the results of the tests provided.

        “It also potentially affects nobody at all”

        Risk affects people. Invasive species affect natural eco systems & people, across Nations.

        If you’re talking about how likely it is that risk will be realised, in terms of escapes happening: the likely risk is mainly based on assurances from Aqua Bounty.

        It’s interesting these gmo salmon will be raised in Panama -i take it the authorities’ in Panama, have their own risk assesment?

        And, i havn’t seen the risk assesment for the transfer of eggs from Canada to Panama.

        These things bring me back to the need for international protocol.

        “developing methods to produce more with less in parallel with attempting to decrease overall consumption is in my opinion a more realistic route forward (I think of it somewhat akin to gas useage and cars – with more fuel efficient vehicles taking the role of GMOs here – sure the world would be better off if everyone just stopped bloody driving everywhere, but realistically that isn’t going to happen in the short term so making it less impactful is a better route forward than just using everything up and forcing everyone’s hand)”

        the problem with that approach is that people never have to take responsibility.

        we put off facing the reality of our situation for as long as possible – we acknowledge the causes of our problems, but because they’re not stopping us doing things, we don’t really get involved with them. sure we may feel a little better as we’re driving a more efficient car, but as you say – we still drive just as much. nothing tangible is being done to deal with the problem at the level of the individual.

        Unless we people make a sincere connection now with these issues, and act on them, the problems are just shunted to the next generation, for our children to deal with – it’s those people that will have to live with our ignorance.

      • Anastasia Bodnar
        October 26, 2010

        I think a big difference between your way of thinking, Gavin, and that of myself and Ewan is that we’re willing to consider solutions that involve technology while we’re getting to that long term social change – whether that technology is high efficiency engines while we’re moving towards less of a car-oriented society or fast growing salmon while we’re waiting for people to start eating a more sustainable diet that includes less animal protein. The end goals are the same, but we think we can get there in different ways. I’m not willing to wait because I don’t even know if people will ever change. I wish I could be optimistic and think that we’ll get to a culture that consumes less, is less selfish, and is more conscious of the world around them without basically forcing a behind the scenes decrease in environmental impact by using technology, but I am not.

      • gavin venn
        October 26, 2010

        hello Anastasia,

        its interesting to hear you know about my way of thinking – perhaps you can teach me about it sometime.

        “or fast growing salmon while we’re waiting for people to start eating a more sustainable diet that includes less animal protein. The end goals are the same, but we think we can get there in different ways. I’m not willing to wait because I don’t even know if people will ever change.”

        there is a big difference here. i see many people as willing to take responsibility if they have a strong enough connection or involvement with the challenge. a big problem is lack of connection between people & food systems & their connection with biodiversity. by closing that gap, people will naturally become more involved.

        the present application of gmo in farming, widens that gap. & i’m not sure why you would think people would be more willing to face problems in the future rather than right now.

        i’m not against technology at all, but the problem i have with gmo technology in farming, is it’s current application: the only winners are corporations.

      • Ewan R
        October 26, 2010

        the present application of gmo in farming, widens that gap.

        Would you care to elaborate on this? I don’t see how using GMOs in any way removes more people from agriculture than not.

        but the problem i have with gmo technology in farming, is it’s current application: the only winners are corporations.

        Really? I’ll see your corporations and raise you all the cotton farmers in India who’ve adopted Bt and seen yields and incomes rise by 50-150%, I’ll also throw a few hundred chinese insecticide applicators who haven’t died because the presence of Bt meant that they didn’t have to use as much insecticide and thus avoided getting poisoned.

        Hell, I’ll go almost all in (I may remember a few more after the next cards are revealed) and add in the thousands of US farmers who benefit from Bt and RR technology.

      • Ewan R
        October 26, 2010

        you’re suggesting the public just accept lack of openness & transparency because that’s how corporate IP lawyers see the world? My view would be that corporates’ are hanging themselves if that is their stance – public trust will not come without transparency. Further, we are entering a time when transparency will become the accepted norm – corporates can choose to embrace that or not.

        As I stated “none of this is really a great excuse, but is an explanation” – I don’t see it changing really – corporate science can get the trust of the regulatory bodies, and shares the data with them to gain that trust – imo the issue here is more trust of the regulators than trust of the corporations (as they provide the perfect go-between in terms of maintaining corporate secrecy and public trust) – nobody is ever going to trust corporations, and no corporation is going to disclose information that is potentially patentable or would put them at a competitive disadvantage – if on the balance of things there was an advantage to be had then the data would be released (clearly corporations do not believe that releasing the data will actually change anything, and I tend to agree – either it’ll be subject to poor analysis a la Seralini et al, or will be roundly ignored (in the same manner that all the non-corporate safety research on GMOs is))

        share holders, like corporates are in this for profit. if corporates are prepared to stand by their technology and how that effects others, then they have nothing to fear from transparency.

        I’m not convinced shareholders will be happy if you release data which subsequently invalidates a patent application on a product which would have netted $5Bn over 5 years. The profit motive is however one thing that I think keeps corporate research honest – you bugger up academic science you might get a paper rejected or have some irate letters responding to something which slips through peer review – you fudge your numbers with corporate research then the buck stops at you when people wonder why you spent $100M attempting to commercialize something which won’t make any money at best, or which costs the company hundreds of millions in fines at a later date – particularly important in today’s climate (as compared to 30 years ago)

        a fish that grows twice as fast as normal, and if left to grow will achieve up to three times the size of it’s non gmo farmed counterpart – and all that’s been noted (in terms of GH) are slightly higher IGF1 levels?

        That’s what the research points to – I honestly don’t find this hugely surprising (partially because a fish that is 3 times the size can have 3 times the absolute quantity of hormone while having exactly the same hormone level) – also given the power of hormones etc you don’t need a huge change in levels to have large effects on some parameters (size, growth rate) while not effecting others (everything else)

        Amplifying one hormone without considering it’s interdependence with other hormones and process within the fish, must have a high chance of resulting in an imbalance based on what that GH affects.

        I’ll call out the whole ‘without considering its interdependence with other….’ as a strawman – I seriously doubt that the scientists involved just thought – hey guys – lets alter this, while not taking into consideration anything else! Also *must* have a high chance of resulting in an imbalance? Why must? may have a chance for sure – I’d guess more than one transformation was done, I’d guess different transcription levels gave wildly varying results and that the event finally selected for utilization was that which yielded positive results in terms of growth while minimizing/eliminating any negative phenotype – this is part and parcel of developing transgenics for commercial use – it doesn’t matter if 5% or 99% of events generated have horrible offtypes – so long as you end up backing the one that doesn’t then the final results will apparently surprise and shock the uninitiated (although if 99% of events generated have a horrid offtype it’s pretty unlikely you’ll ever see success in early development – which is one of the sucky things about transgenics, I often wonder how many awesome genes haven’t been advanced because they require a high degree of fine tuning which either wasn’t possible at the time of testing, or is too economically risky to do so)

        Risk affects people.

        Only if the risk is realized. Given that I see the risk of an escape as miniscule, and the actual effects should an escape occur as being utterly unimportant, I’m of the opinion here that
        a) Nobody will be affected because it is highly unlikely any escape will occur and
        b) Even should an escape occur there really isn’t a significant risk of impact anyway

        Invasive species affect natural eco systems & people, across Nations.

        This presupposes that any escaped salmon would become an invasive species, which I think is a rather bold claim unsupported by the facts of the matter – these fish would categorically be less fit than wild fish, they’re grown in areas where interactions with wild populations are practically nil, they’re sterile and so any interactions would be meaningless, and the natural history of salmon suggests, to me at least (and on Salmon my knowledge is essentially that of the layman – so any salmon experts can chime in and call me out if this is spurious), that it’s unlikely an escaped salmon would get to the spawning grounds of wild salmon (based on the assumption that salmon return to whence they came to spawn – which is at least what David Attenborough taught me growing up)

        the problem with that approach is that people never have to take responsibility.

        I work on the assumption that at least in the short term people won’t take responsibility anyway, so we’re left with the quandry of either doing nothing and watching everything go to hell quickly, or doing something and putting the brakes on somewhat in the hope that change will still be forthcoming at essentially the same pace as it would have had you done nothing – your approach would seem to be to just let everything collapse sooner rather than later so as to teach a lesson.

        we still drive just as much. nothing tangible is being done to deal with the problem at the level of the individual.

        I put it to you that having everyone drive more efficiently (even if the same amount) makes a tangible difference, and is more impactful than not changing efficiency while haranguing people to drive less (but not having them do so) – and that the best workable solution is to increase efficiency while at the same time pushing for reductions in useage, that way you ameliorate the effects in the short term with increases in efficacy and magnify this impact in the mid to long term with a combination of efficacy and reduced use.

        Unless we people make a sincere connection now with these issues, and act on them, the problems are just shunted to the next generation, for our children to deal with – it’s those people that will have to live with our ignorance.

        Oddly enough this isn’t a bad summing up of my opinion on the utilization of GMOs wherever they can make an impact. Generations to come will have to live with the aftermath of our ignorance, and ignorance around GMOs is an area where there is huge scope for impact (I’d like to see every death and injury from insecticide application on eggplant (or to be a little more charitable those linked to insecticides which would have been eliminated) in India layed at the feet of Greenpeace, Seralini and Shiva for instance – peddlers of ignorance which will have direct negative effects on people within the next decade – although this is going off at a tangent now)

      • gavin venn
        October 26, 2010

        hello Ewan

        “imo the issue here is more trust of the regulators than trust of the corporations (as they provide the perfect go-between in terms of maintaining corporate secrecy and public trust) – nobody is ever going to trust corporations”

        the regulators’ are dependent on the source of the information – the corporations. perhaps this is why many people don’t trust the regulators’ either.

        “The profit motive is however one thing that I think keeps corporate research honest”

        i’d tent to disagree wholeheartedly. massive profit provides the incentive for the opposite. where is the reputation / track record to say gmo corporations are honest?

        “That’s what the research points to – I honestly don’t find this hugely surprising (partially because a fish that is 3 times the size can have 3 times the absolute quantity of hormone while having exactly the same hormone level)”

        i do. the fish may be 3 times as big, but its evolution over millions of years has led to it being it’s original size. the GH amplification is working only on certain aspects of the fish.

        “this is part and parcel of developing transgenics for commercial use – it doesn’t matter if 5% or 99% of events generated have horrible offtypes – so long as you end up backing the one that doesn’t then the final results will apparently surprise and shock the uninitiated”

        agree – the company will have gone with the fish results that work best: but that doesn’t mean they are safe for human consumption or that fish experience health & wellness.

        “I work on the assumption that at least in the short term people won’t take responsibility anyway, so we’re left with the quandry of either doing nothing and watching everything go to hell quickly, or doing something and putting the brakes on somewhat in the hope that change will still be forthcoming at essentially the same pace as it would have had you done nothing”

        why will people be more likely to change their behaviour in the future instead of right now? Facing the challenge is the challenge – putting it off just makes it more difficult.

        “Generations to come will have to live with the aftermath of our ignorance, and ignorance around GMOs is an area where there is huge scope for impact”

        i’ll come back to respond to that -thanks, gavin.

      • Ewan R
        October 26, 2010

        i’d tent to disagree wholeheartedly. massive profit provides the incentive for the opposite. where is the reputation / track record to say gmo corporations are honest?

        10 years of GM food being out there without any indication whatsoever of health risks (and the general scientific consensus being that all commercialized GM foods are safe)
        10+ years of improved varieties coming out of corporate breeding ventures (not GMO per se, but they come from the same companies) – lets look at what the repercussions would be if the data coming out was dishonest:-

        If RR or Bt actually had health effects that would essentially be it for Monsanto in today’s climate – you wouldn’t see a slap on the wrist, or even just a heavy fine (as has been the case with previous instances where they’ve fallen foul of safety) – Pfizer was almost bankrupted in the past 2 years because they pushed a drug for a non-proven useage (and I’ve witnessed the aftermath of this personally – 100’s of people from the building next to mine are out of work now, and the entire campus has been bought up by Monsanto essentially because Pfizer needed to come up with billions of dollars) the backlash for actual harm caused by GMOs would, I assume, be orders of magnitude worse – shareholders aren’t overly happy if you take them down a road which may utterly negate the value of their shares.
        On a less catacysmic front – if Monsanto lies about yield performance of a GM variety (or even a new elite germplasm) they’ll lose millions in subsequent years in lost trust from their customers – nothing forces farmers to purchase Dekalb seeds – they buy em because they perform, likewise nobody is going to purchase a +10% yield gene which never performs, and they’ll likely pay more for a gene which increases yield in 80% of cases rather than 60% of cases – and if you lie to them about which is correct then next year they’ll likely not buy the gene AND not buy your genetics.

        do. the fish may be 3 times as big, but its evolution over millions of years has led to it being it’s original size. the GH amplification is working only on certain aspects of the fish.

        I’m not sure I fully understand what you’re getting at here – the evolution leading to size has nothing to do with how slight variations in GH levels will effect the physiology of the fish (indeed given that GH levels vary within and between populations the evolutionary arguement could lead one to assume that there are internal mechanisms at work to maintain physiology unrelated to growth with varying levels of GH)

        agree – the company will have gone with the fish results that work best: but that doesn’t mean they are safe for human consumption or that fish experience health & wellness.

        Well no, the safety studies done mean they are safe for human consumption – the selection for the best working events is part of getting to this conclusion however, and is an explanation as to why only those traits you wanted to change are what get changed.

        why will people be more likely to change their behaviour in the future instead of right now? Facing the challenge is the challenge – putting it off just makes it more difficult.

        It isn’t a case of either or. Change takes time. It isn’t a binary situation, you don’t either have change, or not have change – modification of behaviour at the level of society (or indeed multiple societies) will, imo, take generations (if it is achieved at all) – I’m not arguing for putting anything off (other than putting off when people start starving to death, or when natural populations collapse due to overfishing) I’m jsut being realistic in acknowledging that the changes required aren’t going to happen overnight and it is therefore, in my opinion, better to ameliorate the damage done while society transitions to a model of reduced consumption rather than to allow the status quo to continue and have society forced to adapt on the fly due to earlier resource depletion.

      • gavin venn
        October 26, 2010

        hello Ewan

        “10 years of GM food being out there without any indication whatsoever of health risks (and the general scientific consensus being that all commercialized GM foods are safe)”

        10 years? 10 years is a blink of an eye!! how long have plants like corn or soy taken to evolve – thousands, perhaps millions of years. the products you’ve created are new foods – we have no idea of the long term conditions they will create for humans & farm animals or (through contamination with natural eco systems) biodiversity.

        “On a less catacysmic front – if Monsanto lies about yield performance of a GM variety”

        i dont want to get into a gossip fest about monsanto, suffice to say, look at their present share performance.

        “I’m not sure I fully understand what you’re getting at here – the evolution leading to size has nothing to do with how slight variations in GH levels will effect the physiology of the fish”

        fine, you’re the scientist – i’m not. i just dont see how a fish that has evolved over millions of years in balance, can have one of its hormones manipulated – and everything is fine – except we have giant fish – Da da – like magic!!

        “Well no, the safety studies done mean they are safe for human consumption”

        yep thats right – those safety studies done using AB’s data. we’re back to circles & no trust.

        “It isn’t a case of either or. Change takes time.”

        yes it does, so unless we face up to the cause of those problems and start that change NOW, nothing tangible will happen – our children get a lovely heritage.

      • Ewan R
        October 26, 2010

        Meh apparently we’ve reached the limit of reply chain – so now this gets all broken up, awesome!

        Anyway to respond:-

        10 years? 10 years is a blink of an eye!! how long have plants like corn or soy taken to evolve – thousands, perhaps millions of years.

        So I’m tasked with demonstrating corporate trustworthiness over the course of millions of years? I’m generally up for a challenge but think I’ll give that one a miss thanks all the same.

        On an unrelated side note – plants like corn or soy have taken jsut as long as everything else on the planet to evolve, approximately 3.5 billion years, not that his has diddly squat to do with safety or anything, jsut a peeve of mine regarding evolutionary time lines (things change if you give a ‘how long did it take them to evolve from X’ qualifier)

        the products you’ve created are new foods

        No, they’re very slight variations of common foods, unless you’re of the opinion that every new variety of corn, soy, tomato or whatever your preferred food is a new food.

        i dont want to get into a gossip fest about monsanto, suffice to say, look at their present share performance.

        Suffice to say what exactly? A decline in share price which coincided with a reduction in sales of glyphosate due to massive chinese overproduction combined with the worst global recession since the great depression? What exactly is your point here? Or did you mean look at their share performance over a longer period of time, say from the spinning off of the company as a purely agricultural business – which still shows a 5 fold increase in share price from initial release.
        I assume by “dont want to get in a gossip fest” you meant “want to make a snide comment which has nothing to do with the debate at hand hoping that nobody is remotely aware of the monsanto share price or why it is doing what it is doing” – as my retirement fund is tied to monsanto stock (by choice – and as such I’d ratehr it were a lot lower for the next 30 years or so followed by a sudden upspike at which point I’ll convert entirely to government bonds and go live in the bahamas – I’m well aware of its movements and the reasons for them.

        i just dont see how a fish that has evolved over millions of years in balance

        What does this even mean? If you’re in balance you’re not evolving by any meaningful definition of evolving.

        …can have one of its hormones manipulated – and everything is fine – except we have giant fish – Da da – like magic!!

        Whether or not you find it unlikely doesn’t change the experimental results, which by the way do not suggest that nothing else has changed other than growth rates – fish eat more, eat larger prey, discriminate less with prey, tolerate a tighter range of temperatures and pHs – the changes just don’t do anything harmful (one could argue the changes that are there are rather serindipidous in that they make spread of the GM salmon less likely)

        yep thats right – those safety studies done using AB’s data. we’re back to circles & no trust.

        I guess here we’re stuck, as such I’ll drop this for now. (until I forgot that I said I would, at which point reference me back here and I’ll weasel out somehow)

        yes it does, so unless we face up to the cause of those problems and start that change NOW, nothing tangible will happen – our children get a lovely heritage.

        I agree, with the caveat that due to the nature of the problems we need to ameliorate them during the change.

      • gavin venn
        October 26, 2010

        hello Ewan,

        “Oddly enough this isn’t a bad summing up of my opinion on the utilization of GMOs wherever they can make an impact. Generations to come will have to live with the aftermath of our ignorance, and ignorance around GMOs is an area where there is huge scope for impact (I’d like to see every death and injury from insecticide application on eggplant (or to be a little more charitable those linked to insecticides which would have been eliminated) in India layed at the feet of Greenpeace, Seralini and Shiva for instance – peddlers of ignorance which will have direct negative effects on people within the next decade – although this is going off at a tangent now)”

        pls can you point me to best concise info showing stats on how gmo reduces use of chemicals?

      • Ewan R
        October 27, 2010

        Reduced pesticide use in GMOs

        Reduced insecticide use in China on Bt cotton

        12kg/Ha cf 60kg/Ha – The article also makes claims of improved farmer health although imo the data here isn’t great as it relies on a simple survey rather than any actual measurement.

        Paper discussing alleged increases in farmer suicides in India

        Table 10-12 have pesticide use data – ~40% reduction in pesticide useage.

        Bt cotton in Argentina 60% reduction in insecticide use

        Bt Brinjal 52% reduction in pesticide use estimated

        There are probably better studies and more data out there, but this should make for a decent start (hard to find anything on brinjal in the time I have that wasn’t behind a paywall even with the decent access I have – the linked abstract at least has some numbers to it however)

      • gavin venn
        October 28, 2010

        hello Ewan

        thanks – will take a look at this info.

        would also be helpful if you can point me to what you see as meaningful references to show relationship between gmo use and weed killer use

  16. qetzal
    October 24, 2010

    Hi gavin

    I’m curious about something. How much of your objection to these salmon is because they’re GMO, as opposed to because of their specific traits?

    What if, instead of being GMOs, these salmon were somehow generated by crossing atlantic and chinook salmon. Suppose they have the same growth properties as the actual GMOs. In your opinion, should these hypothetical non-GMO salmon have to go through just as much investigation, review, and effort to prevent their escape? Why or why not?

    By the way, I agree with you that risk assessment should be transparent. Personally, I think the claim that data needs to be withheld to protect company IP is bogus. And FWIW, I work in the biotech industry, so it’s not as if I don’t understand the importance of IP.

    • gavin venn
      October 26, 2010

      Hi qetzal

      “I’m curious about something. How much of your objection to these salmon is because they’re GMO, as opposed to because of their specific traits?”

      the two go together, don’t they?

      “What if, instead of being GMOs, these salmon were somehow generated by crossing atlantic and chinook salmon. Suppose they have the same growth properties as the actual GMOs. In your opinion, should these hypothetical non-GMO salmon have to go through just as much investigation, review, and effort to prevent their escape? Why or why not?”

      as you know, these gmo farmed atlantic salmon have a hormone from chinook salmon and also ‘events’ from Ocean Pout – so there are three creatures involved here – very clearly GMO.

      possibly, you’re interested in my view on how gmo differs from traditional breeding? if so, there is a lengthy conversation on my web site between a enthusiastic biotec person and myself – i learned a lot from this. but please note, the conversation is based on plants and is limited by my own shallow perspective.

      “By the way, I agree with you that risk assessment should be transparent. Personally, I think the claim that data needs to be withheld to protect company IP is bogus. And FWIW, I work in the biotech industry, so it’s not as if I don’t understand the importance of IP.”

      that’s one thing that seems to be clear here – most people, including the gmo scientists’ themselves agree the need for transparency.

      thanks, gavin

      • qetzal
        October 26, 2010

        Hi gavin,

        The point I’m trying to make is that the introduced traits and the process used to introduce them are two separate things.

        You’re arguing for a very high level of regulatory oversight for these GMO salmon. Not just at a national level, but even to the point of wanting international protocols (enforced by treaties?) before they could be released. I’d like to understand why you think that’s warranted for these salmon. Is it simply because of the traits they carry and the potential consequences they might have? Or do you consider the fact that they are GMO a substantial risk in itself, independent of whatever traits they carry?

        Put another way, would you expect the same level of regulatory oversight, including internationally agreed protocols (enforced by treaties?), for a cross-specied hybrid salmon that exhibited all of these same traits?

        I looked for the conversation on your website, to see if you’d already answered similar questions there, but I couldn’t find it. Can you give link, or at least the title of the page I should look for?

        My personal opinion is that GMOs are not inherently dangerous simply because they are GMOs. However, GM tech does let us combine genetic traits that we couldn’t combine by breeding. Thus, IMO, we need to focus on what was done, not how it was done. In this case, GM tech was used to create a very specific modification. One that could also happen naturally or through conventional breeding. The difference is that GM allowed this specific modification with little or no other change. If anything, that makes it safer than conventional breeding for this specific trait, because there is much less risk of some other deleterious change that we don’t know about.

      • gavin venn
        October 26, 2010

        hi qetzal

        link

      • qetzal
        October 26, 2010

        Thanks for the link, gavin. That discussion was relevant and interesting, but doesn’t really address my key question.

        I hope I’m not mischaracterizing here, but you seem to think that anything gmo is automatically in a different category of risk. For instance, in one of your replies to Ewan, you state:

        agree – the company will have gone with the fish results that work best: but that doesn’t mean they are safe for human consumption or that fish experience health & wellness.

        The exact same thing could be said about every man-made hybrid variety of every crop and food animal ever grown. Which, as you probably know, covers a huge amount of what most Westerners eat.

        Why do we need international protocols to govern atlantic salmon that contain a single chinook salmon gene, but not to govern plumcots (plum/apricot cross)? Do we not need to make sure that plumcots are safe, or that they won’t contaminate wild members of the same family?

      • gavin venn
        October 28, 2010

        hi qetzal

        Sorry to take a while to get back to you. Probably you can get a reasonable idea of my view from the other conversations here.

        I would like to point out that my view is only that – just one person’s view – i don’t represent anyone else – and as such, my view carries no more importance than any other person’s view.

        “I hope I’m not mischaracterizing here, but you seem to think that anything gmo is automatically in a different category of risk.”

        I’m concerned with how this new gmo technology is being implemented and the effects on people and wider others. I’m not against the technology itself.

        “The exact same thing could be said about every man-made hybrid variety of every crop and food animal ever grown. Which, as you probably know, covers a huge amount of what most Westerners eat.”

        I don’t quite see it like that. This gmo atlantic salmon takes a gene from a chinook salmon and events from ocean pout – three creatures. The gmo mechanism to do this is new.

        New doesn’t mean negative – but as I said, I’m concerned about the effects on people and wider others: these things are not imo, understood.

      • qetzal
        October 28, 2010

        Hi gavin,

        Thanks for the reply. I don’t want you to be ganged up on here, so I’ll just make a couple of final comments for your consideration.

        The gmo salmon actually involves the GH gene from chinook salmon, plus regulatory DNA sequences from ocean pout. The chinook part encodes the actual GH hormone. The pout part is what make the GH gene be “on” at relatively higher levels all the time.

        The important point I’d like you to consider is this. We understand what’s going on with these GMO salmon much, MUCH more than we understand what happens when you create a cross-species hybrid, or when you create new varieties using radiation or chemical mutagenesis. In the former case, we know exactly what gene was modified, exactly how it was modified, and exactly where it is in the salmon genome. We know a great deal about what the GH hormone does. We also know at least some of the unexpected/undesired things that could have happened at the genetic level, and we can test for those things. (E.g. we can test to see if insertion of the extra DNA significantly altered the expression of any nearby genes.)

        In comparison, cross-species hybridization and mutagenesis have enormously more complex effects on the resulting organisms. Dramatic DNA rearrangements, changes in gene & chromosome number, mutations everywhere, variations in expression for hundreds of genes, etc. In those cases, our understanding is very close to nil.

        So if you’re really concerned about our level of understanding and the possibility of unanticipated risks from unrecognized changes, you should be MUCH more concerned about these “traditional” techniques than you are about GMO. Conversely, if you’re comfortable that traditional techniques are suffiently safe, there’s no intrinisic reason to fear GMOs per se.

        Once again, I’m not arguing that anything GMO is safe, by any means. I agree that the modification itself can be a reason for concern. E.g. one could probably use GMO to introduce peanut proteins into salmon, which would be bad for people with peanut allergies. But it’s bad because of what was introduced, not because of how it was introduced.

        Hope you find that worthwhile food for thought. I’ll back off now and let you continue your other discussions.

  17. gavin venn
    October 26, 2010

    hello Ewan,

    the point of talking about the evolution of the plants before they were gm’ed is that this is what nature created over, as you say billions of yrs. i trust nature – i dont trust your gm’ed version of nature – which is a new version of these plants.

    “No, they’re very slight variations of common foods, unless you’re of the opinion that every new variety of corn, soy, tomato or whatever your preferred food is a new food.”

    no, they’re new foods. unless you count the very rare horizontal gene transfer between sea slug & bacteria or similar, the changes happening with gmo don’t happen in nature.

    “What does this even mean? If you’re in balance you’re not evolving by any meaningful definition of evolving.”

    healthy balance: for example if you’re cold, you’ll reach for a sweater or turn on your heating system – youre still changing, but there is some balance happening.

    “Suffice to say what exactly? A decline in share price which coincided with a reduction in sales of glyphosate due to massive chinese overproduction combined with the worst global recession since the great depression?”

    nothing to do with failed yield gains with smartstax then? or perhaps RR tolerant weeds?

    • gavin venn
      October 26, 2010

      Ewan .. re mon shares, i raised point because i see it relevant to trust in the company – but i have to say, i know very little about shares. this doc does seem to be relevant though.

      ive no further interest in talking about monsanto.

      • Ewan R
        October 26, 2010

        ive no further interest in talking about monsanto.

        If this was the case why bring new information to the table? If you weren’t interested you wouldn’t have said anything, apparently you want a bye to state whatever you want without any comeback. Not happening.

        The grist piece is obviously pretty one sided (sorry but any article which describes herbicide useage using the loaded phrase “douse” is obviously far from impartial, or indeed accurate) and the smartstax data under discussion is the very early data – it’d be akin to calling an election based on the first 2 poll stations to report in.

        this statement for instance

        2) its target audience — large-scale commodity farmers in the south and Midwest — are turning against its core offerings in genetically modified corn, soy, and cotton seed traits.

        is patently untrue – Monsanto market share in seeds and traits remained pretty constant in the US last year – so there is no turning against – and the release of smartstax, while not where predicted, was still the most succesful trait release in the history of GMOs in terms of acreage.

      • gavin venn
        October 26, 2010

        “If this was the case why bring new information to the table? If you weren’t interested you wouldn’t have said anything, apparently you want a bye to state whatever you want without any comeback. Not happening.”

        fair point.

        to bring us back to salmon, & why i mentioned shares – talking about public trust in gmo:

        i live in Europe, there is a petition here with over 1 million people calling for an outright ban of gmo – so that would show lack of trust in gmo corporations.

        Germany: gmo corn banned.

        India: public forced moratorium on Bt brinjal.

        there are many many examples.

      • Ewan R
        October 26, 2010

        I’d agree with you that there is a lack of trust – I think in the case of GMOs this inherent lack of trust in corporations is spun to paint GMOs in a bad light – and I’d also highlight that lack of trust, while the reason for the bans isn’t sufficient reason to ban anything – there should, imo, be sound scientific reason for doing so (I don’t trust organized religion for instance, and millions of other think the same – I’d be 950 thousandth in line to oppose measures to ban organized religion should this come up)

        I’d say that each of your examples show just how a campaign of misinformation combined with misunderstanding and a mistrust of corporations (one out of 3 is excusable imo, I’ll let you guess which) combine to keep a valuable technology out of the hands of farmers. (I’ll provide reduced useage data tomorrow once I get back to work and my handy list of articles on that very subject)

  18. Ewan R
    October 26, 2010

    nothing to do with failed yield gains with smartstax then? or perhaps RR tolerant weeds?

    There may have been moderate early response from the market on smartstax results – however once more data is in it is obvious that smartstax is workign well in most localities despite low insect pressure – there are two varietal issues where yields are lower but this is a drought pressure on the varieties selected. However the price drop there was marginal at best and has since recovered (drop by ~$5 per share at the end of September which has been completely recovered as of this minute and is infact now higher than it was before the non-issue of smartstax performance raised its head) – roundup resistance can’t really be said to have had much of an impact – you’d expect to see a concomitant decrease in seeds and traits income which isn’t the case – seeds and traits increased last year taking some of the sting off of the absolutely massive decrease in glyphosate sales. However the dominant change in pricing from the high of around $140 to the relatively steady $50-$70 has been driven mostly by the factors I mentioned (a $5 variance for 2 weeks really doesn’t say anything about anything)

    no, they’re new foods.

    No, they’re not. Unless you also categorize new varieties of present foods as completely new – do you? The changes happening with GMOs do happen with nature – GMOs gave us roundup resistant crops, nature gave us roundup resistant weeds. GMOs give us drougth resistant corn, nature is replete with drought resistant varieties – do they occur by exactly the same mechanism? No – the mechanism by which they are achieved using GMOs is well understood and thought out, the mechanisms by which nature achieves its goals are nowhere near as well understood and by no means at all thought out (if you’re of the opinion that nature gets to its solutions in any sort of organized or useful fashion look at the recurrent laryngeal nerve in giraffes, or human reproduction (which is so chock full of absurdities that to attribute any sort of ability to do things right to nature is ludicrous))

    the point of talking about the evolution of the plants before they were gm’ed is that this is what nature created over, as you say billions of yrs. i trust nature – i dont trust your gm’ed version of nature – which is a new version of these plants.

    Essentially nothing you eat is “created” by nature – it’s all selected by humans over thousands of generations to do what we want with it – it’s all genetically modified, we can just do things at the individual gene level now rather than having to wait for freak occurances to happen along.

    healthy balance: for example if you’re cold, you’ll reach for a sweater or turn on your heating system – youre still changing, but there is some balance happening.

    I’m thinking this is a complete understanding of evolution fail, it’s not a process of balancing, it’s a process of maximizing reproductive fitness regardless of whatever else is going on (if nature was replete with balance then predator prey relationships wouldn’t follow completely stochiastic tracks with essentially the potential for either predator or prey to go extinct at the drop of a hat – neither would you see evolutionary arms races or ridiculous excesses caused by natural selection (peacocks tails for instance, a balance has obviously been reached, but it is a pretty ridiculous balance) (also what exactly does “healthy balance” mean in evolutionary terms? Sounds like smoke and mirrors talk to me)

    • gavin venn
      October 26, 2010

      hello Ewan

      “nature gave us roundup resistant weeds”

      the human over-application of glyphosate has caused the result – glyphosate resistant weeds. so, human screwing with nature has given us glyphosphate resistant weeds.

      “if you’re of the opinion that nature gets to its solutions in any sort of organized or useful fashion look at the recurrent laryngeal nerve in giraffes, or human reproduction (which is so chock full of absurdities that to attribute any sort of ability to do things right to nature is ludicrous))

      i make good use of that unorganised or ‘unuseful fashion’ –the soil at my farm is biologically rich because i add rotten manure, charcoal, compost etc – that environment is populated by countless billions of bacteria. with care, this soil grows healthy crops without the need for any artificial fertilizer. i let wild plants grow in rows between my crops – more unuseful fashion – & no need for herbicide. because populations of insects can move up these rows of wild plants – they get access to the crops & guess what, i rarely get crops eaten – why – because there is some balance happening – where ‘pests’ regulate each other – completely ludicrous i know – but yet more unorganised unuseful fashion :)

      “Essentially nothing you eat is “created” by nature – it’s all selected by humans over thousands of generations to do what we want with it – it’s all genetically modified, we can just do things at the individual gene level now rather than having to wait for freak occurances to happen along.”

      before homo sapiens came along, cause & effect was happening, & what we call food was resulting. yes, there has been much human interplay with nature, as we’ve evolved – but never before what i call gmo, (& you’ve called a “mechanism”) have we humans’ altered food in such a fundamental way. As such, it is new food.

      “I’m thinking this is a complete understanding of evolution fail, it’s not a process of balancing, it’s a process of maximizing reproductive fitness regardless of whatever else is going on”

      i never said evolution was a process of balance – i never defined evolution at all – you did that.

      i mentioned balance way back, because a living being like a gmo salmon – to have good health is connected with balance -the conditions it lives in affect it – everything in that salmon’s world effect it – water temperature, amount of food – number of fish in tank – too much / too little. the salmon is constantly changing / adapting – i would say regaining it’s balance in it’s environment. the internal workings are no different – when in balance there is good health. i suppose this is more of a holistic way of looking at health – connecting it with balance, but i think you can better understand me now.

  19. Ewan R
    October 26, 2010

    the human over-application of glyphosate has caused the result – glyphosate resistant weeds. so, human screwing with nature has given us glyphosphate resistant weeds.

    Not quite – the variation has to exist in a population to be selected for, it doesn’t arise as a response to an applied pressure. Although if you were to go with that explanation you’d have to also concede that human screwing gave us all crops – cant have it both ways (and humans actively selected for certain crop characteristics, whereas roundup resistance in weeds is accidental)

    the soil at my farm is biologically rich because i add rotten manure, charcoal, compost etc

    Shouldn’t you be letting nature take care of itself as it has for millions of years and not be interfering with it? Just sayin’ (seriously though – if nature was designed and balanced towards feeding humans you wouldn’t have to supplement your soil at all) – I can also pretty much guarantee that you are losing some yield to the setup you have, there’s really no way you aren’t (any and all energy that diverts into non-crop plant biomass or insect biomass is categorically lost yield)- and I’ll guess for the sake of arguement you haven’t run a fair side by side comparison

    before homo sapiens came along, cause & effect was happening, & what we call food was resulting.

    Hogwash, the majority of foods we eat now were selected from practically (although not entirely) unrecognizable ancestors – what we call food now is as non-natural as just about any other human invention – the changes in food from circa 10,000 years ago until circa 18 years ago are orders of magnitude higher than the changes introduced by using genetic engineering (compare teosinte to maize for instance) and are the result of direct human selection.

    i never said evolution was a process of balance – i never defined evolution at all – you did that.

    Sorry, the following statement by you did seem to suggest the two were related somehow, I guess I misinterpreted your meaning of balance –

    i just dont see how a fish that has evolved over millions of years in balance

    I’m still of the opinion that viewing health (in particular) as a balance issue is dangerously wooish magical thinking (maybe not dangerous in terms of evolution of species or how animals or plants interact with the environment(just entirely wrong), but the same sort of thinking is categorically harful and indeed insulting if applied too widely – although here I’m getting tangential again (I like to do that) and simply thinking out loud – not trying to put words in your mouth)) which I personally don’t think has a basis in reality.

    • gavin venn
      October 27, 2010

      hello Ewan

      “the variation has to exist in a population to be selected for, it doesn’t arise as a response to an applied pressure”

      are you saying that these wild plants were already glyphosphate resistant or that they carried the potential to develop the resistance?

      “if nature was designed and balanced towards feeding humans you wouldn’t have to supplement your soil at all”

      nature isn’t designed.

      manure, charcoal, compost & soil are all part of nature. nature doesn’t distinguish between soil and manure – people do.

      people, wild plants, human bred plants and gmo plants are all part of nature.

      so, where gmo plants differ from plants bred using traditional “mechanisms” is the level of human interplay at the genetic level. This interplay or as you say “mechanism” is new – it hasn’t been used by people over the past 10,000 years or before.
      Isolating and transfering individual genes & traits is new.

      “I can also pretty much guarantee that you are losing some yield to the setup you have, there’s really no way you aren’t”

      I’m sure you could teach me a lot about how science could help me improve productivity. But, my interest is in growing quality food while improving soil fertility and the health of the entire farm. That’s not to say productivity
      isn’t important, but i see it as finding a balance with my other concerns – which affect the future.

      “Hogwash, the majority of foods we eat now were selected from practically (although not entirely) unrecognizable ancestors
      – what we call food now is as non-natural as just about any other human invention”

      Possibly our views of nature or what is natural, are very different.

  20. Ewan R
    October 27, 2010

    are you saying that these wild plants were already glyphosphate resistant or that they carried the potential to develop the resistance?

    The plants were already glyphosate resistant – plants which are not resistant but have the potential to develop resistance will die under glyphosate application and have no fitness benefit.

    nature isn’t designed

    I agree, your arguements previously seemed to suggest you thought it was with statements like

    the point of talking about the evolution of the plants before they were gm’ed is that this is what nature created

    The wording implies intent, which is where I guess I confused your message.

    manure, charcoal, compost & soil are all part of nature. nature doesn’t distinguish between soil and manure – people do.

    Ok so everything is part of nature this means your pandering to what is natural is meaningless – GMOs are nature, ammonium nitrate is nature, glyphosate is nature. My point was that if ‘balance’ in nature was something that came about naturally you wouldn’t have to supplement your soil – the fact that you’re supplementing means you’re altering nature’s “balance” – which I had presumed might be meaningful to you (I’ve already made clear that the notion of balance in nature is pretty empty to me so it may be that I’m just tilting at windmills here)

    Possibly our views of nature or what is natural, are very different.

    Your suggestion was that the foods we eat now had evolved prior to our appearance, which is clearly a falsehood – some things we can eat now existed to be sure, but the bulk of crops and livestock which make up our diet have been selected by us from ancestors which bear very little resemblance to pre-human versions. Your assertion was that what we call food was resulting before we were on the scene, this is only true if you set your defining parameters spectacularly low.

    You’d also have to tighten up what you’re defining as ‘natural’ – I’m working under the assumption we’re discussing that which isn’t man made, which by my definition includes all essentially all food stuff.

    • gavin venn
      October 28, 2010

      hello Ewan

      “The plants were already glyphosate resistant – plants which are not resistant but have the potential to develop resistance will die under glyphosate application and have no fitness benefit.”

      i’m still not clear how this works: if the plants were already glyphosate resistant, why did roundup, work at all?

      “Ok so everything is part of nature this means your pandering to what is natural is meaningless”

      I’m interested in how our human interplay with our world effects ourselves, and everything else.

      As humans have evolved, so has their intelligence. With this evolution in intelligence has come the increasing possibility to manipulate our world in our favour. This has many benefits for humans based on how we see ourselves and our world. However, sometimes we can forget that our being on this planet is interdependent with everything else. Our human wellbeing depends on our relationship with everything else. A simple example would be trees and their connection with air – that we constantly require. Or the health of bees, and their connection with pollinating our crops. Or the purity of water and our health. Unless we ensure some sense of balance between humans and other life and their environments, our own problems continue to increase.

      For this reason, I’m concerned about the current application of this new gmo technology – how it effects not only people, but wider others as well.

      • Ewan R
        October 28, 2010

        i’m still not clear how this works: if the plants were already glyphosate resistant, why did roundup, work at all?

        (apologies in advance to anyone with either a better knowledge of evolution, or who is better at explaining it – it’s a passion of mine but one I often muddle terms in – corrections welcomed!)

        Evolution works by selecting for variation within a population, not creating variation (think of it as a filter) – to consider a hypothetical weed X which has evolved glyphosate resistance by massive overexpression of the enzyme effected (which is one of the means by which weeds have become glyphosate resistant) – prior to the use of glyphosate the population maybe had variants with overexpression present at a really small proportion – perhaps one in a billion plants or somesuch number, or perhaps even something as low as one plant per generation turning up with a mutant form which overexpresses the protein – with no selection pressure for this enzyme/gene and we’ll assume a mild selection pressure against (making more enzyme than you need is probably not a great idea in most cases if only because it channels amino acids into a wasted pool) the population at large would be characterized as having ‘normal’ levels of the enzyme and would thus generally be glyphosate sensitive.

        Now you apply glyphosate, generally the field you spray on has no mutants and all of weed X is killed. However by chance one year your field contains a single mutant and you spray with glyphosate – all of weed X is killed bar this single mutant – this single mutant can now grow without competition, so next year the entire local population of weed X comes from the mutant parent (and if it was heterozygous(single copy of the mutation) for the mutation ~75% of the population will be resistant, potentially 25% to a greater extent as they are homozygous (have 2 copies of the mutation) – with each spraying of glyphosate only plants containing the mutant gene reproduce which increases the proportion of the mutant gene in the population – therefore a highly rare and potentially marginally harmful gene variant quickly becomes dominant in the population (as the selection pressure applied by glyphosate is massively high) (same kinda thing happened with myxomatosis resistance in Australian rabbits if memory serves)

        So variants already present in a population get filtered from generation to generation – natural selction doesn’t create variation it selects from that available – the creative ‘force’ behind evolution is mutation, which is utterly blind – it will not supply that which is needed as and when it is needed, it just supplies variation within the population which may or may not be useful should conditions change.

        However, sometimes we can forget that our being on this planet is interdependent with everything else.

        It’s dependent on a lot, I don’t think with everything else.

        would also be helpful if you can point me to what you see as meaningful references to show relationship between gmo use and weed killer use

        I’m sure I can dig something up – the story here is however a little different – there has been an increase in quantity (in terms of lbs of active ingredient) used (generally anyway) however the environmental impact of herbicide use has generally decreased due to the utilization of RR crops (I like to make the comparison between taking 5mg of morphine as compared to 500mg of asprin – looking at quantity alone you’d assume morphine had the lower impact – if you’ve ever taken morphine you’re likely aware this isn’t the case (although on a personal note this isn’t a great comparison as the only time I ever was administered morphine it did exactly diddly squat))

      • Ewan R
        October 28, 2010

        Some linkage to changes in herbicide use

        interestignly this one shows decrease in AI aswell as EIQ

        global EIQ changes and total pesticide reduction (includes insecticides here, splits later to insecticide & herbicide but no longer gives quantities, just EIQ)


        Impact of GM canola

        Again, there are more out there – google scholar is your friend (search terms like Environmental Impact Quotient herbicide/roundup/pesticide/GMO) – the few I’ve provided is all I have time for at the moment.

      • Anastasia Bodnar
        October 28, 2010

        But Ewan, I don’t want to have to look for stuff myself. Come on, can’t you paste the relevant paragraphs here for me?

      • gavin venn
        October 28, 2010

        Ewan – thank you – will digest.

        Anastasia – ouch! Notice I asked for references Ewan, thinks are meaningful. I truly am interested in understanding your views here: and broadening my own. You know, one of the big problems with the debate (or lack of) around gmo, is the two sided debate. People arn’t talking to each other. There are washing problems on both sides. I’d like to bridge the divide – this is why i’m here.

        thanks gavin.

      • Anastasia Bodnar
        October 29, 2010

        Yeah I probably should keep my snarkiness to myself. But I find that people read a ton of junk on anti-science websites but never bother to look up actual scientific papers for themselves. I don’t know if it’s laziness or what but then when someone does bring up actual science-based evidence they get all huffy. The evidence of this can be found on comment boards all over the place, from Huff Po to the NY Times.

      • gavin venn
        October 29, 2010

        hello Anastasia

        “But I find that people read a ton of junk on anti-science websites”

        interesting comment – what makes you see it as anti- science?

        Not being a scientist myself, please can you tell me how you define a scientific paper?

        Also, how important do you see socio cultural concerns connected with gmo, which may be presented in a more qualitative manner?

        thanks, gavin

      • gavin venn
        October 29, 2010

        evenin Anastasia

        No probs – I think we can both be snarky.

        “I find that people read a ton of junk on anti-science websites”

        Interesting. Do you see these sites as anti-science or are they just anti – gmo or other specific science subject?

        Being far from a scientist myself, it would be useful for me to understand what you scientists’ define as scientific papers?

        How relevant / useful would you see socio – cultural issues connected with agriculture, that may be presented in more of a qualitative format?

        input from all scientists’ most welcome …

  21. Charles M. Rader
    October 27, 2010

    Gavin, it shouldn’t be necessary to explain this, but here goes:

    The word natural in a discussion can mean a lot of different things. It certainly is not a synonym for good.

    When it comes to plant breeding, there are a lot of breeding techniques that I would be reluctant to call natural, but which don’t seem to have drawn the cloud of suspicion that comes with recombinant DNA technology.

    The oldest such technique on the list is grafting, which creates a single plant with one genetic heritage in the root system and another genetic heritage in the branches which bear the fruit. This never happens in nature, without human interference.

    Around a hundred years old is the technique of subjecting plants to x-rays or gamma rays to induce mutations. This creates genes that have never been in the universe before, and selective crossing then selects the few which are beneficial traits.

    Almost as old is treating plants with chemicals that cause chromosome doubling. In a human being, a single extra chromosome causes a devastating genetic disease. Yet we accept plants like strawberries which have three extra chromosomes for every one nature provided, and we give scarcely a thought to it.

    Similarly, there are the techniques for eliminating seeds. Seedless grapes didn’t arise by breeders patiently selecting, as breeding stock, each generation, the plant with fewest and smallest seeds. They used treatments to force an odd number of chromosomes, making the resulting plant sterile. Obviously not a product of nature.A similar idea has been used with the Aquabounty salmon to get only sterile females.

    Then there’s wide outcrossing. Often the result would not be viable but can be kept viable by embryo rescue. That’s how we got triticale, a cross between wheat and rye.

    None of these unnatural techniques got much attention from Greenpeace or similar propaganda groups. I wonder why they are less threatening than recombinant DNA transfers.

    But also, I’d like to point out that none of the GMO gene transfer technology would exist without a tool kit provided by nature. The Agribacter tumafaciens vector is an obvious example, but besides that, every restriction enzyme (used to make cuts in DNA) and DNA polymerase enzyme (used to make joins in DNA) is borrowed from nature. Most gene transfers are pretty disruptive and wouldn’t work if the plant didn’t come with DNA repair enzymes. If you are the type that will personalize nature, it’s hard to argue that she didn’t intend for us to have this tool kit.

    • Anastasia Bodnar
      October 27, 2010

      Thanks, Charles! Genetic engineering would probably be impossible without using natural enzymes.

      • Ewan R
        October 28, 2010

        Would have just required advances in nano-technology – tiny scissors, tiny tweezers, tiny superglue tubes – problem solved.

    • gavin venn
      October 28, 2010

      hello charles

      please show me where i said nature was good? or for that matter, where i said gmo was bad? imo, these issues have nothing to do with good and bad.

      ive already said i have nothing against this new technology – my concern lies with how it is being implemented and the wider effects on everything else.

      • c_rader
        October 28, 2010

        Gavin, I didn’t look through all your comments to try to find some case where you said GMO was bad. It’s clear that you think that it, in some fundamental way, crosses into new territory and without sufficient precaution. I haven’t seen where you have any suggestion for a specific type of precaution other than simply stopping the GMO practice, but maybe you have a suggestion I didn’t notice.

        There are countless instances in your comments where you contrast the breeding changes made by GMO technology, which you distrust, with the changes based on “nature”, which you seem to trust. But you talk very little, if at all, about other ways of producing new plant varieties. My previous comment was meant to suggest to you that many of those older methods were just as significant a departure from what is natural as DNA transfer between species.

        Yes-no question: Does moving a small and completely characterized DNA sequence from a bacterium into a plant pose a greater concern than disrupting that same plant’s genetic structure by radiation or chemicals?

      • Karl Haro von Mogel
        October 28, 2010

        Gavin Venn:
        “hello charles

        please show me where i said nature was good? or for that matter, where i said gmo was bad? imo, these issues have nothing to do with good and bad.”

        Gavin Venn:
        “i trust nature – i dont trust your gm’ed version of nature – which is a new version of these plants. ”

        While not exactly the same, you have indicated that you trust what nature produces – as in, it is good for you, while contrasting it with GE which you do not trust. If this trust was not to say something other than that, then what? What do you trust about nature that is not about whether what it produces is good or not? I think you are attempting to shift your apparent position in light of Charles’ argument.

      • gavin venn
        October 28, 2010

        hello Karl,

        I don’t trust how your gmo technology is being implemented. This is not the same as saying it’s bad. People labelling good and bad isn’t conductive to encouraging dialogue. But let me be very clear – no, i don’t trust how your gmo technology is being implemented.

      • Karl Haro von Mogel
        October 28, 2010

        Yes, but what about what you said about how you trust nature? Trust it to do what?

      • gavin venn
        October 28, 2010

        hello Karl

        If you follow my view of the importance of balance in our world – this involves some appreciation of how we (humans) depend on and effect everything else.

        As we humans have evolved, so has our potential to manipulate our world to suit ourselves. Animals and other creatures don’t have the intelligence to effect the world as we humans do.

        As our human interplay with cause and effect reaches new levels, so does our potential to effect everything else.
        These effects don’t have to be negative because we have a new technology, but we do need a clear understanding of not only the immediate results, but also the longer term results that we are creating before preceeding.

        In the past, in farming, we didn’t consider the wider effects of our (human)actions. Consider the development of artificial fertilizers, which have enabled humans’ to reap many benefits, but also caused many problems – that we’re just now having to look at, and future generations’ will be forced into dealing with.

      • Karl Haro von Mogel
        October 28, 2010

        You didn’t answer my question.

      • gavin venn
        October 28, 2010

        Let’s try this Karl:

        For things to work, we can’t have it all our own way. For me, human involvement with and work with nature – with what is there, (as opposed to continually changing it solely to suit ourselves), is more considerate of this wider balance that is necessary for our wellbeing. So i trust in that.

      • Karl Haro von Mogel
        October 28, 2010

        But the problem is, your idea of the distinction between “working with nature” and working against it (or solely for ourselves) is socially constructed. All our ideas about the distinction between nature and artifice are that – social constructions. There is no non-arbitrary reason to draw the “working with nature” line between mixing compost and charcoal with your soil and genetically engineering a plant to, say, attract nematodes that will attack insect pests. Why not draw the line on this side of genetic engineering, to include both as ‘working with nature’? Or instead, draw the line on the other side of manure and charcoal to call both activities not working with nature?
        It would seem to me that in order to rescue ourselves from this natural-artificial problem of distinctions is to instead rely on what the actual effects are to determine right and wrong. It seems that you have defined GE as categorically not “working with nature” (unless I read you wrong), but you can use GE do make a crop that will tolerate artificial herbicides – or – you could make a crop that enhances bio-control of insect pests. There is, for example, a GE corn trait developed using a gene from oregano that attracts nematodes that attack corn rootworm beetle larvae. Just like you can apply too much charcoal and manure to your land and throw off the balance, it seems to me that there are things you can do with genetic engineering that would fit the bill for “working with nature”, and things you can do that would definitely not fit the bill.
        My opinion is that it is the trait and its effects on the environment (and people) that matters, not how the trait was developed. This thread started talking about GE salmon, so I would like to return to that issue. I think others asked you what your opinion would be of the fast-growing salmon if it was not genetically engineered, and I don’t think you quite answered it. Granted, you’re talking to a bunch of people all at once and I commend you for sticking through all this debate. But let me try it again, rephrased slightly.
        Let’s say a salmon breeder was going through her or his tanks, and discovered a fish that was bigger than the rest. They took it out, put it in its own tank, and studied it. It turns out that it grew twice as fast as the rest of the fish. They took some tissue samples over time, and studied it to look at hormone levels. They discover that in contrast to wild salmon which have their hormones cycle during the year, that the hormones are produced year-round. This fish is expressing a new mutant trait – something in the genetics world that is known as constitutive expression. (Biologists have discovered many examples of this.) The result is a fish that is identical in its characteristics to the GE salmon that we are all talking about – but it was not generated through genetic engineering but arose from natural variation. What do you think of this fish? Should it be regulated differently from the GE salmon, or the same? Does the natural origin of the new characteristic mean that it would have a different effect on the environment if released? Would raising this fish be ‘working with nature’ more or less, or the same? If it meant that eating this fish would require 20% less feed (and be cheaper at the store) would you eat it?
        The important part of this thought experiment is whether you think this new fish should be treated any differently from the GE fish, or whether it should be treated the same. If you believe it should be regulated differently (and less harshly) than the GE version, then you believe that the GE fish should be regulated thus because it is GE, and not because of its characteristics. But if you instead believe that it should be treated the same as the GE fish, then you agree that it is the trait that matters.
        (…could you think of any reason why it should be perhaps more strictly regulated?)
        I appreciate your thoughts on this.

      • Anastasia Bodnar
        October 28, 2010

        What about how non-GE technology is being implemented? Hybrids, for example, have arguably changed the face of agriculture more than anything else.

        Edit: I’d also like to bring up a few other things.

        I think we’re in agreement that herbicide resistance isn’t a good trait if we want to develop a more sustainable agriculture. The need for herbicides can be reduced if not eliminated with good use of crop rotation. Herbicide resistance can and has been developed with breeding/mutagenesis and with genetic engineering.

        Vitamin enhanced crops have a lot of potential to help alleviate nutrient deficiencies while we continue to work on long term efforts to reduce poverty. Vitamin content has been improved with breeding/mutagenesis and with genetic engineering.

        Is the problem* the use of the trait, the implementation, or indeed what the trait is itself – or is the problem whether or not it is genetically engineered?

        Edit (again) Maybe the problem is that people are involved? Like, anything people do is bad or something to be wary of?

        *problem = some people’s philosophical concerns.

      • Ewan R
        October 29, 2010

        I think we’re in agreement that herbicide resistance isn’t a good trait if we want to develop a more sustainable agriculture.

        I’d question this – while herbicide use may not be the best of all imaginable worlds on a spectrum of sustainability (as the qualifier you use here is a “more sustainable agriculture) I’d argue that herbicide resistance can be a good trait in developing more sustainable agriculture – glyphosate resistance certainly shifted agriculture towards a more sustainable mode of operation – a more environmentally benign herbicide + a resistance to it would surely shift things further in this direction – I think it’s also not entirely clear that good crop rotation to get rid of the requirement for herbicides would allow for agriculture that is sustainable in all senses of the word – I’m not convinved for instance you’d be able to sustain a year on year productivity to produce the quantity of food required (any crop rotational study I’ve seen shows equivalent yields in the year you grow the crop of interest at best, and glosses over the fact you can only do this 1 in 2 or 3 years for instance)

      • Anastasia Bodnar
        October 29, 2010

        I think there is a role for herbicides, especially more benign ones like glyphosate, but the current paradigm of broadcast spraying (with the help of herbicide resistance traits), while it may increase yields, reduces biodiversity in fields. There are weeds and then there are weeds. Some take a lot of water and energy from the crops while others aren’t as harmful but provide habitat/food/etc for wildlife and can help encourage ecosystem services like pollinators and natural predators of crop pests. There’s a bit of give and take there that deserve attention. You might loose 3% of yield due to weeds but gain 2% of yield due to reduced insects and increased pollination (for insect pollinated crops) and I think I’d be willing to say that net 1% yield loss is worth it for the improved biodiversity on the farm.

        As for yields of rotations – yeah, I thought that too. If you have to spend 3 out of 6 years (or whatever) growing whatever else to get the same yield of corn and soy as you would in a straight corn and soy rotation, then what’s the point? But then I looked into it a little more and was really surprised. Matt Liebman at Iowa State has done a lot of research on rotations and intercropping that shows total yield and total profit to be just as high in a complex system as in a simple system (of corn and soy). The problem is finding a market for all the other crops you’re growing. A lot of it can be used for silage and biofuels. Others can be valuable crops in their own right – barley, oats, etc. Another problem right now is the lack of locally adapted high yielding varieties of anything but corn and soy – try finding wheat germplasm that’ll work well in Iowa for instance. Despite the things that need to be done to get there, I think this is the best way to move agriculture forward.

        I also didn’t really understand how rotations could control weeds until last week! I knew that rotations can help reduce crop-specific diseases and insects by breaking up pest life cycles and by having more different crops on the landscape so pests can’t spread as easily. So I asked my Sus Ag buddies what they thought rotations could do for weeds. The answer was surprising but awesome. Long story short, each crop in the rotation has a different life cycle and different growing habit. For example, the grassier crops like sorghum shade out weeds so many of the weed plants aren’t able to get to the reproductive stage. Some crops mature fast so you can harvest them before the weed seeds are mature – the weeds get cut down before they can produce mature seeds. After a few rotations, you’ve effectively reduced the weed seed bank that’s present in the soil. You’ll still have some weeds but the amount is greatly reduced.

        I really want to write a whole blog post about this but sadly don’t have time to do all the research I’d need before I would be willing to present this info as anything but a comment. :(

  22. André
    October 28, 2010

    Charles, and Gavin,

    « Yes-no question: Does moving a small and completely characterized DNA sequence from a bacterium into a plant pose a greater concern than disrupting that same plant’s genetic structure by radiation or chemicals? »

    Let me supplement that question from Charles: What if it is later found out that nature has produced (let’s use this somewhat debatable phrase) a similarly performing sequence in glyphosate resistant malaysian goose-grass and and australian ryegrass (see previous post « Where the superpowers of superweeds come from »)?

    What if that plant sequence were now introduced into crops?

    And, on the other side, what about a cross with a wild relative, to capture a disease resistance, knowing that an unknown number of unidentified genes of the wild relative will also be introduced into the crop plant?

    And who guaranteed that the crosses between wheat and rye, which produced triticale, did not produce an explosive combination of ugly genes?

    If our neolithic ancestors had applied the precautionary principle we would still be hunter-gatherers. Or more likely extinct.

  23. gavin venn
    October 29, 2010

    evenin Karl,

    I have to say, I’m enjoying the conversations here and really learning a lot. Please take my response here in the spirit it’s intended – I’m not trying to insult you.

    “But the problem is, your idea of the distinction between “working with nature” and working against it (or solely for ourselves) is socially constructed.”

    Isn’t that true of everything, including science? We’re observing what is happening, but the way of seeing and how we’re relating to that are socially constructed.
    Or more accurately, socially influenced, as our personal way of viewing the world will also colour how we relate to what is being observed. Unless you’re suggesting scientists’
    provide the authorative and correct way of viewing our world?

    To add some flesh to that idea: you’re observing a gene, at the gene level ,and you have developed a detailed understanding of how that works and what it contains – that’s amazing stuff.

    But you’re seeing a gene! Who came up with the idea of gene – of seeing what you’re seeing in a ‘gene’ like way? Is seeing what you’re seeing as a gene, the correct or only way of seeing?

    “There is no non-arbitrary reason to draw the “working with nature” line between mixing compost and charcoal with your soil and genetically engineering a plant to, say, attract nematodes that will attack insect pests.”

    Again, comes back to how we see the world – we ain’t all scientists. I’ve said already, i see gmo plants as nature. The big difference for me personally, is our human interplay or mechanism (thank’s Ewan), with gmo, is now at the single gene level, so our potential to affect people and everything else is more powerful – much more powerful than mixing charcoal & manure. It’s all nature, it’s all interplay, but the potential effects differ in magnitude.

    Now, lets say you gm a plant to, as you say, attract nematodes. You’re changing that plant based on your scientific view of the plant, to do the job you want, and it does do the job you want, and that job may well
    have a positive result for farmers. You’re using your scientific knowledge or your intelligence applied to your scientific view of the world to create what you see as a positive result. But have you truly understood
    the wider effects of what you’ve created? Possibly your new gm plant cross pollinates with related wild plants and the nematode population explodes, creating big problems for neighbouring farmers, who arn’t using your
    gm solution. Possibly your gm nematode event continues to affect associated wild plants, as cross pollination moves the event across a massive geographical area – creating huge new problems for farmers across an entire
    Nation.

    Of course, this is just a hypothetical example, but I use it to illustrate the potential difference in effects, compared with mixing manure & charcoal.

    The level of human intelligence being applied to effect a change to nature to benefit ourselves (humans), is of a much greater magnitude. You are also now able to transfer single genes across species – this is powerful stuff – extremely powerful. Let’s show it the respect it deserves, by having deep risk assesments, or effect assesments – as risk assesments are based mainly on our previous understanding of risk. Let’s bring in various views – not only those of scientists.

    “It would seem to me that in order to rescue ourselves from this natural-artificial problem of distinctions is to instead rely on what the actual effects are to determine right and wrong.

    Spot on! But who is determining right and wrong? science? Only science – the authorative view? Or maybe the FDA?

    “It seems that you have defined GE as categorically not “working with nature” (unless I read you wrong),”

    GM plants are nature. I agree with you – it’s what we are doing with them and the effects that creates that are important.

    “My opinion is that it is the trait and its effects on the environment (and people) that matters, not how the trait was developed.”

    I can only say i agree so many times. But the caveat i’m adding is – who is deciding what effects to look for? Or the importance of those effects on people?

    “Granted, you’re talking to a bunch of people all at once and I commend you for sticking through all this debate.”

    What, you mean I’m not one of the gang? Oh well – always the black sheep :)

    “The result is a fish that is identical in its characteristics to the GE salmon that we are all talking about – but it was not generated through genetic engineering but arose from natural variation.

    How would you know it’s characterists are the same? How are you looking at the fish? Is the scientific way of viewing the fish, the only way to view it? Are you missing anything? Who says what you’re seeing is a fish at all?

    Sorry, to be such a slippery fish. But, you see, I don’t see the world through scientists’ eyes.

    • c_rader
      October 29, 2010

      We’re observing what is happening, but the way of seeing and how we’re relating to that are socially constructed.

      Gavin, you are getting dangerously close to a way of thinking that is intellectually vacant, the idea that science is not about truths but is essentially a creation of a culture. The idea is usually traced back to the writings of Karl Mannheim.

      In a trivial way it is true. We wouldn’t expect an Esquimo thinker to study the physics of snow in the same way as a tropical thinker might. But once you get beyond the trivial, it quickly becomes ridiculous, e.g. Who says what you’re seeing is a fish at all? — at which point it is playful philosophy but not serious thought.

      I mean really, can you expect to use your mind to reach a useful conclusion when you deny the most basic confidence in the reality of what you are thinking about?

      I recognize that you haven’t strayed that far into social constructionism. Your examples show that you mean that perhaps the advocate of the GMO fish is not thinking about all the important issues.

      Here’s the point: We can consider the issues of, say, a GMO fish, one by one, as many as we can think of. We do the best we can. A naysayer can say “You haven’t thought of everything!”, but unless he can tell us another issue to consider, he’s useless. The fancy language of this is to say “You’re thinking like a reductionist whereas you should be thinking holistically.” But in my observation the holistic folks never actually do any thinking, only posing.

      • gavin venn
        October 30, 2010

        Charles, as you know, i’m no scientist, and have never pretended to be one. My opinion is that trying to be, what I clearly am not, is counter productive. It may be useful for you to keep in mind , that these gmo issues, while created by scientists, effect all people. pose completed :))

        First two issues:

        1. How do people benefit from gmo fish?

        Ewan’s ideas hint at some reasoning. But from their web site, Aqua Bounty, make no comment about these possible motives, and refer to the gmo salmon as ‘product’.

        We’ve been discussing a risk assesment undertaken by scientists’ and the FDA. Why take the risk – where is the important driver?

        2. Welfare of gmo salmon:

        Over expression of growth hormone (in humans anyway) can lead to agromaly, thickening of skin, respiratory problems and increased odour. But we’re told the only notable difference to the fish is a slight increase in IGF1. But the fish have thicker, larger jaws – which we’re told are no different to usual farmed salmon.

        It seems sensible to me, to ask how amplyfying the GH, so that the fish grow at twice their usual rate effects the total development of the fish. These gmo fish, are expressing a given level of GH continually, whereas their non – gmo, farmed counterparts are not. Body tissues, as I understand it, do not all develop at the same rate. Wild atlantic salmon have evolved over millions of years and their fluctuating levels of GH, correspond with the conditions in which they have evolved, to result in healthy fish. So I think it’s reasonable to look at the tissue samples in more detail – how have the different tissues developed in relation to each other? Do we have fish with weak circulatory systems? (pose completed)

        I’ve some more issues and will highlight them when you’ve responded to these.

        thanks, gavin

      • c_rader
        October 30, 2010

        Gavin, I’m not a scientist either, although I consider myself scientifically literate. Your latest post asks specific and sensible questions, which can, in principle be answered.

        Your questions fall into two groups.

        In one group, a typical question asks about how the extra growth affects the health of the fish. AquaBounty and FDA have tried to answer questions like this. I doubt that they’ve answered every question to everyone’s satisfaction. I certainly have no more to add — what I know comes from the same documents the rest of us have seen, and from Ms. Bodnar’s excellent summary. But I will make one important comment about group I questions. There have been other non-GMO modifications of salmon such that the farmed salmon stock is genetically very different from wild salmon. As several people have already asked you, “Is it the GMO-ness of the change that makes you subject these changes to extra scrutiny?” Because there are salmon, already being farmed, that grow twice as fast as wild salmon. There are also other species of fish being farmed with large genetic differences between the farmed and wild stock. I don’t hear a lot of objection to the breeding methods that created these farmed fish.

        Your second group of questions is quite different. Typical question – How do people benefit from gmo fish?

        The underlying assumption of these group II questions is that it is any of your business. People can decide for themselves what benefit they seek from a new product. AquaBounty executives may be motivated by a chance to make money. Ecologists may appreciate if a kind of salmon can be farmed economically without exposing the ocean habitat to pollution and disease. Fishermen may appreciate that it takes less fish meal to bring these salmon to marketable size, leaving more food in the ocean for wild fish to eat. technologists may experience the joy of creating a new thing. Fish markets may appreciate the availability of salmon in a different season.

        Suppose the conversation is turned on its head. Suppose someone asks you why you need to farm using charcoal and manure blends. Maybe you enjoy answering that question, but you would be perfectly within your rights to say “I’ll farm any way I like.” as long as you are not causing harm to another person or the environment.

      • gavin venn
        October 31, 2010

        Charles,

        “The underlying assumption of these group II questions is that it is any of your business. People can decide for themselves what benefit they seek from a new product.”

        Most people here seem to be agreed on the necessity for focus on the application of the gmo technology and the resulting effects.

        You seem to be arguing that the resulting effects of a gmo application are comparable to traditional breeding techniques. If you are taking that view, then surely, the application of gmo effects everyone – just as traditional breeding methods have done? So, saying people can decide for themselves what benefit they seek from a new “product” doesn’t take into account how this application of gmo effects other people.

        From my perspective, the potential effects of the gmo application are much more potent than traditional breeding methods. So, we need to understand the impact of these effects, and how to manage them, before we consider commercializing that application – if we are to have even a cursory consideration for others.

        The potential effects of introducing a new application of gmo, creates questions about effects for people, biodiversity, ecosystems and individual Nations. An individual Nation, my well have chosen to reject a specific application of gmo, yet through contamination, they are forced into dealing with it.

        I’ve a passionate interest in how people in different Nations’ have developed their own style of agri ‘culture’ and traditional ways of relating with their food, that are intimately connected with their local biodiversity and ecosystems. Commercializing new gmo applications that have the potential to contaminate and change biodiversity, also has the potential to impact these traditions, and possibly the human rights of the people. The culture and biodiversity of a Nation, are an incredibly valuable heritage, that in my opinion deserves to be protected.

        These are just some of the reasons to ask, why take the risk of commercializing the application? And your answer – it’s non of our business?

        “AquaBounty and FDA have tried to answer questions like this. I doubt that they’ve answered every question to everyone’s satisfaction.”

        Correct – and not just mine:

        this quote is taken from Common Ground ‘Dr. Michael Hansen, Senior Scientist at Consumers Union in the US, testified before the Veterinary Medicine Advisory Committee on September 20, saying, “The data are too superficial and of insufficient scientific quality to warrant approval.” Having examined the summary of AquaBounty’s science, he says, “The FDA is relying on woefully inadequate data. There is sloppy science, small sample sizes and questionable practices.”’

        “Because there are salmon, already being farmed, that grow twice as fast as wild salmon.”

        As I understand Anastasia’s review, the gmo salmon grow twice as fast as non-gmo farmed salmon – the comparison is between the two types of ‘farmed’ salmon.

      • c_rader
        October 31, 2010

        Gavin, you hit the nail right on the head when you said From my perspective, the potential effects of the gmo application are much more potent than traditional breeding methods.

        The trouble with your statement is that it is creating a problem by defining it as a problem. There is zero evidence that GMO genes are “more potent” than other genes. Since you’ve been posting here you’ve consistently ignored questions about other breeding techniques like chromosome doubling, irradiation, embryo rescue, etc.

        I think we would be in 100% agreement that any new product that can reproduce itself, shed pollen, etc. ought to be studied carefully before it is approved because it has the potential capacity to harm others. I also think that this point of view has been and is being followed with commercialization of GMO plants and, now, animals. This thread wouldn’t even exist if not for the FDA evaluation now taking place for GMO salmon. But where are the similar evaluations on other new agricultural introductions? Who did you have to satisfy before any of your own farming innovations?

        The gene in a GMO plant is precisely a string of As, Gs Cs and Ts in a chromosome, and it has exactly the same properties whether it got into the chromosome by means of a gene gun, an agribacter infection, a random mutation or a gamma ray exposure. You have provided us with absolutely zero reason to believe that the AGTH string which we call a gene (or a transgene) is fundamentally different from other genes. (Maybe nature invented the AGTH string in another species, but the gamma ray derived string never existed in the universe at all.)

        Now a few of your other comments deserve counter-comments.

        the gmo salmon grow twice as fast as non-gmo farmed salmon – the comparison is between the two types of ‘farmed’ salmon. Yes and the farmed salmon grow twice as fast as wild salmon. The question is – why would one factor of two raise alarms while the other was calmly ignored?

        Saying people can decide for themselves what benefit they seek from a new “product” doesn’t take into account how this application of gmo effects other people. But Gavin, I agree that we have to take into account any properties of the new product that might affect other people. My only problem is when the GMO product is singled out for special attention while non-GMO products are pretty much allowed a free ride. This subject deserves a separate discussion, but for example – Pollen from one variety of oilseed, meant to provide an industrial lubricant, can fertilize plants meant to produce another variety of oilseed. The resulting oil would taste too bitter to be used. This problem is managed quietly and calmly without Greenpeace demonstrations or international trade restrictions. Why, then, does pollen from a GMO oilseed, which causes no bad taste or, indeed, no difference that can be detected without a laboratory DNA analysis, become elevated to the level of a huge cause?

        this quote is taken from … ‘Dr. Michael Hansen, Senior Scientist at Consumers Union Here we go again, on whether one should be paying attention to the substance of a comment when the maker of the comment has a track record. I’m going to descend to the level of a wisecrack. – The Consumer’s Union regularly evaluates consumer products by testing a small sample, say two or three cars, and supplements its evaluation with hearsay reports from its subscribers.

        Commercializing new gmo applications that have the potential to contaminate and change biodiversity … This one really hurts because it is so current. For decades, ecologists and diplomats had been working on biodiversity protection, until in 1992, the diplomatic effort was captured by the anti-GMO movement. Since then, it has been impossible to accomplish anything internationally about invasive species, or trade in endangered species. Only protection from the dreaded GMOs can even get on their agenda. This attitude has driven the United States, a nation with a population that supports most environmental initiatives, out of the Convention on Biodiversity, guaranteeing its irrelevance. This is an exact replay of the Kyoto Treaty on climate change, and even some of the players are the same.

      • gavin venn
        October 31, 2010

        Charles,

        “There is zero evidence that GMO genes are “more potent” than other genes”

        Never said they were – because I don’t know if they are. I I said, imo, the mechanism is more potent than traditional breeding methods, because of the control over manipulating individual genes – and also said this isn’t necessarily a negative development: & it’s been made clear to me that this could even be seen as a positive development.

        So again, comes back to how the technology is being applied and the effects of that application.

        “Since you’ve been posting here you’ve consistently ignored questions about other breeding techniques like chromosome doubling, irradiation, embryo rescue, etc.”

        Trying to get clear understanding of these. Will then comment.

        “You have provided us with absolutely zero reason to believe that the AGTH string which we call a gene (or a transgene) is fundamentally different from other genes.”

        Thought we were concerned with the effects of the gmo application? There is no benefit in me commenting on a string I know nothing about.

        “Yes and the farmed salmon grow twice as fast as wild salmon. The question is – why would one factor of two raise alarms while the other was calmly ignored?”

        So the gmo farmed salmon grow 4 times as fast as wild salmon

        I’ve already said, I’m sure the non-gmo farmed salmon also have many issues. Personally, I wouldn’t buy any farmed salmon – gmo or not.

        Again, I’d like to emphasize my concerns over the health of the gmo salmon – the amplification and continual expression of a single hormone.

        “This attitude has driven the United States, a nation with a population that supports most environmental initiatives, out of the Convention on Biodiversity”

        The anti-gmo people are only there because of what they see happening with gmo. What needs to change?

    • Karl Haro von Mogel
      October 31, 2010

      Gavin, thanks for your thoughtful responses. I don’t have much time right now to respond, but I wanted to clarify my thought experiment. You said:

      How would you know it’s characterists are the same? How are you looking at the fish? Is the scientific way of viewing the fish, the only way to view it? Are you missing anything? Who says what you’re seeing is a fish at all?

      Since it is a thought experiment, I can answer that question easily. In this thought experiment you have absolute knowledge that the two fish are identical in characteristics. The manner in which they produce extra growth hormone is the same, the levels, the phenotype, all of that is the same. The difference being tested by this thought experiment is on your belief about the process used to generate the trait – whether that matters more or less than the trait itself.

      Mind you, I am talking about physical characteristics of the fish. As for moral, religious, philosophical positions ascribed to it, that is a different issue entirely.

      Sorry, to be such a slippery fish.

      Gavin wins the thread.

      • gavin venn
        November 1, 2010

        Karl, I can’t debate the pure science with you, because I’m not a scientist: but I did suggest you invite one into the discussion.

        My view is based on the validity of interdependence. The evolution of a fish that takes place over millions of years, involves literally limitless causes and effects. Even with human involvement in breeding farmed salmon, I can’t see how you could use your gmo mechanism to achieve an identical fish. Hence my questions about the health of the gmo salmon – the relationship between the different tissues, & health of different internal systems.

        Interdependence is also relevant when we consider the wider effects on people, eco systems, biodiversity and individual Nations.

        As for me winning the thread – i’d consider my time here well spent if we’re able to find even small pieces of common ground. I don’t represent anyone except myself (a farmer with limited knowledge), so it would be pointless to suggest my involvement here represented anything bigger than that.

      • Ewan R
        November 1, 2010

        Gavin – “winning the thread” as Karl put it is general internetese (as far as I’m aware) for acknowledging some hilarious (or awful, depending on your predilicition) pun or such (had it been a little better there is the possiblity you would have been awarded 1 internet)

        My view is based on the validity of interdependence

        I’m not sure how valid a view this is, particularly when used in fuzzy terms – sure a lot of things are dependent on one and other, but not everything is dependent on everything else in any meaningful way, and if we’re going to believe it is we’d best lock ourselves in hermatically sealed rooms to avoid ever altering anything – I for one am not going to quiver in terror every time a butterfly decides to flap its wings in my direction.

        The evolution of a fish that takes place over millions of years, involves literally limitless causes and effects.

        You keep coming back to this, but I’m not sure what exactly it has to do with arguing for or against GM technology, notwithstanding there aren’t limitless causes and effects (there may be more than we know, or will ever know, but we can be sure it is less than an infinite number /pedant). Another interesting way to look at your evolution approach is to consider the vast number of differences there are between different types of Salmon, and various types of fish in general (from Minnows to Sharks and everything in between (including humans and aardvarks if you’re not going to get all paraphyletic on us, and I assume you’re not)) and then consider the spectacularly minor change that is an inserted gene in the grand scheme of things -different species of fish will have Genomes of various size (likely megabases different), shape (number of chromosomes… possibly a poor fill in for shape but what’s a boy to do?) and colour (erm, yeah, different quantities of random viral inserts and repeated chunks of parasitic DNA….)

        Interdependence is also relevant when we consider the wider effects on people, eco systems, biodiversity and individual Nations.

        Only if you can define this interdependence in a way that is meaningful and testable, until then it’s just a block to doing anything ever (or doing whatever is arbitrarily decided will effect the interdependence based I guess on nothing more than a gut feeling)

        Karl by the by wins one internet for inserting a rogue unopened italic tag making everyone after appear to be putting undue emphasis on everything they say.

        I said, imo, the mechanism is more potent than traditional breeding methods,

        It has the potential to be, but thus far isn’t in my opinion – all the major crop species have been produced by breeding – this includes major morphological changes, yield gains, weirditude in terms of colour change etc etc – thus far genetic engineering hasn’t given us anything of the sort (promises promises etc, but hard to realize)

        The anti-gmo people are only there because of what they see happening with gmo. What needs to change?

        What they see, or what they think they see?(or what they’ve decided they want to see based on their politics and have decided to stick with regardless of the reality of the situation?)

      • gavin venn
        November 1, 2010

        Ewan, happy with that – almost getting the worst pun :)

        “I’m not sure how valid a view this is”

        Valid? For conversation? With you? Your choice.

        Possibly you have the impression that i’m questioning the validity of science. Not the case, although I clearly am questioning how that scientific understanding is being implemented with gmo, and the effects of that.

        “sure a lot of things are dependent on one and other, but not everything is dependent on everything else in any meaningful way”

        Everything that comes into being is dependent on something else. If you agree with that, then through cause and effect, everything has to be connected – although in an incredibly subtle and complex manner.

        Why am I bringing such a view to this website? Because I’m interested in how gmo science is effecting others. With our developed human intelligence, we have the potential to effect these others in positive or negative ways. Here, I’m not only talking about physical health. But also peoples’ socio – cultural connections with their world.

        “It has the potential to be, but thus far isn’t in my opinion – all the major crop species have been produced by breeding – this includes major morphological changes, yield gains, weirditude in terms of colour change etc etc – thus far genetic engineering hasn’t given us anything of the sort”

        That would fit with my view that it’s the implementation of the technology and the effects that result that have to be considered. But we also have to be clear about the longer term results of the application – 10 years isn’t a long time if we’re comparing results of gmo implementation with the evolution of plant breeding techniques.

      • Ewan R
        November 2, 2010

        “I’m not sure how valid a view this is”

        Valid? For conversation? With you? Your choice.

        Valid as in being useful when applied to the real world – if you’re going to go with the interconnectedness of everything being important, and not undertake anything without understanding all the repercussions then I don’t see that it is remotely possible to ever do anything.

        Everything that comes into being is dependent on something else. If you agree with that, then through cause and effect, everything has to be connected – although in an incredibly subtle and complex manner.

        Incredibly subtle, complex and probably meaningless manner – the spin state of an electron in the heart of alpha centauri is “connected” to the air speed velocity of an unladen swallow – whether this is important or even measurable is highly doubtful (and that’s without getting into the nitty gritty of whether we’re discussing European or African swallows) – once your web of connectivity gets so wide as to be unmeasurable and probably meaningless it ceases to be useful as anything other than a tool for halting progress behind a wall of smoke and mirrors (this may not be what you are doing, but I’ve come across the tactic enough times to view it with suspicion – you haven’t tested enough, test more, and more, and more – setting the bar so high as to make any technological advancement economically impossible to get off the ground is not my idea of good thinking)

        That would fit with my view that it’s the implementation of the technology and the effects that result that have to be considered. But we also have to be clear about the longer term results of the application

        The results of the technology have been considered (in rather impressive depth to be fair), once you step away from GM fish and into the mainstream of GM there is an impressive amount of data on the actual real world results of their utility rather than just meaningless waffle about the nebulous potential for some future harm – they’ve been enormously beneficial – benefits which would never have come to fruition if the level of scrutiny you seem to be advocating had been applied prior to commercialization of the traits in question.

      • gavin venn
        November 4, 2010

        Ewan,

        You’ve said i’m saying everything is important. The definition of interdependence was offered because I took your comments to mean you wanted a definition – that’s all.

        Modern science is very valuable, but it’s mainly focused on physical view of ourselves and the world. A healthy body, is not much use without a healthy mind: we can’t snap our fingers, give people drugs and medicines and expect peoples’ minds to be healthy. Interdependence can be applied in specific ways to help us understand more about the connection between ourselves, our world and how that influences the wellbeing of our mind.

        This view of interdependence is often presented along with the importance of compassion: understanding how we are effecting others, for their benefit and ours.

        I know you’re interested in why there is much anti-trust with gmo technology, and you’ve got you’re own ways of explaining that. But people are very complex, and so, I’m interested in using these approaches to explore some of what I see are the main issues with this new technology.

        thanks, gavin

      • Ewan R
        November 4, 2010

        Modern science is very valuable, but it’s mainly focused on physical view of ourselves and the world. A healthy body, is not much use without a healthy mind: we can’t snap our fingers, give people drugs and medicines and expect peoples’ minds to be healthy. Interdependence can be applied in specific ways to help us understand more about the connection between ourselves, our world and how that influences the wellbeing of our mind.

        I’m not sure I understand where you’re going with this paragraph – as someone who has taken anti-depressants (thankfully short term about a decade ago) I categorically disagree that you can’t give drugs or medicines and produce healthy minds. I also can not think of another discipline which has done more to further our understanding of the mind than science, in fact I can’t think of another discipline which conceivably could further our understanding of the mind – given that it is grounded in the physical world.

        I’m thinking we agree that interdependance can be taken too far, but just disagree as to how far is too far – I’m more than happy to explore interdependance to the nth dimension – so long as this exploration isn’t proposed as a prerequisite to commercialization of a trait – imo this process needs to be sensible and timely.

      • Karl Haro von Mogel
        November 1, 2010

        Minus one internet for me for messing up the syntax of my ad-hoc italic tags! Everything is interdependent.

        Come on Gavin, you are missing the point of the thought experiment. The idea is to figure out how someone’s mind works – what is the most important issue or concept in a particular question.

        For example: If you were faced with having to sacrifice a developmentally disabled (mentally handicapped) human or a healthy gorilla for important medical research that would save countless lives, which would you choose? The question assumes all you need to know to make the choice – and it doesn’t matter whether anyone would ever be faced with such a question in real life. The point is to figure out what they value. It doesn’t matter if there is or is not a GE trait that is identical to a non-GE trait – the question assumes that such is true.

        You don’t need to be a scientist to find value in my thought experiment. Usually I find that people are unwilling to answer some thought experiments either because they do not want to admit what their answer will be, or they are unable to figure out what their answer would be. The gorilla one is hard for many people. This one should be easy. And “I don’t know” is a valid answer!

      • gavin venn
        November 1, 2010

        Karl, as ive said, you’re thought experiment isnt valid – unless you’re cloning the fish? In which case my response would be affected.

        Give me a real life thought experiment or figure out my mind from talking more with me.

      • Karl Haro von Mogel
        November 1, 2010

        Explain how the thought experiment isn’t valid? This example is very close to real life – I did mention that constitutively expressed mutant genes can be found. The GE trait is a simple one – endogenous hormone gene turned on all the time – that can happen naturally if you mutagenize and screen enough fish you can make it. Thought experiments by definition are not real-life. That’s why they’re called experiments! We can talk about what we think without having to screen millions of fish.

        Perhaps a real life example would be breeding maize to produce lots of pro-vitamin A (beta carotene) versus engineering it into the plant.

      • Anastasia Bodnar
        November 1, 2010

        I already proposed that one in a previous comment but it was ignored.

        Well, not totally ignored, Ewan called me on part of it which was good.

      • qetzal
        November 1, 2010

        Hi gavin,

        I’m a PhD molecular biologist. Been doing research for ~ 25 years. I promise you that Karl’s thought experiment is completely valid. It would be entirely possible to a) find a naturally occurring mutant salmon that constitutively overexpressed GH, and b) use GMO techniques to create another salmon having exactly the same mutation(s). It might not be particularly easy or straightforward, but there are no problems in principle.

  24. c_rader
    October 31, 2010

    The anti-gmo people are only there because of what they see happening with gmo. What needs to change?

    Let’s go back to the Kyoto process. The US was very involved in the beginning, when the diplomatic delegations were coming to meetings to get to know one another while scientists worked out details. In the climate change treaty, scientists were needed to decide how effective each kind of reduction step would be. The obvious reduction step is to not burn a certain amount of fossil fuel. But there are other steps that reduce atmospheric carbon, including growing new forests and reducing deep ploughing.

    At this point in the process, the scientific part, it was clear that the US would have to make the deepest cuts in emissions, but that it could, with little burden, meet about a third of its treaty obligation by reforestation and by encouraging no-till agriculture.

    The US vice president then was Al Gore. The country was ready to support a climate change treaty.

    Then the scientists stepped aside and the international politics began, and that was dominated by some of the very same people who are now doing the anti-GMO biodiversity process. They insisted that the US could not count reductions in greenhouse gas emissions achieved by either forestry or agriculture, only from reduced fuel burning. That, of course meant that the US burden of the treaty, already the highest of any country, would be increased by an additional fifty percent. (The other thing that made the treaty unpopular was that emerging countries made no commitment to ever curb emissions.)

    Everyone knew that the Kyoto reduction goals were largely symbolic. The main purpose was to get the nations of the world to cooperate on a first step that they could build upon. By driving the world’s largest emitter out of the treaty the anti-GMO radicals condemned the Kyoto treaty to irrelevance.

    Now move back to biodiversity. In most of the world, the biggest threat to biodiversity is destruction of habitat. Clear a patch of forest and the biota that live there will disappear. A large fraction of forest clearing is done to open up land for agriculture. So the policies that make agriculture less efficient are the policies that encourage habitat loss. The second biggest threat to biodiversity is invasive species. Last week’s news included, for example, a proposal to block the Chicago River to prevent Asian carp from reaching Lake Michigan, where they might reduce biodiversity by eating local species to extinction.

    I don’t think it’s very hard to see that these are problems which need international solutions. Something analogous to CITES (Convention on International Trade in Endangered Species) is needed for invasive species. But these are not easy matters. They involve a lot of hard diplomatic and technical work. When the diplomatic representatives from the various countries allow the process to be captured by the anti-GMO groups, those groups are simply not motivated to do that kind of work.

    Gavin, there has not been a single species anywhere shown to have been harmed by GMO agriculture. (Unless you count the harm by definition, where someone declares that a transgene is some sort of pollution.) All that effort from 1992 until now has produced a protocol that solves a non-problem, or at best, a vaguely defined potential problem. Meanwhile, the two major factors that reduce biodiversity have had no diplomatic attention. And, just as with Kyoto, the United States is no longer even participating.

    What has to be done is we have to insist that our efforts to solve the world’s environmental problems be based on science, not ideology.

    • gavin venn
      November 1, 2010

      Charles,

      I can’t pretend to know about the politics around Kyoto. But you seem to be making a direct connection between the withdrawl of the US, and enviro groups’ anti-gmo stance?

      “(Unless you count the harm by definition, where someone declares that a transgene is some sort of pollution.)”

      why would it not be contamination?

      “What has to be done is we have to insist that our efforts to solve the world’s environmental problems be based on science, not ideology.”

      Please give specific example of a science solution that will help solve enviro problems, but is being blocked by US not being involved in protocol?

      • c_rader
        November 2, 2010

        We call something a contaminant if it is in some way harmful. It’s not logical to ignore most genes and single out one gene and declare it harmful for no good reason.

        Pollen contains tens of thousands of genes. One of those genes could be potentially harmful if it produced a trait with a bad result, like a toxin or an undesirable flavor or color, etc. So you could reasonably call that gene a contaminant.

        But consider a gene that expresses a desirable or neutral trait. Why would you call that a contaminant?

        Of course, you can arbitrarily decide that you don’t want that gene and you can call it contamination. That’s what by mean by “harm by definition”.

        Take an analogy from materials science. Suppose I have a container containing a huge number of nitrogen molecules. That’s pure nitrogen. Now suppose instead that there are a very small number of other molecules in the container, some molecules of argon, of carbon dioxide, methane and cyanide. The container is no longer pure nitrogen. I choose these four impurities because three of them are found in normal air, while the fourth is a poison. I think it would be seriously illogical to ignore the cyanide while calling the argon a contaminant.

        If you accept that the earth’s climate is being affected by increased carbon dioxide in the atmosphere, it’s obviously a science solution to burn less coal. If the US had signed a treaty requiring it to reduce its emissions of carbon dioxide, it would be passing laws and regulations to make that happen. This is such an easy answer that I wonder if I misunderstood your point.

  25. gavin venn
    November 2, 2010

    Karl & qetzal,

    “that can happen naturally if you mutagenize and screen enough fish you can make it.”

    Why don’t we have a mutant salmon (mutagenized by people) that has similar growth characteristics to gmo salmon? Surely the non-gmo salmon farmers would have tried to do that?

    This mutagenizing is done by applying chemicals or radition to fish eggs?

    • gavin venn
      November 2, 2010

      Are the International Salmon Farmers Association welcoming gmo technology?

      I get the impression, the industry is interested in breeding ‘better’ fish using conventional selective breeding techniques.

    • Karl Haro von Mogel
      November 2, 2010

      That is probably how the mutagenesis would work. I’m not up on fish mutagenesis protocols but I did it to corn seeds this spring with a chemical mutagen. Point of fact – the outcome of my experiment would be OK to grow on an organic farm. Cray Ironic? Certifiable.

      I can think of a good reason why it would be a bad idea to screen millions of fish – that is a huge undertaking, would cost a ton of money, and be terribly wasteful with a low likelihood of the specific desired outcome. Although it costs $$ to make transgenics, your chance of success for things like this is pretty good by comparison.

    • qetzal
      November 2, 2010

      Hi gavin

      I second Karl’s response. I suspect the main reason is that it would be really, REALLY hard to find a mutagenized salmon that had consitutively upregulated GH as the only novel trait.

      Conventional mutagenesis is random. It hits all parts of the genome more or less equally. You can’t specifically target it to the GH gene (except using GMO techniques, of course).

      If you mutagenize fish at a low level, any given fish gets only one or a few mutations. But then, the chance of getting the desired change in the GH gene is tiny. You’d have to screen millions or billions of fish.

      If you mutagenize at a higher level, there’s a better chance of getting a change to the GH gene, but there will almost certainly be many other changes in every fish as well. Finding one that has the desired increase in GH without having various other problems would be very hard, I think.

      GMO gets around that by letting you specifically ‘mutagenize’ just the GH gene. Even better, it lets you metagenize the GH gene in exactly the way you want to.

      IMO, that’s a compelling reason why GMO can actually be better than conventional methods. You have enough control on the process to get the changes you want, in the places you want them, without getting lot of other changes all over the place that you don’t want and may not even be aware of.

      Of course, that doesn’t show that using GMO to increase GH levels is safe. You still have to consider whether the specific changes to GH have risks. But the same would be true if you increased GH using a conventional mutagenic approach. The difference is that the GMO approach dramatically reduces risk from other unwanted and/or uncharacterized changes.

      That’s why I’ve said preveiously that I don’t think the GMO process per se carries any extra risk. If anything the opposite. All of the risk depends on what changes were made. GMO does give us the ability to make changes that we couldn’t practically make using other techniques, and this is a valid concern, but it’s the nature of those changes that creates the risk.

  26. gavin venn
    November 3, 2010

    My impression of international salmon farm industry is they see mutagenic substances as pretty much negative things, and as such are not much interested in that method.

    The way salmon farmers seem to deal with breeding ‘better’ fish is to use conventional selective breeding techniques, including the use of Molecular Marker Assisted Selection.

  27. gavin venn
    November 5, 2010

    Something i’m struggling to understand:

    The salmon farming industry is distancing themselves from gmo salmon, and there doesn’t seem to be any other reason to introduce this “product” (Aqua Bounty’s words), other than make money. Where is this money going to come from?

    • Ewan R
      November 5, 2010

      Where is this money going to come from?

      The sale of salmon.

      Even if some of the industry backs off my assumption is that Aqua Bounty believe there is at least some interest – when interested parties can produce farmed salmon with lower overheads than those not utilizing the GM tech they’ll either

      a) Sell at parity with the rest of the market and make mo’ money
      b) Sell cheaper than the rest of the market and make mo’ money

      At which point a lot of folk who backed off initially will adopt the technology (and make mo’ money) – while those who remain staunchly opposed will sell their salmon as “GM free” and make mo’ money.

      (One can probably see why I’m a molecular geneticist and not an economist from the above statement)

      • gavin venn
        November 5, 2010

        “Even if some of the industry backs off”

        Which parts of the salmon farming industry are supporting gmo salmon?

      • Ewan R
        November 5, 2010

        I have absolutely no idea, but if GM Salmon aren’t a commercial prospect then the idea that they pose any risk goes away, the fact that a company has invested 10+ years in developing the product suggests that there is at least some interest – people tend not to invest tens of millions of dollars with no chance whatsoever of recouping their investment.

  28. gavin venn
    November 5, 2010

    “people tend not to invest tens of millions of dollars with no chance whatsoever of recouping their investment.”

    Agreed.

    “if GM Salmon aren’t a commercial prospect then the idea that they pose any risk goes away”

    What I’m interested in understanding is who will be running these farms, if not experienced salmon farmers? As you say, AB, must know they have a money maker here.

  29. Ewan R
    November 5, 2010

    What I’m interested in understanding is who will be running these farms, if not experienced salmon farmers?

    Do you have information that supposes experienced salmon farmers wouldn’t be using the GM salmon?

    Even if a large portion of the industry is “distancing” itself from GM salmon this doesn’t mean no experienced farmers are interested (brings to mind GM wheat a little, only the disinterest and fear was such 10 years ago that the idea was shelved until essentially last year – putting wheat farmers about a decade behind others in terms of available technology)

    • gavin venn
      November 5, 2010

      The International Salmon Farmers’ Association arn’t keen. As I understand it, they are the main voice for salmon farmers – but i could well be wrong. If I am correct, then farmers interested in moving ahead with gmo, are going against the industry. Nothing to say they can’t do that, but leaving the fold is a bold move. As I havn’t seen any evidence to say that any salmon farmers are supporting gmo technology, I’m asking questions, because if we have inexperienced fish farmers involved here – that may well affect the risk assesment.

      • Anastasia Bodnar
        November 5, 2010

        Actually it doesn’t affect the risk assessment at all. Every new facility will get a new assessment and every approved facility will get periodic evaluations.

        The question here has nothing to do with economic feasibility. People can try to sell whatever stuff they want. The question is whether AB’s goal of making the modified salmon available is more of a possible risk than is outweighed by the possible benefits.

  30. gavin venn
    November 7, 2010

    “Actually it doesn’t affect the risk assessment at all. Every new facility will get a new assessment and every approved facility will get periodic evaluations.”

    The FDA risk assesment covers gmo salmon that will be sold into USA & other countries?

    “The question here has nothing to do with economic feasibility. People can try to sell whatever stuff they want. The question is whether AB’s goal of making the modified salmon available is more of a possible risk than is outweighed by the possible benefits.”

    What are the benefits? & who are the beneficiaries?

  31. qetzal
    November 7, 2010

    Hi gavin,

    What are the benefits? & who are the beneficiaries?

    Why does that matter? I hope you’re not suggesting that AB should have to convince national/international regulatory bodies not only that these salmon are sufficiently safe, but also that they provide enough benefit to the right people.

    Obviously, AB thinks there are benefits that people will pay for, so that they can ultimately make a profit. They may or may not be right, but the only people they should have to convince in a case like this is their potential customers.

  32. c_rader
    November 7, 2010

    What are the benefits? & who are the beneficiaries?

    That’s not a fair question. In a world of free people, you can reasonably ask whether some action harms others unfairly. You can’t reasonably ask whether some action is sufficiently beneficial. In a world of free people, I can decide to play chess, even though it benefits nobody.

    If you want to make arguments against the GMO salmon, those arguments have to be of a kind that demonstrates some sort of harm. Even that may not be enough, because we’ll have different ideas about what constitutes harm, and about whether some harm is balanced by benefits.

    • Ewan R
      November 8, 2010
      What are the benefits? & who are the beneficiaries?

      That’s not a fair question.

      It is a fair question (particularly as Anastasia brought up the risk vs benefit) – so long as the answer has no impact on whether or not GM fish are commercialized – it isn’t really a fair question (or perhaps meaningful/useful question would be better) in the discussion on regulation per se but in a broader it is a perfectly fair question I think. (it may even be fair in terms of talking on regulation – part of regulation is looking at cost/benefit analysis – if all we account for is costs (risks) but do not look at the benefits then even a miniscule risk tips the balance in favor of not allowing the product – is such a case one should have to at least demonstrate a minimal benefit to counterbalance the miniscule risk involved (what would a response be without contradicting itself in the first paragraph…)

      As such, my own personal stab sans vast amount of knowledge is…

      The beneficiaries of the technology are two fold – the farmers who adopt the technology – they benefit from having reduced production costs via the route of faster time to market on production Salmon – running a Salmon farm clearly costs money, and a lot of this will be in terms of fixed costs (salaries, cost of running buildings etc) – if you can turn around Salmon in say 6 months as opposed to 12 (pulling figures out the air for the sake of demonstration only) then you cut your fixed costs per lb of Salmon in half (which is a good thing ™).

      The other direct beneficiary is the inventors of the product – they make money selling to the farmers, economically this is a good thing (people do love to rail against corporations etc – but to an extent having a corporation make money has to be a good thing as it keeps a bunch of people in employment, medical insurance and the like – and assuming the aquabounty scientists are anything like scientists working on other GM products in industry it keeps a bunch of people working on what they love to do)

      There are also potential benefits to others – consumers *may* see cheaper Salmon (not a given – price may simply be at parity with other farmed salmon with the difference in production cost going into the farmers pocket), a drop in price *may* push farmed salmon prices down thus reducing the demand for wild caught salmon thus preserving wild salmon populations (I don’t find this enormously likely – but given that we’ve discussed miniscule risks ad nauseum above I don’t think it is particularly unfair to bring up potential benefits that are unilkely or even highly unlikely to come to fruition)

      Which is all I can think of right now, but that’s only because I’ve just had the one coffee so far today

  33. gavin venn
    November 11, 2010

    “The beneficiaries of the technology are two fold – the farmers who adopt the technology ”

    The International Federation of Salmon Farmers arn’t keen on AB’s technology – so it’s unlikely AB, developed their own version of salmon to meet the needs of this group- if they did, they didn’t listen too well. If we look at why this group arn’t keen, we can see it’s because they feel their customers’ don’t want it. However, with FDA approval, the door opens for AB, to present their technology in a favourable light to developing countries. Once the technology is being implemented in developing countries, where is the protocol to ensure there is any risk assesment or monitoring at all? The FDA, is opening the door to more than the US market here.

    “they benefit from having reduced production costs via the route of faster time to market on production Salmon – running a Salmon farm clearly costs money, and a lot of this will be in terms of fixed costs (salaries, cost of running buildings etc) – if you can turn around Salmon in say 6 months as opposed to 12 (pulling figures out the air for the sake of demonstration only) then you cut your fixed costs per lb of Salmon in half (which is a good thing ™).”

    On paper, this may well be true, but it doesn’t take into account problems with AB’s new ‘product’ (continue to be astounded that these fish are referred to as product). You’re assuming everything works like clockwork, but, usually when dealing with farming – with living systems, that’s not the case. There is also the question of start-up capital, that would need to be recovered. If US farmers wanted to use AB’s technology they would presumably have to set up inland fisheries to get their approval from the FDA, as they couldn’t raise these gmo salmon in their usual sea enclosures – so new, start-up ventures would be necessary. But, let’s say you’re right, the technology is so well considered, the initial risk assesment and further possible pleiotropic effects with the gmo so well covered, and the implementation so efficient and cost effective, that all production costs for AB salmon, are eventually cut by half. This is afterall AB’s sales pitch – salmon in half the time. I’ve already gone into why imo, the welfare and health of these AB salmon are being compromised. This compromising imo, will effect the quality of the AB salmon – in terms of it’s taste and it’s potential to benefit the health of people eating it.

    So, it remains to be seen whether salmon farmers who embrace this gmo technology, will actualize AB’s claims of reduced time to market. If they do, they will benefit financially, once their own investment costs have been recovered, and only if they find a receptive enduring market for their gmo salmon. AB will benefit by selling their technology – they have to do this to recover their investment – so they also need receptive enduring markets.

    “but to an extent having a corporation make money has to be a good thing as it keeps a bunch of people in employment, medical insurance and the like”

    Yes, clearly the USA, benefits economically from approving and promoting gmo technology.

    Do the risks outweigh the benefits – and remember, these are global risks, – my answer is – no way near.

  34. c_rader
    November 11, 2010

    Again, Gavin, you are arguing that the FDA ought not approve the GMO salmon for a set of reasons. Your reasons sort easily into two sets. Set 1 contains the reasons that you don’t think there is much market for the product (even if it makes you nervous to call a fish a product.) Set 2 contains the reasons that you think there are potential harms to others (including the fish themselves).

    As we have pointed out before, this is the free world. It would be completely unreasonable for the FDA to deny the right to produce a product because, in its estimation, there is not much demand for the product. It’s simply not the business of the government in a free country to decide what people ought to want.

    This leaves the matter of whether the product causes harm to innocent others, a completely proper function of government regulation.

  35. Ewan R
    November 12, 2010

    The International Federation of Salmon Farmers arn’t keen on AB’s technology – so it’s unlikely AB, developed their own version of salmon to meet the needs of this group- if they did, they didn’t listen too well.

    So because the IFSF isn’t keen that means that automatically all Salmon farmers at all future points in time won’t want to use the technology?

    10 years ago the bulk of wheat farmers (and associations thereof) were leary enough of GM wheat that Monsanto backed the hell down and dropped wheat as a GM prospect – conditions have changed, wheat farmers see the obvious benefits enjoyed by farmers growing GM crops, and are now 10 years behind in terms of technology (hopefully lessons learned in the production of GM crops will at least cut down the development phase and mean farmers predominantly only have to await regulatory approval for Ag trait containing crops (HT, IR) – yield type traits however, which are still in development for all the main GM crops, is going to be severely lagging.

  36. Zhenyu Shen
    April 11, 2011

    Thank you, Anastasia.
    I like this post.
    Do you have information about the GM salmon’s history?

  37. Anastasia Bodnar
    April 11, 2011

    Thank you, Zhenyu! I worked very hard on this post so I am happy to have someone appreciate it :)

    I don’t know much of the history of this particular GM salmon, though, unfortunately.

  38. Zhenyu Shen
    April 12, 2011

    Two questions:
    1. what position/locus on the chromosome is the opAFP-GHc2 fragment integrated?
    2. How did they screen fish to lose bla gene carried in the vector?

  39. Zhenyu Shen
    April 12, 2011

    One more question:

    They said “The founder animal from which the AquAdvantage Salmon line derives was a mosaic, transgenic female (EO-1) generated in 1989 by micro-injecting a linearized form of opAFP-GHc2 into the fertilized eggs of wild Atlantic salmon.”
    And they mentioned later there are two forms, alpha form and beta form.

    Does it mean EO-1 have both alpha form and beta form?
    How are the two forms organized on the chromosome?

  40. Zhenyu Shen
    April 12, 2011

    I also remember their fish have only one insert copy. So it means only chromosome has the insert. So, only 1/2 (breed with wild type)or 3/4 (breed with the fish with one insert copy)of their progeny grow faster. Why did not they use fish with the insert in both chromosomes?

  41. Anastasia Bodnar
    July 16, 2011

    I came across an interesting article about GM salmon: GM Fish Study Raises Red Flags. The article is about the following journal article:

    Moreau. D, Conway. C, Fleming. I, Reproductive performance of alternative male phenotypes of growth hormone transgenic Atlantic salmon (Salmo salar), Evolutionary Applications, Wiley-Blackwell, July 2011. (Press release)

    The Moreau et al. show that male salmon transformed with a growth hormone gene have reduced fitness and reduced reproductive fitness compared to wild type fish, but that the GM fish were still able to reproduce nonetheless. In the abstract and in the press release Moreau et al. talk about the risk of releasing GM fish that can reproduce.

    However, as I discuss in this post, only sterile female triploids will be used by AquAdvantage. This information is easily available. Yet, the author of the above article and Moreau et al. somehow weren’t able to find this information. Did they not look? Or did they just know that their research would get more press if they could tie it to some fear factor?

  42. Charles M. Rader
    July 17, 2011

    The press release mentions the Trojan gene hypothesis:

    One of the key concerns about a transgene escape is the “Trojan gene effect”, caused when a GM fish outcompetes or reproduces equally against wild rivals, however if the resulting offspring are genetically inferior this could lead a species towards eventual extinction. Until now there is no empirical research to demonstrate the ability of transgenic Atlantic salmon to breed naturally and infiltrate the wild gene pool.

    What is the Trojan gene hypothesis? It says that if a gene simultaneously makes male fish more sexually successful than wild type, and less fertile, the overall population can spiral down to extinction.

    But the data in this paper show that in the case of AquAdvantage transgenic salmon, the males are both less sexually successful than wild type and also less fertile. Obviously, this is the opposite of the Trojan gene hypothesis. It might be taken as a reason why the escape of transgenic salmon into the wild population might not matter so much. (I don’t seriously advocate that!)

    Anyway this probably doesn’t matter anyway. On June 15, the US House of Representatives accepted an amendment to the bill that funds FDA. That amendment prohibits FDA from approving genetically modified salmon. It’s highly unlikely that the US Senate will delete this prohibition.

    I was seriously shocked to see how this happened. The House of Representatives was virtually empty. Congressman Don Young of Alaska introduced his amendment, and it passed by a voice vote, with probably less than ten Congressmen voting. Young, explaining the reason for his amendment, said nothing about food safety – the normal basis of an FDA approval decision – but simply that Alaskan salmon fishermen should not have to face competition from “unnatural Frankenstein fish”.

  43. Eric Baumholder
    July 17, 2011

    The risks of GM salmon are very obvious, and very real.

    Legislators from the state of Alaska have precisely identified the core issue. GM salmon could out-compete wild salmon (on the basis of producer cost and consumer price), thereby damaging Alaska’s wild salmon industry.

    Yes, indeed, there is a financial version of the Precautionary Principle.

    • Charles M. Rader
      July 17, 2011

      Actually Eric, I disagree. I recently saw in a local fish market two competing products, Alaskan wild salmon for $26.95 per pound, and farmed Atlantic salmon for $6.95 per pound. Obviously that represents what the market would bear on that day, not just cost of production. Today in the same fish market the trice of Alaskan salmon is $16.95/lb and the farmed salmon is still $6.95/lb. A taste test will usually show that the wild caught fish is better tasting and I think it also has a larger amount of omega-3 oil content than farmed salmon. My guess is that the Alaskan fishermen will be more constrained by how many fish they can safely catch without decimating the stock than by the price of a competing inferior product.

      The Alaskans have also pushed hard to require GMO salmon to be labeled.

  44. Eric Baumholder
    July 18, 2011

    Charles,

    That’s an interesting analysis. It suggests that, in this instance, the Alaskan legislators don’t know where their political interests lie (protecting the Alaska salmon industry), and their constituents (salmon industry) don’t understand where their financial interests lie (losing market share to Aqua Bounty).

  45. MaryM
    December 21, 2012

    I know this is an old post, but just in case it heats up with the new approval stuff–here’s an item I needed to use already today about the “trojan gene” claim. Even the scientist whose work it was says that it’s wrong to use his model on this fish.

    http://latimesblogs.latimes.com/greenspace/2010/11/ge-salmon-foes-cite-trojan-gene.html

    Not so, says the author of the Trojan Gene hypothesis, William Muir, an animal science professor at Purdue who has been yelling loudly, to little effect so far, that his work is being misrepresented by the GE salmon’s opponents….

    On Sept. 20, Muir told the FDA Veterinary Medicine Advisory Committee evaluating the GE salmon that “the data conclusively shows that there is no Trojan Gene effect as expected. The data in fact suggest that the transgene will be purged by natural selection. In other words the risk of harm here is low.”

    He supports the salmon.

  46. Jack
    March 7, 2014

    i don’t eat it

    • Anastasia Bodnar
      March 9, 2014

      Well, Jack, since these salmon aren’t on the market yet, you couldn’t eat them even if you wanted to.

      • Jack
        March 10, 2014

        oh

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