The AquAdvantage salmon has captured the attention of the news, politicians, scientists, and activists, and now you have a chance to learn more about it – directly from the people who developed it. AquaBounty Technologies developed the genetically engineered Atlantic salmon by inserting a salmon growth hormone gene with a promoter from ocean pout that causes the salmon to produce growth hormone year-round. This results in a fish that grows to full size in about half the time of wild salmon.
For an excellent backgrounder on the AquAdvantage Salmon, see this article by Anastasia Bodnar.
AquaBounty Technologies is currently seeking FDA approval for producing the salmon to sell in the United States. This has attracted the attention of competing markets, such as the Alaskan salmon fisheries and their representatives in government, as well as various anti-genetic engineering organizations such as Food and Water Watch and the Center for Food Safety. If approved, the AquaAdvantage salmon would be the first genetically engineered animal intended for human consumption.
The FDA has released its draft environmental assessment, stating that their preliminary finding is that the AquAdvantage Salmon will have no significant impact on the environment. Public comments are being accepted until February 25th. There are a lot of competing claims about these fish, and some have made up their minds about it, however, you now have an opportunity to have your questions about it answered by the developers directly.
I talked on the phone with the CEO of AquaBounty, Ron Stotish, Ph.D., and he is willing to participate in a discussion right here on the Biofortified Blog, and answer your questions about it. If you have aching concerns, curious questions about intimate scientific details, or want to hear about their future plans with these fish, put your questions in the comments below. In a few days, we will assemble the most thoughtful and interesting questions and send them to AquaBounty and he and his team will answer them here on the blog, and then stick around for the discussion.
So, what do you want to know about AquAdvantage Salmon?
What do you want to know about AquAdvantage Salmon?
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Biofortified 
I would like him to address any animal welfare issues from expedited growth? How does this compare to e.g. Belgian Blue cattle? I’ve read that the rate of malformations are comparable to wild type but is that the only measure of animal welfare or can some behavioral changes be monitored for example? The environmental benefits of land-based production look promising but I suspect that the same consumer that would see that as a positive would also care about the well-being of the fish.
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Anders, according to documents submitted by Aquabounty to the FDA, these GM fish have no fear of traveling new places, and they tend to eat a far more varied diet than wild salmon. They also grow to adulthood in a season and may stay upriver for several years in fresh water streams before migrating to the ocean. I expect that we should be worrying about the impact upon the biodiversity of our fresh water streams in Northern Europe and North America before we concern ourselves with the welfare of individual GM salmon. These salmon (according to Aquabounty’s own documents) use dissolved oxygen at an extraordinary rate, and huge salmon inhabiting fresh water streams for several years will certainly have large impacts on the oxygen content of the fresh water streams. So don’t cry for me Argentina – if fish have a self-aware sense of comfort and security, it’s not these GM fish whose well-being we should consider.
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Kirby, Please do not hijack my question with your own unrelated concerns.
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Sorry.
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Karl:
The 391 pages of documents I have are on a backup drive. I’m getting it out now and will begin a search for you.
Kirby
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The current regulatory assessments for inland tank facilities do not take into account certain risks that are more likely if the salmon were to be raised in ocean-based aquaculture facilities. However, many consumers are concerned that given the way regulatory approvals work, the current approval will eventually be the only major regulatory event and eventually ocean-based facilities will operate growing AquAdvantage salmon. Most current non-tank aquaculture (i.e. in the ocean) is currently poorly managed and it does not seem likely to me that this is going to change. Farmed salmon is particularly poorly managed. What is AquaBounty doing to ensure that the AquAdvantage salmon will always be raised in inland tank systems? Alternately, should a producer pursue sea-based facilities, how will AquaBounty maintain public trust during the regulatory process and once facilities are in operation?
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The conditions of use stipulated by the FDA for the current application that is under consideration is for freshwater culture in contained, land based culture systems. In addition, AquaBounty has publicly stated that the GM salmon will not be reared in sea cages. The current application that is before the FDA contemplates only one grow out site, an inland location in Central America, 100’s of km from the sea, in which the salmon will be confined to a culture system designed with 21 individual containment measures. The salmon will be sterile and all female, and cannot establish reproductively active self-sustaining populations, nor can they breed with other fish. In addition, there is a natural (ecological) thermal barrier in the form of lethal water temperatures downstream from the facility, which would prevent live GM salmon from reaching the sea. This is the ONLY grow out site under consideration in the current FDA application. If an alternate site is proposed, another (supplemental) application must be filed by the FDA, and the site inspected by competent authorities designated by the FDA. Under the current conditions of use, it is very unlikely that the authorities would permit sea cage farming of the GM salmon. So speculative discussions of “someday the GM salmon being grown in sea cages” is precisely that……speculation. AquaBounty believes that land based, contained culture of their GM salmon represents a sustainable, environmentally friendly alternative to traditional sea cage farming of salmon.
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Rachael, has it occurred to you that the FDA has no regulatory power over either Panama or Canada? Once this approval has been granted, these salmon will show up all over the world. Remember, not all the salmon are female – up to 10% will hatch out male; and breeding is a certainty. Raise them in the ocean? If these things are approved, they may become the only things IN the oceans.
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Aquabounty’s documents submitted to the FDA confirm that up to 10% of the Canadian salmon eggs will hatch out male, so the fish can indeed breed in a hatchery and spawn. The FDA has no supervisory jurisdiction over either Panama or Canada, so it cannot guarantee or even suggest a guarantee that the salmon will not be introduced into the wild. GIVEN that breeding AquaAdvantage salmon will show up in the World’s waters; given that these salmon have been found to be very aggressive, will stay upriver for up to several years, and are capable of depleting fresh water streams of biodiversity as well as oxygen; my question is:
What steps has Aquabounty taken to assure us that the World’s fresh water streams will not become stinking, red toxic pools from the anerobic bacteria that will come to infest the life-denuded, deoxygenated streams?
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Kirby, can you point to where it gives the 10% figure in the documents submitted to the FDA? I would like to include some form of your question, however, I would need to see the source for this claim first. According to the breeding strategy outlined in the FDA documents, this is not possible.
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The figure is 5%, not 10% – my apologies.
I refer you to the FDA Preliminary Analysis for the FDA September, 2010, public hearings. AquaBounty’s claim of less than 1% of eyed eggs hatching as diploid salmon was discussed in this preliminary analysis, which concluded that at that time the rate was closer to 5% “or higher”.
I also refer you to FDA analysis that states that any diploid salmon at their Panama facility are easy to recognize because their growth rate is much higher than the triploid, AquaAdvantage salmon. Aqua Bounty refers only to the triploid GM salmon as AquaAdvantage. Since the diploid, breeding salmon are not triploid sterile, they are apparently not considered part of the application process for AquaAdvantage Salmon.
The FDA removed a graphic from their preliminary analysis draft showing that at one time they considered the issue of intentional introduction of diploid, breeding GM salmon into a wild environment. This graphic was almost immediately replaced with a nearly identical graphic, and the issue was removed from consideration. Please contact me should you wish to see a copy of this graphic.
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You also stated that the 10% figure (now adjusted to 5%) was the number of male fish, not diploids. According to the breeding plan, male fish would not be possible. I have also skimmed through the FDA documents and found a reference to 5%, but that was describing a batch-specific metric. I discussed the issue of the percentage of diploids with Ron and he indicated a much smaller number, and described the process by which accidental diploids are weeded out. So I could definitely put together a question that addresses this question.
I am interested in getting reasonable questions answered in the interview, so I want to narrow it down to something that will provide people with more info, not have a back-and-forth about specific percentages removed from the original context. Is there perhaps a way you could word your question that would be more information-seeking?
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Karl:
I intentionally misspoke for this site when I called them “male fish”, because AquaAdvantage Salmon are known to be all sterile females; and it was my intention to call attention to the fact that a certain proportion of eyed-eggs (FDA says 5% or more) will hatch as fertile diploid salmon capable of breeding in a wild salmon environment. My remarks are usually brief and directed to my largest scientifically nonliterate audience – my small white dog Kali – and the process of educating the public on triplody versus diplody is usually just too much to bear. I’ll be good from now on, now that you’ve called me on it. Diploid hatchlings (FDA says 5% or more, and says that Aquabounty is misleading and possibly deceitful in continuing to state 1%) can be either male or female. Triploids are all female and all sterile. AquaAdvantage Salmon can’t be male – by definition. The diploids (male or female) do, however, contain the AquaAdvantage gene construct which allows them to grow into salmon plus. Triploidy (as in AquaAdvantage Salmon) is a genetic defect which limits the robustness of vertabrates. A deleterious mutation, so to speak. When a “diploid” hatches, it does not bear this genetic misfortune and therefore grows much bigger, much faster, is more aggressive, eats a more varied diet, and travels further and faster than triploid salmon can manage – triploid salmon being genetically defective, you know. Any males that hatch (according to the breeding plan) are diploid mistakes to be weeded out. When Ron speaks of AquaAdvantage Salmon, I get the impression he is talking strictly about triploid females by definition. The “breeding plan” will make it impossible to have male fish because all the diploids (male or female) will be “weeded out”. Any eyed-egg that hatches as a diploid can be either male or female and is likely fertile. Any diploid that hatches will also grow faster, grow bigger, be more aggressive, and outcompete any triploid salmon in the tank and any wild salmon brought in for betting purposes.
How much incentive does a fish farmer have to “weed out” the biggest, fastest-growing fish on his farm and pile them up and burn them? Heck, I’d take some home and put them in my pond! I don’t want to carp on it, but the FDA (being in Washington D.C.) will have nothing to say on the matter of diploid fish gone wild – nor will Ron Stotish, being in Massachusetts.
The 5% or more figure is from the FDA preliminary analysis wherein they criticized Aquabounty for being at best misleading and possibly deceitful in continuing to state that the rate of diploid fertile salmon (male or female) hatching from their eyed-eggs to be 1%. There was no “batch specific” criteria attached to it when I read it. I checked it a few minutes ago – still isn’t.
The process of “weeding out” the diploids is exactly what I consider the whole problem to be. There will be diploids. The diploids will be fertile. The diploids are huge even compared to AquaAdvantage Salmon size, more aggressive, and quite probably have more wander-lust in their eyes. It is easy to weed out the fertile diploids – simply look in the tank and pull out those huge, mean suckers that have eaten all the food! Then drive down to the ocean and dump them in (what a waste!), or put them on a cargo craft and fly them up to a ritzy restaurant on the East Coast. Hmmm. Diploids=profit. Hmmm. FDA in Washington, fish in Panama. Hmmm.
When (not if) someone becomes determined to introduce diploid, fertile GE salmon into a wild salmon environments, who you gonna call? The FDA? Mr. Stotish? Oh, by the way, don’t eat one of those diploid monsters you catch in the Trinity River ten years from now without first sending a check to Aquabounty.
I’d like to frame the question you are asking me to properly frame, but I keep getting distracted. But I think I’ve got a handle on it. Here goes:
Mr. Stotish:
Since AquaAdvantage Salmon are completely sterile and cannot escape into a wild environment nor breed there even if they do escape, will Aquabounty commit itself in a formal, legal document stating that it has absolutely no financial interest in its gene construct patents applying to any diploid, fertile salmon that may appear in the world at any time in the future? Will it limit its patents (and profits) to triploid sterile salmon solely and make no attempt to profit from proliferation of diploid fertile salmon in the waters of the world?
I already know the answer to this one – Ask me! Ask me! Here’s my answer, teacher: “We find no need to limit our company’s profit participation while basing it upon an eventuality which we and the FDA have determined to be an impossibility.”
As I said, Karl, if you want the FDA documents that back up everything I’ve said, just email me and ask. I’m not so much interested in what the breeding plan states; but I am certainly concerned about human nature, the profits to be made at the expense of the environment, U.S. agency actions taken unilaterally but applying internationally, and the fact that I can’t envision a way to buy a nice chunk of Aquabounty to pass on to my kids while leaving them a world worth using the money in.
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Hi Kirby,
When you said that “I intentionally misspoke for this site when I called them “male fish”, because AquaAdvantage Salmon are known to be all sterile females,” you surprised me. I was willing to accept mixing things up accidentally, but to say that you intentionally lied to get attention to issues that concern you is another thing. The purpose of this interview is so that people can learn more about the science and the issues involved, and purposefully misrepresenting the facts detracts from that goal.
Thanks for submitting a question about patents and royalties, I should be able to ask some form of it, because it is an important issue. However, the background for your question, i.e. Monsanto suing farmers for accidental pollination, is not true. There was a lawsuit from organic farmers last year that alleged that they were afraid of getting sued, but could not provide a single example where someone was sued over accidental cross-pollination, so the judge dismissed the case. (See this article for more.)
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The figure is 5% or more in standard conditions, according to the FDA’s preliminary analysis of August, 2010. I adopted 10% as a worst case scenario, since the FDA will only assess impact on the basis of the submitted proposal and will not look into worst case scenarios. In fact, since AquaBounty claimed and continues to claim only a 1% rate of eyed eggs hatching as diploid, breedable fish, the FDA concluded in its preliminary assessment that AquaBounty’s figure is misleading and, possibly, deceitful. The actual percentage is irrelevant, however; because it is my contention that even three diploid, breeding salmon out of 1,000 is too many. The diploid, fertile salmon are easily recognized because they are 10-18% larger at 4 months and could easily be segregated from the triploid population and intentionally introduced into a wild salmon environment. The FDA has failed to assess the capability of diploid GE salmon to breed with existing wild salmon. Ultimately, the diploid, fertile salmon grow up to 3X the size of the triploid AquaAdvantage salmon, and 563% larger than Atlantic salmon. The FDA refuses to publicly consider the issue of intentional introduction, although they are provably aware of it.
The mention that you make of the FDA documents indicating wild breeding to be impossible is due to the FDA’s definition of its job. The agency DOES NOT assess environmental impact with respect to worst case scenarios, i.e., intentional introduction of GE salmon into a wild environment, to-wit. “Sixth, the agency evaluates the environmental assessment associated with the conditions proposed to raise the GE animal.” (See page 15 of “An overview of Atlantic salmon, its natural history, aquaculture, and genetic engineering,” published for the September, 2010 public hearings.) In other words, the FDA is basing its environmental assessment ONLY on the AquaBounty proposal, which defines AquaAdvantage Salmon as strictly triploid. The assessment does not consider the diploid, giant, breeding GE salmon because, strictly, they are not AquaAdvantage Salmon. They are mistakes. There would be a huge commercial motivation to up the percentage of these mistakes, however, due to the much faster growth of the diploid fertile salmon (3x the rate of triploid).
The 5%(or more)diploid-from-eyed-egg figure comes from the Preliminary Assessment of the FDA published for the September, 2010, public hearings. Note that at that time, the FDA included in a draft of their 391-page assessment package a graphic demonstrating that they were considering the issue of intentional introduction of diploid, breeding, GM salmon into a wild environment. This graphic summarized subsequent talking points. The graphic was pulled, and in its place for final publication was substituted a graphic bearing only the issue of “Escape”. The published assessment then completely ignores the issue of intentional introduction. It is on the basis of the FDA considering only “Escape” and not “Introduction” into the wild environment that the FDA has concluded that no reason exists to consider environmental harm from a potential escape of breeding, GM diploid salmon into a wild environment. I quote:
“…it is not necessary to quantify the consequences of the escape, establishment, and spread of GE salmon if the probability of escape leading to the exposure
(i.e., establishment & spread) is zero or close to zero.” (p.59 of 84, FDA Environmental Assessment)
Note that the words “escape or introduction” would be more appropriate; but of course the entire assessment would have to be changed. The FDA has NEVER indicated that there exists little or no possibility of intentional introduction of the salmon into the wild.
Please note that intentional introduction is not considered, because it does not fall under the FDA purview as set forth in the document cited above.
Karl, this whole matter begs for a competent science writer with publication connections to assess and write about it. Are you the one? If so, email me directly and I’ll pull all the documents I’ve got together and help you out. This GE salmon matter is potentially far more harmful than the FDA simply releasing damaging drugs to the public to please its pharmaceutical partners. You can recall bad drugs.
Terrorism, of course, would be a suitable reason to introduce diploid, fertile GE salmon into a wild salmon environment – perhaps this whole show should be turned over to Homeland Security. But there are certain commercial aspects of fish farming (think patents) that would make the replacement of the world’s wild stocks of salmon with a GE salmon particularly profitable. I do not think Aquabounty could profit from such an eventuality because their patents have to do with triploid, non-breeding GE salmon. Other GE salmon-marketers might not be so constricted. Especially when they realize they can make three times the profit for the same amount of work simply by upping the rate of eyed-eggs hatching into diploid salmon.
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Sorry about the unintended post above this last one. I just got to thinking, however, that Aquabounty holds the patents on the gene construct and not the triploid salmon derivative. So even the mistakes – the fertile diploid GE salmon – would be covered by the gene construct patents. Recall the Monsanto lawsuits against farmers whose land was unintentionally contaminated by Bt corn and you’ll realize that replacement of all the world’s salmon – or even a significant portion – by diploid GE salmon could be immensely profitable. You might not ever again be able to eat a bite of salmon without making out a check to Aquabounty.
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I would be happy to look at documents that you have, when I have some more time. Perhaps next week I will have more time. For one thing, it would allow someone to check some specific statements being made about what the documents contain. What would you estimate is the total filesize of the whole collection?
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“… and are capable of depleting fresh water streams of biodiversity as well as oxygen; my question is:
What steps has Aquabounty taken to assure us that the World’s fresh water streams will not become stinking, red toxic pools from the anerobic bacteria that will come to infest the life-denuded, deoxygenated streams?”
I have two questions regarding this. First, you do know how oxygen gets into the water (especially fresh water streams) right? And second, can you please explain how this “depleting fresh water streams of oxygen”-thing works exactly?
thanks
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I would like to ask Mr. Stotish about his previous career exclusively in animal pharmaceuticals. What, if any, was the relationship between your appointment as CEO of Aquabounty in 2006 and the surprising 2006 decision of the Administration of George W. Bush to place the AquaAdvantage Salmon under the FDA’s Animal Pharmaceuticals section?
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Kirby, your comment about Stotish having a career in animal pharmaceuticals would seem irrelevant to most readers, but I’ve followed this discussion fairly closely and your comment seems to be related to a standard complaint of the anti-GMO movement, namely that regulating the salmon as a drug is a way of getting around proper regulatory requirements. So let me take that on directly.
The current laws about what the FDA can and cannot do are inadequate. Even without the GMO issue, there are still lots of food safety issues that FDA cannot address before a problem arises. But the companies who want to market GMO products WANT TO BE REGULATED. They want an FDA blessing. The decision to treat the AquaBounty salmon as an animal drug is the exact opposite of avoiding regulation. It is bending the law to give the FDA some authority which it otherwise would not have. And what truly angers me is that so many of the propagandists know this and still portray it as a scheme to avoid regulation.
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In response to the response of Charles M. Radar to my question for Mr. Stotish:
Of course Aqua Bounty wants the FDA to regulate its salmon! The FDA has no jurisdiction in either Canada or Panama and cannot interfere in Aqua Bounty business once GM salmon production is approved. On the other hand, receiving FDA approval will effectively limit Aqua Bounty’s liability exposure should environmental world-wide fresh water biota catastrophe come to pass. Is the FDA the proper forum in which to address environmental impact? No. The FDA’s concerns are food and drug safety for consumers – not environmental protection for the world.
Charles, we have exchanged texts in the past and you are quite aware of my supportive views of GM technology; so I somewhat resent your attempt to lump me in with the knee-jerk and ignorant anti-GMO movement. As you know, I am trained in GM engineering and an ardent supporter of research into safe techniques by which genetic engineering via viral vectors can improve the overall human quality of life. As you also know (despite the wording of your message which seems to indicate otherwise), none of my concerns about the FDA approval of AquaAdvantage salmon has anything to do with concerns about the food supply or the health of consumers. My concern is for the health of the fresh water streams and rivers in Northern Europe and North America and the biodiversity of our oceans. My concerns are not the concerns of the Birkenstock-wearing, massive-vitamin-C-and-wheat-grass-dose crowd. My concerns are whether FDA approval of AquaAdvantage salmon production will result in toxic red death of Europe and North American’s fresh water streams. My concerns are whether food chains in our oceans will be unpredictably and irreparably damaged by intentional release of diploid, breeding GM salmon stocks into the wild.
You seem to be under the impression that ‘bending the law’ by the Aqua Bounty/FDA cabal is appropriate in order to allow the FDA to have a measure of authority. My question is: What “measure of authority” are you talking about? As you know, the FDA has no authority on Prince Edward Island nor in Panama – the offshore production facilities of Aqua Bounty so reminiscent of Dr. No’s island of evil. The FDA “measure of authority” is largely non-existent for Aqua Bounty’s production of GM salmon. In fact, there is no law at present which prevents Aqua Bounty from proceeding on its own with its plans to produce and market these fish. There would, of course, be potential consumer liability and international liability which would devolve directly onto Aqua Bounty. The sought-after FDA approval of AquaAdvantage salmon production will be, as you say, a “blessing” – the blessing of liability limitation identical to that received by pharmaceutical companies receiving FDA approval for drugs which have been exhaustively researched and thoroughly subjected to animal and human trials. Are you aware of any exhaustive empirical trials undertaken by Aqua Bounty in its attempts to measure and/or reduce potential harm to consumers? Any evidence that Aqua Bounty has attempted to predict or measure potential environmental impact? I am aware of some, and it was presented to the FDA by Aqua Bounty and available to the public up to the last set of public hearings on the matter. Aqua Bounty submitted material which showed conclusively that GM salmon mature much faster and grow much bigger than native salmon, as well as staying not one but several years in fresh water biomes where they would be the biggest and baddest animals in the food chain, using massive quantities of oxygen while depleting fresh water streams of same. The capacity for displacement of wild salmon stocks by GM salmon is high. Aqua Bounty’s documents indicate that GM salmon eat a far wider variety of foods than wild salmon, while at the same time being much more aggressive in their foraging than wild salmon. To top all this off, GM salmon have apparently had an internal switch shut off which keeps them from venturing into unfamiliar territory. GM salmon have no fear of new places. Aqua Bounty’s own documents make it clear that should breeding stocks of diploid GM salmon (up to 5% of the GM salmon are diploid, according to these documents, and can therefore breed) find their way into a wild environment either accidentally or on purpose, the potential for environmental catastrophe is unknown.
Of course GMO companies want the blessing of the FDA! Up until now, GMO companies have been concerned exclusively with modified vegetation; and their concerns have been with respect to consumer health – not environmental health. There are many issues of food safety that are appropriate to address in GMO; and the FDA is the appropriate forum in which to address those food safety issues. None of those issues is appropriately addressed in the FDA’s veterinary pharmaceuticals branch, however. We are not concerned about the effect on the poor salmon that their genes are modified – any more than we are concerned about the health of cows injected with massive doses of testosterone. The FDA’s purview revolves strictly around consumer health and safety. The FDA is NOT the appropriate forum in which to address the issue of potential environmental impact of a newly created, aggressive salmon which may harbor the potential to destroy the food chain in the world’s fresh water environments and decrease biodiversity in the world’s oceans.
You state: “… there are still lots of food safety issues that FDA cannot address before a problem arises.” My point is and has always been that lacking any food safety issues for the AquaAdvantage GM salmon (and, indeed, I am aware of no evidence that these salmon have any food safety issues beyond those of wild salmon), the proper forum for regulation of this new type of animal is the EPA. Only the environmental Protection Agency is qualified to prepare an appropriate Environmental Impact Report – something that the FDA is not qualified to do in spite of its white-washed ‘environmental assessment’ which seeks to give the impression to the public that environmental issues have been considered. It is this ‘white-wash’ I was alluding to in my question to Mr. Stotish. In point of fact, certain environmental issues have been intentionally obscured by the FDA in order to encourage public acceptance of the GM salmon. I have copies of FDA documents which conclusively demonstrate that the FDA has in the past and continues to sit on the issue of intentional introduction of GM salmon into wild environments. The issue was raised in a single draft of the initial FDA report in 2010 (of which I have a copy), then immediately removed prior to publication of the report. This unremarked removal of the issue – an issue the FDA knows to exist but which it has chosen to actively hide from the public – is proof that the FDA is acting inappropriately and possibly illegally. Your remark about “bending the law” could be more accurately labeled “fraud”. I have come to the reasonable conclusion that the FDA has buried this issue for one reason only – to avoid honestly addressing the issue in their environmental assessment – an issue that if raised would possibly trigger a nearly automatic EPA review. At the least, such an EPA review would likely result in a finding that approval of GMO animal production should be subject to an international forum on environmental impacts.
You are incorrect to state that current law as to what the FDA can or cannot do is inadequate. The FDA is, in your own words, “bending the law” here in order to do something that it is not charged to do – assess the environmental impact of a potentially hazardous new animal which will most assuredly find its way into the world’s waterways. I know that this last sentence is a matter of my opinion, but the low probabilities of the GM salmon escaping into a wild environment to breed cited so cavalierly by the FDA must be measured against the potentially catastrophic consequences of such an eventuality. A low probability does not equal low potential damage. We do not cross a quiet street blindfolded even though the probability of harm is low. The potential consequences of harm are far too great. The FDA has buried the issue of intentional introduction altogether; and they worded their so-called environmental assessment in such a manner that “low probability” equals “minimal harm”. The FDA is putting a blindfold on the world and telling it to go ahead and cross the street – there’s hardly any chance at all of harm!
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Kirby, I was quite careful to not say or imply that you were dishonest or ignorant.
And I know nothing about your background in genetic engineering beyond what you said in this comment.
The previous discussion between us was in a series of comments on a Yahoo bulletin board. My memory is that besides yours and mine, there were dozens of other comments, many of which were false or silly. I can’t remember whether you criticized any of the silly comments or not. Of course, you had no obligation to do so, but it adds to credibility if you discourage distortions.
I have one comment about your remarks above. You wrote the Aqua Bounty/FDA cabal , implying that somehow there is collusion to benefit the company. Kirby, I first heard about this project 17 years ago. If there has been any inappropriate influence of FDA by Aqua Bounty, they should get their money back! This is a tiny company which was, a few years ago, so close to bankruptcy that they had to give away a controlling interest to get enough money to keep going. Your concerns about the possibility that the future of these fish may endanger the environment is worthy of the most serious consideration, but it is possible to disagree with you without being corrupt.
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Charles:
My use of the words “Aqua Bounty/FDA cabal” is meant in the sense defined in Wikipedia: “A cabal is a group of people united in some close design together, usually to promote their private views or interests in a church, state, or other community…”. Aquabounty and the FDA have worked very closely together on this matter since it was assigned to the FDA in 2006. I do not find any reason to regret the manner in which I referred to their cooperation.
You are correct – most of the Yahoo forum comments were uninformed, but they weren’t silly. Ignorance is rarely silly, unless one is of a cruel nature and is prone to laugh at human deformities and situational maladies. Is it possible that the comments of the public remain uninformed because there has been a cooperative effort to shape the public perception based on emotional reaction and without regard to science? Of course there has! This is not due, necessarily, to the fault of either the FDA or Aquabounty. The environmental movement has long been typified by knee-jerk radicalism and a tendency to poke its own eyes out to avoid seeing the obvious. The FDA, however, has clearly done its part to obfuscate matters – otherwise, why call their document an “environmental assessment” when it assesses only the propogation proposal put forth by Aquabounty? Would it not be more accurate to label that document a “proposal assessment without environmental consideration”? As to Aquabounty itself, the company was quite pleasant with me upon my initial contact. With my first hard question, however, Aquabounty hung up on me and will not return my calls. It’s a shame that fair questions can render one persona non grata, but that’s the way it is with Aquabounty, unfortunately. Aquabounty will not abide difficult, probing questions.
And yes, it is indeed possible to disagree without slinging allegations of corruption. Unfortunately, I got a glimpse – more than a glimpse, really, I have copies – of the FDA graphic demonstrating that it was considering the issue of intentional introduction before it pulled the graphic from its web site and redefined its legal role of “environmental assessment” to include only those conditions of propagation set forth in the Aquabounty proposal. I also read their initial preliminary analysis and supporting documents stating that Aquabounty was at the least being misleading and quite possibly deceitful in reporting the percentages of eyed-eggs hatching out as breeding diploid monster-salmon (if they’re 5x the size of Atlantic salmon and 3x the size of giant AquaAdvantage Salmon, they are monsters). And I also saw everything quickly change – the FDA’s role in assessment was redefined to exclude the potential for environmental catastrophe, and the public hearings were scheduled and announced late on a Friday evening to begin the next Monday morning and last for no more than three days before approval would be granted. An approval that was widely considered to be pro forma. Typical types of behavior when the fix is in.
I don’t make allegations of corruption lightly, Charles; and I’ve never actually made any allegations of corruption in this matter. I do point out, however, that the FDA’s act of issuing an “environmental assessment” that does not assess the potential environmental impact of GE salmon production is a whitewash. Is a cabal whitewash in and of itself corruption – or is it merely evidence of corruption? These are questions best left to a semanticist. Or a Justice Department investigator.
The question that raised this discussion, Charles, was merely one I wished to ask Mr. Stotish: What, if any, is the relationship between your appointment as CEO of Aquabounty and the FDA assignment of GE salmon production to its veterinary pharmaceuticals division during the later years of the Bush Junior administration?” I did not mean to imply the possibility of corruption with this question. The proximity of appointment and assignment, however, does raise issues of cronyism and the old boy network. I should think Mr. Stotish would wish to settle and put to bed the appearance raised by the unfortunate timing of the FDA assignment of GE salmon to its veterinary pharmaceuticals division at the same time that Aquabounty appointed a CEO with a previous career in – you guessed it! – veterinary pharmaceuticals. I thought perhaps Mr. Stotish would like to publicly reflect on the acquaintances he has long had with personnel in the FDA’s veterinary pharmaceuticals division and talk about all the warm friendships he has formed there. I would like to see a public discussion of those relationships he has formed and the potential conflicts of interest which an uninformed public might dream up out of the blue. I should not be the only person asking this question, but I’ve heard that journalism isn’t what it used to be – so apparently I’m alone in the wilderness.
You surprise me, Charles, and I should not have to tell you that it is not up to me to advise Aquabounty to ask for its money back from the FDA. I do not have a 17-year knowledge of Aquabounty’s dealings with the FDA; and I do not know of any such shenanigans. Perhaps you can help me here, though, Charles. Do you recall the month in 2006 during which Mr. Stotish was appointed CEO of Aquabounty, and can you give me the month the FDA assigned the AquaAdvantage proposal to its veterinary pharmaceuticals division?
I apologize for using the phrase “Bush Junior” in referring to our former President to distinguish his Presidency from that of his father, but “Bush Lite” sounds too much like “Bud Lite”, and sounds disrespectful, even though our former President was quite fond of beer in his day (and nights).
The bottom line? No Environmental Impact Report has been appropriately addressed, and there is simply too much potential for commercial abuse of the Aquabounty patents (not to mention potential for worldwide environmental catastrophe) to allow them to be released on the world at this time.
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Charles:
I deeply thank you for your reply to my post – specifically your statement:
“Your concerns about the possibility that the future of these fish may endanger the environment is worthy of the most serious consideration..”
You are the first biotechnology-oriented responder to any of my writings to indicate that I have raised an issue worthy of serious consideration. Perhaps it is a deteriorating economy coupled with economic self-interest that has blinded the biotech community to the international issues implied in one country (potentially and unilaterally) determining the future of the world’s water resources (for good or ill). Even among colleagues, the perspective seems to be: Anything biotech=good – Any form of criticism=ignorance.
“…worthy of the most serious consideration…” I cherish those words. Thanks again.
Kirby
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Kirby, any honest criticism of a new innovation is worthy of serious consideration. But why did I stress the word “honest”?
In the general category of genetically modified food, some of the criticisms have been designed to absolutely prohibit any use of the technology. Others have been designed to identify an issue so that it can be managed. The latter type are honest.
For example, there are numerous dishonest complainants who say that GMO food can’t be considered safe enough without long-term testing, but their meaning of the phrase “long-term testing” turns out to always mean “much longer than has already been done”. There’s no change in management or regulation that will satisfy that complainant except a total ban for all time.
By contrast, the possibility that a GMO food might introduce a new allergen into the food supply was the impetus for a series of tests and regulations that have avoided the problem. The possibility that Bt crops might lead to evolution of resistant pests was why the refuge strategy was adopted. The possibility that a newly introduced crop could escape and become a weed led to regulations that new GMO crops be evaluated for characteristics that lead to weediness. Frankly, the very good record of safety of GMO foods is because of the attention to honest criticisms.
Essentially all of your expressed concerns come down to the possibility that GMO salmon might escape into the environment, with unknown implications. You could be satisfied by some form of management. Maybe the genetics of the salmon could be changed so that they could not survive without some nutritional supplement not found in the environment. Maybe experiments could be done that show that the diploid salmon are less fit than the wild type. Maybe we could give the salmon an instinct to breed only in a single river where they could easily be trapped or killed.
I wonder if you have some ideas, which you might share with us, for how to protect the environment without entirely banning fast growing salmon entirely.
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Charles:
I’m not afraid of this technology – I embrace it! I’m not afraid to voice specific criticism against its misuse; and neither am I one to believe that the solution to world hunger is to provide more calories at any cost.
You’ve come pretty close to stating my concerns; but it is not ‘escape’ of diploid salmon from the Panama salmon farm I fear. It is the certainty of ‘intentional introduction’ of fertile diploid salmon into wild salmon environments – an eventuality which both Aqua Bounty and the FDA have chosen to ignore. To continue to discuss the concept of “escape” is to fall for the marketing/propaganda ploy developed jointly by the FDA and Aqua Bounty. Someone will certainly introduce the diploid GE salmon into the wild. The motive may be profit, it may be terror, it may be a juvenile prank or a fisherman who wants to catch something bigger than usual. But it WILL occur. There is only one way to manage this risk, and that is to remove the risk entirely with the technology through which the risk has risen.
I have seen no research indicating that the diploid salmon will not displace wild populations. I think perhaps the research hasn’t been done – probably because it may be widely understood that it doesn’t need to be done because the diploid GE salmon is obviously a superior competitor. I disagree, by the way, that it need not be done. Such research should be a basic requirement for any commercial preparation of GE animal genetic constructs.
Neither have I seen research pinpointing any animal’s genetic migratory dispositions. There may be no such genetic predispositions to re-engineer. Certainly, at this time, talk of engineering a salmon’s migration and breeding patterns is premature. Even should “instinct” be genetically manipulated some day, I am not a fan of leaving in the human element to trap and kill in order to prevent environmental consequences. Even if we didn’t have to take into account profit motive, terrorism, bi-polar acting out and every other human motivation, we still have to account for Murphy’s Law.
Yes, some sort of foolproof management would satisfy me. I say ‘foolproof’, because the potential consequences to the world for ANY probability of environmental contamination – even the tiniest probability – is too great to take when there are so many unanswered, and perhaps unanswerable, questions with respect to a GE animals’ effect on any given environment.
Unfortunately, the triploid AquaAdvantage Salmon is the reverse case of the lysine contingency fiction writers used in the movie Jurassic Park. In JP, the dinosaurs not given lysine would die in the wild – the inability to produce lysine was their ‘natural’ state. With the GE salmon, however, the ‘natural’ state is diploid and fertile, and a growth rate 563% that of their wild counterparts. Currently, direct human intervention is required to reduce the environmental threat. The eggs need to be ‘heat shocked’ in order to induce a >95% sterility rate, instead of the other way around – the eggs should be heat-shocked to induce viability! Complete re-engineering is required. Alas, Aqua Bounty is a marketing company – not a genetic engineering company. The genetic construct was developed in a university setting, not a commercial one. Because re-engineering of this particular salmon is not likely, the question becomes: How can ANY animal be engineered so that it poses no risk. Not “little risk”. No risk.
1. Attach to the gene-construct of choice a requirement for the presence of a synthetic, complex transcription factor. In the absence of this synthetic molecule, the fish still breeds but the fry maintain a normal growth rate. The molecule will not arise in nature, and it should be too complex in its interaction with its gene to be substituted for by mutation. The gene construct fails to express in its absence, and the GE salmon have no evolutionary advantage over those in the wild. The engineered gene is self-limiting. This required transcription factor should be one not occurring naturally and not capable of being substituted for due to its complexity. Underlying patents are more fully protected in this scenario, and corporate liability is even more limited than implied with FDA approval.
2. On the other hand, you could engineer a constitutively-expressed gene suppressing transcription of the gene construct. Develop a mechanism to turn off the constitutively-expressed gene, and the salmon grow fast and multiply. This would be a less desirable option, because a slight change in the suppressor gene would render it unable to prevent expression of the gene construct. Patent protection would be less rigid as it would apply only to a dual-gene construct; while liability would be significantly increased (1/2 the patent proves damaging with ensuing liability, but no protection).
3. You could engineer a constitutively-expressed gene that suppresses fertility. Suppress this gene via direct human intervention when you need eggs. Corporate types would be very satisfied with this, because the process could be kept completely in-house if a suitable proprietary compound is found to suppress the gene construct.
In the AA salmon, these solutions would require a second gene construct to be prepared and inserted; and great care would have to be taken experimentally to assure the absence of deleterious interactions of constructs. It would be another 17-year project.
4. You could, I suppose, tinker with a sex gene so that eggs need a (say) specific temperature (or light spectra, etc.) not found in a wild environment, to hatch.
5. Require a synthetic hormone flood at a specific time during embryogenesis. No hormone flood and development stops. This would require a separate gene construct, I suppose, and extensive gene interaction study. Recent research into embryonic stem cell variation indicates such a hormone flood could be quite minimal if timed appropriately.
6. I think the University of Toronto was leaning in the right direction by using the eyed-egg limitation – they just took a shortcut with heat shock to induce triploidy and got it all backwards. Genetic manipulation is called for so that the eggs hatch only with direct human intervention.
Charles, I agree that experiments could be done showing the diploid GE salmon to be less fit in the wild than wild populations. These experiments would have to be peer-reviewed, however, and not merely marketing assertions. The essential problem for genetic engineering of animals is to keep the GE animals from breeding in the wild by virtue of the inherent engineering – not by virtue of fallible human caretakers or FDA applications claiming no possibility of “escape”.
The real problem here is that the Aqua Bounty salmon are the very first genetically engineered animals suitable for commercial exploitation. As such, they will set a precedent that will continue to be followed until things go bad. And since regulatory authority has been given to the FDA and genetic constructs classified as ‘drugs’, things will almost certainly go bad. The drug regulatory model followed by the FDA is not viable when applied to organisms capable of sustaining and increasing their populations in the wild. The FDA veterinary pharmaceuticals division was given purview over these matters during a ‘business’ Administration which had faith only in faith – and none in science. The FDA can re-call a widely-distributed drug should regulatory approval be given prematurely, as the past several years have shown us on several occasions. But animal genetic engineering is kind of like the way Pope John Paul II described his dilemna as he grew older and recognized limitations of his abilities to handle his office – you can’t come down from the cross. Perhaps a better analogy would be: You can’t back away from a train wreck. Entropy tends toward maximum.
I have never envied Aqua Bounty; and in fact, I admire the company. It takes a lot of guts to raise the money and spend years of one’s life on a project that will almost certainly be shot down – if not for the lack of foresight in the engineering, then simply because it’s the first of its kind during a time of great environmental stress and fear. People are necessarily, and appropriately, wary.
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Kirby, We should all appreciate the thought you have put into this.
I have only two mild comments in contrast to the two points you made which I don’t accept.
First, it should not take anything like another seventeen years to get a new version of the salmon through regulation. That is an unconscionably long time to evaluate a novel trait. We have to be reasonable about this or give up the technology altogether. And the same obstruction can be applied to any other new technology if people are willing to tolerate it.
Second, I think you are too quick to dismiss exploiting migratory preferences. Most salmon are known to return to the stream from which they were hatched so a genetic tendency to sense that stream must already be there.
Thanks for a very rich discussion.
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Charles:
Thank you for your kind words.
Although 17 years is an extremely long time, I was speaking only of the case of attempting to genetically modify the AquaAdvantage breeding stock so that the ‘natural’ state of those GE salmon without direct human intervention would be sterile and/or lacking in gene expression of the gene construct. In other words, to insert an additional gene construct into the already-modified AA Salmon breeding stock to render them environmentally passive.
Although it’s fairly simple to pull from the list of known genes one specific for desired characteristics and package it for insertion, it is much less easy to engineer the gene package so that it will breed true and express appropriately. Even more difficult would be to engineer a separate gene construct for insertion into an already-modified GE stock which will not unpredictably interfere with the expression of the original gene construct.
It will become easier in the future, of course; but right now, it would be much more feasible to design a genetic construct with ALL desired characteristics as a single package instead of attempting to re-engineer an existing GM animal.
I disagree that there exists a genetic predisposition for salmon to return to the fresh waterways of their births. From what I have gathered (although I have done no research on the matter), chemosensory cues specific to a population are probably responsible for migratory patterns – the so-called “homing instinct”. Ole Stabell, et al., in his 1982 “A comparative chemical study on population-specific odorants from Atlantic salmon” indicates that he found small amounts of population-specific odorants in salmon skin mucous which might be responsible for the salmon recognizing (homing in on) their birth waters even after two or three years spent in the ocean. (Ooohh! It smells like me in that direction! How pleasant!) In the instant case of GE salmon with no ‘roots’, so to speak, there would exist no such odorants except when GE salmon have been breeding and hatching in the wild. When escaped GE salmon HAVE accreted mucous cues in their birth waters, might those cues not act as a sort of fishy Thomas Wolfe novel warning the GE salmon “You Can’t Go Home Again”? Especially when the GE salmon have so depleted their birth waters of nutrition and dissolved oxygen that there is no more home to go to?
Ask youseslf, why would a stream’s top predator leave its fresh water abode when there exists no genetic imperative to do so? – especially a GE salmon which has demonstrated a propensity to spend several years in its birth waters before allowing itself to be flushed into the sea? The only easy answer I can imagine is that GE salmon might move downstream because food and dissolved oxygen are low to the point that the GE salmon MUST move on in order to survive. Stabell’s “odorants” in the skin mucous would then tend to act as a sort of reverse homing instinct – warning the GE salmon to stay away from those waters from which nutrition and oxygen have been depleted – forcing those GE salmon into a nomadic lifestyle in search of different freshwater resources. But of course I don’t know for sure that Stabell’s “odorant” mechanism would be turned upside down in GE salmon – because the proper and appropriate research hasn’t been done on fertile, diploid GE salmon! Which is what I’ve actually been trying to do – convince intelligent people that there are a number of empirical experiments that are critical to be done prior to waiving all environmental liability for a company whose charter is solely to turn a buck!
P.S. I have stopped beating my head against my doorframe trying to get the public to recognize that the FDA is not acting in the public’s best interests by refusing to address the issue of “intentional introduction” of GE salmon into a wild salmon environment. Because the FDA insists it will only address the issues in the client’s proposal (in this case, AquaBounty’s), and since the proposal and the FDA environmental assessment address only the issue of “escape” (for which they find a near-zero probability) – I will henceforth address the issue of “Intentional Introduction” as one of “Facilitated Escape” and demand of the FDA that it fully consider the issue of GE salmon “escape” in those terms, pointing out that neither AquaBounty nor the FDA has fully considered the environmental risks of “escape” if the category of “facilitated escape” has been bureaucratically avoided.
Kirby Carmichael
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“From what I have gathered (although I have done no research on the matter),”
Let me stop you right there. You are making sweeping claims about the biology of salmon, indeed hypothesizing about biological functions that you have no evidence of (reverse homing instincts?), to object to this salmon. We aim for a fact-based discussion, and pseudo-biology has no place in it. If you truly believe that this salmon is dangerous, your mechanisms should be rooted in observed facts and not hand-waving. If catastrophe is to be averted, in your view, you shouldn’t risk having your objections dismissed because the biological mechanisms you propose aren’t based on actual research.
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Karl:
Let me stop you right there! I am incredibly surprised at your complete distortion of my remarks – distortions that I can only assume to be intentional from someone of your intelligence.
I didn’t “use” a hypothetical reverse homing instinct to object to the GE salmon. I proposed a hypothetical in an attempt to educate Charles on his mistaken assumption (which seems prevalent within the general non-scientific community) as he set it forth:
“Most salmon are known to return to the stream from which they were hatched so a genetic tendency to sense that stream must already be there”
I pointed out that peer-reviewed research (which I cited) indicates that it is unlikely there is a “genetic tendency” to so sense a stream. That in fact the mechanism seems to be one of odor and/or other chemical cues contained in a salmon’s mucous skin coating. I cited the appropriate literature, and then, based on the fact that these chemo-sensory cues are hypothesized – not known – to act as attractants for a salmon to return to its stream of birth and that this one-way hypothesis is unduly restricted based on the actual evidence cited in the research, I indicated that it is as likely as not that such a mechanism could act as a repellant as well as an attractant IF the salmon had depleted its birth waters of biota prior to moving down to the sea (which I have pointed out is not a sure thing – just a possibility that exists upon which Aqua Bounty has done no research). Is this really me doing what you call “pseudo-biology”? You have insulted my effort to clarify a point for Charles without giving me the courtesy of attempting to understand that effort. You have intentionally lifted my remarks out of context in order to falsely accuse me of ‘hand-waving’. Is this enough ‘fact’ for you, Karl? Such unseemly behavior, Karl, does not seem fitting for a moderator of a forum supposedly dedicated to free inquiry in science. It’s more in line with behavior expected of the PR arm of a company with a financial stake in a political issue.
The “IF” GE salmon deplete a birth stream of biota is, I admit, speculation – but it is speculation on a question that has not previously been raised. Aqua Bounty certainly has not raised any public questions about how well the fertile, diploid GE salmon it hatches breed with wild Atlantic salmon – even though it would have been incredibly scientifically negligent not to have conducted a study of such behavior. I suggest that such research has been done and the results filed in the “proprietary research” file in order to keep it from public view. This, Karl, is speculation not based on fact, but rather upon long experience with corporate interest.
Aqua Bounty has claimed that discussing such potential for breeding constitutes “speculation” because all AquAdvantage Salmon are sterile. I raised the point that the proper and appropriate research has not been done (at least not peer-reviewed) by Aqua Bounty with respect to the impact on a natural environment by fertile, diploid GE salmon. This, Karl, is a fact.
You can dismiss my objections to immediate FDA approval of GE salmon for any reasons you deem appropriate, Karl, or for no reason at all. You have turned down my offer to obtain and read the underlying documents initially submitted to the FDA by Aqua Bounty as well as the preliminary analysis made by the FDA, because you stated that don’t have the time. Puzzlingly, you began this entire discussion of the Aqua Bounty application with a summary of the Aqua Bounty corporate propaganda – a most clearly-stated “pro” view if I’ve ever seen one. Your actions lead me to speculate that you aren’t particularly interested in the issues of GE salmon and the overriding issue of commercial exploitation of genetically engineered animals. If you really wish to promote a fact-based discussion of GE salmon, Karl, perhaps you could start by doing a little reading of non-corporate material, and follow that up by trying a tiny bit harder to understand comments within the context in which they were made, rather than jumping to an attack posture more suitable in a corporate toady.
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I did no such thing. And while I have not accused you of lying, you admitted to doing so about the male fish issue, while in turn accusing me of lying and being a corporate shill. You were proposing a biological mechanism without doing any research, as you indicated. I think that the research should come first. (For instance, if you think about it, a reverse-homing mechanism would not explain how fish return to the same stream, rather than other equally-suitable streams.) Discussing things like genetic engineering often involve people proposing new hypotheses about how biology works without doing the research to find out what the current body of knowledge indicates. These kinds of hypotheses are good starters for a research project, but they don’t hold as much water in a debate over issues like this because they don’t have the evidence that other mechanisms have. Here is a recent review on the studies on atlantic salmon homing abilities.
I prefer to keep an open mind and not imagine that people I disagree with are hiding inconvenient facts as a rule. I decide what I accept based on observable evidence. You are saying you have pre-judged them here.
This is false, if you check this comment above, you will find that I asked you more questions about these documents and you did not answer. Here is what I said:
“I would be happy to look at documents that you have, when I have some more time. Perhaps next week I will have more time. For one thing, it would allow someone to check some specific statements being made about what the documents contain. What would you estimate is the total filesize of the whole collection?”
You described my response as the complete opposite of what I said! I will not accuse you of intentionally lying, instead I will chalk it up to your obvious passion for the issue of these fish. That is why I am including a question of yours in the interview.
Please read our comment policy before commenting further.
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Karl:
As you suggested, I have re-read this site’s comment policy and have and will continue to abide by its terms and conditions. I have in every instance but one attempted to refrain from intentional aggravation of others, have always attempted to remain civil, and I have refused to stoop to personal attacks. I am often direct, and I do not fear correcting others who are laboring under false assumptions or veneers of superiority. I make my remarks in all honesty except for the one time I attempted to keep things simple because I apparently underestimated my audience – and for that instance I have apologized and am completely reformed. I will no longer keep things simple by speaking in generalities which the general public uneducated in genetic engineering can understand. I will continue to conform to these standards, and I trust that you will attempt to rise from your own personal lapses and conform to the same standards.
You state that I accused you of lying. No, you are incorrect (although I am not accusing you of lying). I accused you of intentionally lifting my remarks out of their intended and stated context in order to make a point unrelated to my instructive remarks to Charles. Perhaps I was wrong in this accusation. Did you lift my remarks out of context unintentionally or for some other reason than I stated? Please inform me which of these two, if either, mistakes you claim I have made; and I will correct my accusation immediately and apologize profusely.
You state that I accused you of being a corporate shill. No, you are incorrect, although I am not stating nor implying that you are lying about being a corporate shill. I stated that your demonstrated conduct of intentionally lifting my remarks out of context is the sort of behavior expected of a corporate PR department. If I was incorrect about your behavior being intentional, I was of course wrong in so qualifying your behavior and I offer my sincere apology for doing so. If, however, I was correct that you made your remarks intentionally, I let me remarks stand and remind you that you are the one characterizing your behavior as that of a corporate shill.
You state that I proposed a biological mechanism without doing any research. No, you are incorrect again, although I am not stating that you are lying – I think it more likely that you are perhaps out of your league in your ability to understand complex biological issues and unaware that it is necessary to read more than a summary of a review in order to appropriately delve into biology – although this statement is not to be construed as an attack on your person or my attempt to aggravate you. I state this in all honesty and based upon my acute assessment of your use of words. Perhaps it is this inability of yours (if it exists) that I have misconstrued as intentionality in your previous remarks? If so, please accept my profound apologies for misconstruing your lack of ability to understand technical biological issues as an intention to lift my words out of their proper and appropriate context.
If you read the “Summary of Review” you linked in your remark and relied on in your assessment of my remarks to label as “pseudo-biology”, you would see that the “biological mechanism” you state that I “proposed” or invented is the one that was being bandied about in the eighties when this research was beginning – the Atlantic salmon’s biological mechanism of “Home Stream Recognition”. Please be informed that this biological mechanism is the very one discussed in the papers underlying the review which you cited!
You stated that the link you provided was to a Review of Salmon homing instincts. No, you are again incorrect, although I am not accusing you of lying; and I hesitate to imply that you did not understand the link you provided for fear of aggravating you. What you provided was a link to a ‘summary’ of a review of research linking olfactory and homing abilities in Atlantic salmon. “Homing Instinct” is not discussed as a scientific concept – there is no “homing instinct” in salmon. That’s part of the conclusions reached by the researchers cited in the review – the summary of which you provided a link to. It’s not a homing instinct that Atlantic salmon have, it’s the ability to smell and recognize smells originating in their home streams, the recognition being based upon the fact that they carry identical molecules with them in the mucous of their skin. That was my point that I made to Charles. Salmon returning to home streams is not genetic, it’s not instinct – it’s smell and bad personal habits. Please do not misconstrue my judgmental statement about the personal habits of Atlantic salmon as a personal attack upon them – I just don’t like to fish for fish that smell like fish. The ‘summary of review’ says pretty much what I have stated (except for the part about not liking to fish), smell plays a large part in the biological mechanism ‘home stream recognition’ of Atlantic salmon.
“Home Stream Recognition” is a biological mechanism in Atlantic salmon. It is the biological mechanism of which I was informing Charles when I sought to dissuade him from the view that some sort of genetic ‘memory’ is responsible for salmon’s ability to return to home streams. It is the widely-acknowledged biological mechanism which you incorrectly and inappropriately labeled “pseudo-biology” in your apparent attempt to attack my credibility. You labeled it “pseudo-biology” because you thought I invented it, isn’t that correct? This is a question, not an accusation. I won’t speculate on your motivation for labeling me, apparently, a pseudo-biologist for inventing a widely-acknowledged and heavily peer-reviewed biological mechanism. I am appreciative and overwhelmed that you would consider me any kind of biologist at all – pseudo or whatever other kinds there are. Needless to say, I did not invent the mechanism and despite your insistence I refuse to lay claim to it. However, you labeling it “pseudo-biology” smacks of the sort of behavior one would expect of a corporate PR department lobbying for fiduciary advantage. You should perhaps refer to your site’s comment policy before attempting to place my remarks in an inappropriate context while labeling legitimate and widely-respected science as “pseudo-biology”. It is this very sort of context-distorting, invective hurling, vilificative labeling and calumny that such comment policies seek to minimize. You are either aware of this and were patronizing me when you instructed me to read the comment policy, or you were not aware of this and I have just done you a favor. Correct me if I am wrong, for I will certainly apologize profusely.
Atlantic salmon are capable of recognizing their home streams from a distance. Everybody but you seems to agree with this statement, Karl – to you it is “pseudo-biology”. Do you have a different biological mechanism with which you attempt to explain spawning Atlantic salmon returning to their home streams after two or three years at sea? If so, I suggest you not present it on this site for fear of being labeled a “pseudo-scientist” by the moderator. He can be a real stickler!
As to “homing instinct”, although I have loosely used the phrase (you know what I mean), there is no such mechanism – only an inherent sense of smell and filthy skin. I myself have been grease-stained after a day of work stripping totaled vehicles and been able blindfolded to accurately identify the location of those vehicles I have stripped based upon my recognition of the similarities of their smells to the greases on my skin. I never felt compelled to return to those vehicles, however; and I doubt Atlantic salmon would feel such a compulsion absent an attractive association with such smells. I have seen no research that has specifically addressed the issue of whether Atlantic salmon are compelled to return to their home streams when those home streams are recognized by the salmon using this biological mechanism – unless those home streams remain suitable for spawning or were otherwise attractive to the salmon at time of initial migration to the sea. Even if salmon have been demonstrated to use this biological mechanism to return to home streams, there exists no proscription against salmon using their sense of smell and recognition of smells in other ways; i.e., avoiding home streams which may now be unsuitable and/or unattractive (such as depleted nutrition and oxygen – would Attila the Hun return to a pillaged village?). In view of the near-twenty-year shortfall of spawning salmon, coupled with the widely-acknowledged “Home Stream Recognition” abilities of Atlantic salmon (a mechanism which you disparaged), I continue to think it is as likely as not that Atlantic salmon may utilize their home stream recognition in either of two ways – go home to a healthy, attractive stream, or avoid the home stream due to unappealing (in some way or other) associations. I think research into this issue is warranted if not already underway. I have seen no research which addresses this issue or in any way does anything more than assume that home stream recognition equals homing instinct – and ‘homing instinct’ is not scientifically quantifiable. There is an assumption working here, and it may very well prove to be as incorrect as it is common. I simply point out this assumption appears ‘inherent’ in the research into home stream spawning of Atlantic salmon – I proposed no new biological mechanism. By “’inherent’ in the research” I mean the assumption appears in the research but in no way am I able to explain it or scientifically quantify it. Like an ‘instinct’ is to science. Inherent, but inexplicable. In any event, the remarks I made were to inform Charles that there is no such thing in salmon as a genetic predisposition to return to home waters. I did not propose a biological mechanism – the biological mechanism was described in the literature long before I used my first pipette. This biological mechanism, I might add again, that you inappropriately and too-impulsively called “pseudo-biology”. Did you read the paper I cited which completely discusses this issue?
I apologize for unintentionally misrepresenting your stand on accepting and reading the 391 pages of documents I once offered you. I did not review your remark prior to making mine, and I was in error. I stand corrected. You are correct in this instance and are the prevailling authority on this issue of fact. You did in fact make it clear that you would not get around to reading any underlying Aqua Bounty and FDA documents I might provide until after the public comment periods (for the environmental assessment and the finding of no significant impact) had lapsed and no further public input would be allowed. Unless I am mistaken.
In view of your stated negative opinion for the widely-respected research referenced specifically by you in support of your accusation that I was unilaterally inventing a biological mechanism called “Home Stream Recognition” which was actually offered to and accepted by the scientific community in the 1980’s but which you labeled “pseudo-science” quite probably solely because you thought I had invented it and not someone with credentials involving a Ph.D., I am now less than eager to forward these documents to you. They demonstrate much greater professional laxity than the Atlantic salmon home stream recognition research; and I am afraid that you might assume that my forwarding of them to you equals my endorsement of them thereby presenting you with the opportunity to once again accuse me of doing “pseudo-science”. Those documents would obviously be a waste of your time and I wouldn’t bother my pretty head with them if I were you.
I applaud you for keeping an open mind until you have obtained enough objective evidence – or attempted to appropriately weigh the evidence you obtain whether objective or not – to reach a conclusion as to whether Aqua Bounty has its own corporate interests at heart. Delaware Corporate law, under which Aqua Bounty is incorporated and operates, is clear as to the illegality of Aqua Bounty acting in any other manner. I agree, I have judged (not “pre-judged” as you characteristically utilize the grammar) that Aqua Bounty is operating appropriately under the corporation laws of Delaware and thus is operating in its own corporate interests. Any problem with that sort of judgment? I think perhaps even Mr. Stotish would agree with my judgment in this matter – and this judgmentn is specifically of him and the way he manages his corporation!
Good night, Karl, and have a pleasant tomorrow.
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Kirby and Karl, this whole very long and unfortunate discussion seems to have resulted when I suggested to Kirby that he make some suggestions for how the consequences of a non-accidental release into the wild could be managed. I gave him a few examples of some potential policies that would constitute management including
“Maybe we could give the salmon an instinct to breed only in a single river where they could easily be trapped or killed.”
I invited him to suggest other management ideas rather than a complete ban. Kirby responded but also seems to have thought that I meant giving salmon such an instinct by genetic transformation.
Kirby, a large number of salmon return to breed in the stream where they were hatched. Nobody thinks they do this by reasoning, which leaves instinct. Most people think this instinct is actuated by sensing chemicals like those present in the hatching stream. If this is correct, exploiting the instinct would not require genetic change, just exposing the farmed salmon to chemicals of the right sort. I don’t expect you to disagree with any of that.
When I talked about a genetic instinct to return to a certain stream I was not suggesting that there were some genes in salmon that specify the stream, just genes that specify the chemical sensing mechanism.
I think you misunderstood me, as if I meant that some salmon could have genes to seek (say)the Merrimack river and other salmon have different genes to seek the Salmon Falls river, etc.
I would suggest that you pollute your educational effort when you make such long and combative comments.
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Charles, you are right of course. What seems like a few points to make can sometimes, with some people, mushroom into a very drawn-out discussion that is irrelevant. I’ll pretty much end it here and not continue. Suffice to say, I am taken aback by the automatic insinuations that I am intentionally misrepresenting others (lying) or that my behavior is akin to that of someone paid to promote a company (corporate shill).
In closing, however, I will reiterate that I would love to take a look at the documents that Kirby speaks of, however, I am way too busy at the moment to do so because I have something really big I’m finishing up by this coming week.
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I stopped reading this thread a while ago. Long, ranty, nit-picking posts are not worth the time it takes to read them. It’s a shame, because this call for questions was important.
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One might posit that if an increased growth rate of 563% was something which would lead to all fish everywhere being Aquabounty GM Salmon should they escape (as was, I believe, put forward somewhere in the above thread) we’d have to wonder why Salmon have evolved their current growth rates as compared to one 563% that which it is (something achieved spectacularly easily through manipulation of hormone levels).
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Ewan, Kirby thinks that a high growth rate will make the salmon more evolutionarily fit. You are assuming that it will make the salmon less fit. But both of you will surely agree that this disagreement is best resolved by doing experiments, not by exchanging comments on a forum.
The big contribution Kirby has made is to clarify that there is a believable way that GMO salmon can get into the wild population, namely that some individual could take GMO diploid salmon from their controlled environment and release them, perhaps because of anger at the company, or some other base motive. This would be illegal, but that doesn’t guarantee that it won’t happen.
Of course, no regulation can reliably prevent behavior beyond making it illegal. So if the FDA refuses to allow commerce in GMO salmon, some angry person might still steal some diploid fish and release them.
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Invasive species spread by many different mechanisms, it doesn’t have to be by “anger”. A lot of fish spread by stocking by fisherman, who look at a non native species as an advantage, and see their actions as well intentioned improvements, things that (in their opinion) might be in line with the sorts of fish stocking fish and wildlife services do all the time. As could well be true in this case, as was mentioned someplace above. Many might think that they were being kind in dumping the fish that had outgrown their aquarium into a local pond. Others might extrapolate that to a local confined fish farm, although I think most problems with fish farms come from poor management of risk control at the farms themselves.
Regulation of potential for invasiveness does not have to be by making the act of introducing the species into a foreign place illegal, actions can aim at several steps before that. One example is regulating how far off shore ships dump ballast water.
Or in serious cases by banning the species in question. As with piranhas, or potentially here.
The species does not necessarily need to thrive to cause harm, only to live long enough to interbreed and have some of its genetically modified character enter the gene pool.
More on invasive species here: http://www.fws.gov/fisheries/invasive_species/invasive_main.html
Which also demonstrates that this is not a process that ought to be regulated by the FDA, but rather by a US governmental agency that actually has something to do with expertise in dealing with fish.
I agree with Kirby that one does not need to be anti GMO to be wary of some implementations. I believe that it is a product of our economic system, not science, that has caused entrepreneurs to go for these big, splashy and most of all patentable products.
Smaller, more incremental changes, restoring specific disease resistances to overbred speicies, wheat and the current fungus threats for example, might have been a better way to develop appropriate regulatory mechanisms and build public acceptance.
The reasons for not doing that are again, politics and economics, the potential lack of having something, under current law, unique enough to patent and control, not the science.
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Sorry, I can’t work out why you are concerned about a sterile fish “escaping into the wild” by any means.
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Steve:
The natural, non-heat-shocked version of the AquaAdvantage Salmon is fertile and diploid. It also grows much faster (2.5x) than the AA Salmon, is more aggressive, less migratory, stays several years in fresh waters, etc.
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Charles,
Ewan wasn’t simply assuming something, his argument comes from the logic of evolution. If a 530% higher growth rate would give those fish an advantage to the point of dominating all their competitors – as Kirby claims – why didn’t they evolved this trait long ago? This is especially noteworthy as the mutation to archive this would be very simple. So, i think, what Ewan was trying to say was that by the fact we dont see any Salmons out their growing as fast as AA Salmons do we can conclude that this high growth rate is not an evolutionary advantage.
Of course we should do a study to confirm this but the above said is not just an “assumption”, its a strong argument!
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David:
Evolution works at a much slower pace than genetic engineering technology. As an organism evolves, the entire food chain is evolving around it. Thus, an insect that develops a mimicry to hide in plain sight from its chief predator will find that the resulting population explosion of this insect makes it attractive prey for some other predator. Natural evolution works by checks and balances. It’s the duty of the genetic engineering community to provide the checks and balances when it has created an organism that outpaces nature; because nature does not guarantee us that it will contain an evolutionary antidote to our genetic assemblies.
Additionally, it is rare in evolution for horizontal transfer of gross traits (and genetic material) to occur between higher animals. An eel, for example, would almost never (if ever) exchange genetic material with a salmon. I say “almost never” because, frankly, I don’t know. I do know that Craig Ventner found a 1,000bp sequence of his DNA that precisely matches an identical 1,000bp sequence in E.coli. This demonstrates absolutely (maybe) that it is possible in nature for a horizontal exchange of genes between a vertebrate (maybe) and a bacteria. In other words, the diploid fertile version of the AA Salmon is something you would never see via natural evolution, with all its checks and balances. It is quite possible to imagine a genetically engineered top predator that would feed on anything in the ocean and result in the total depletion of all traditional fish stock. Evolution does not work fast enough to come up with a counter-proposal to minimize such an aquatic threat. Thus, we must provide the checks and balances for our own creations, lest, like Frankenstein, (“FrankenSTEEN! Not FrankenSTINE!”) we find ourselves the creators of an organism out to destroy its creator (teenaged children come to mind).
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kirby
it absolute obvious that you have no clue about evolution or biology (nor chemistry for that matter).
1) The mutation that would enable a wild type Salmon to grow as fast as a AA Salmon does is absolutely minimal – a simply mutation of the promoter construct or a duplication that leads to over-expression would be enough. Its not that they would need to evolve some complex and novel bio-synthetic pathway. Therefor the ridiculous argument that in the time the fish evolved everything around him would be “in check” with the new development is even more absurd than it already is – which bring me to point 2
2) THEIR ARE NO CHECKS NOR BALANCES IN NATURE! Nature doesn’t care about the outcomes, only humans do. (which doesn’t mean that we – as humans – shouldn’t care about the outcomes of GM)
Now you suddenly change the topic to something completely different – the horizontal transfer of genetic material. You bring up some unconnected points (eel -> Salmon, Venter, Vertebrates-> prokaryotes transfer) which are at best nice stories in our context. And then you suddenly conclude “In other words, the diploid fertile version of the AA Salmon is something you would never see via natural evolution, with all its checks and balances.” And you even go on about some freaky super predator that will kill everything in the ocean. With assumptions and conclusions like this you just show your ignorance about biology, evolution and ecology in the same way you have shown you ignorance about chemistry when you claimed the fish would deplete all oxygen in a fresh water stream.
To be honest, i couldn’t care less if this fish gets approved or not or whatever. But please educate yourself about how evolution works. The idea that nature has some kind of goal or that it will “watch over” its “creations” to keep them “in check” or “balance” any outcomes is not only wrong but dangerous too.
best wishes from “gmo-free” europe 🙂
David
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Time to take your meds.
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David:
I see from your signature that you take pride in being from a continent that has decided to step around the potential consequences of genetically modified plants.
Has it occurred to you that my position is that “gmo-free Europe” should be consulted prior to releasing fertile, diploid GE salmon into its waters?
Cheers from Ignorance-of-Evolution Land.
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David, Mr. Carmichael’s arguments about evolution are flawed, but neither is evolution such a guaranteed process. No matter how a super-predator arises, whether naturally or by man-made genetic changes, we have to admit that when it gets into an ecosystem it can be seriously disruptive, but also it can die out, or it can just blend in. All are possible.
I accept Kirby’s observation that someone purposely releasing the fertile GMO salmon into the wild is possible. I think Kirby exaggerates the probable consequences. But it is reasonable to ask regulators to evaluate whether the fish would disrupt, blend in, or die out. My guess is that the GMO salmon would be less fit and would die out, but science should be able to give us a better decision basis than a guess. The evaluation should be as rigorous as we can manage, not just hand-waving. And it doesn’t need to take a long time.
We have a frightening example of a predator introduced into an environment where it had not evolved. I’m talking about the Nile perch introduced into Lake Victoria. It has caused the probable extinction of many endemic species of fish through predation. (Examples of newly introduced species dying out are too common to bother mentioning.)
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Charles:
The traits of the fertile, diploid GE salmon include higher aggression, faster growth, wider variety of prey, and an ability to wander further for food. This group of traits constitutes about as absolute a guarantee of enhanced competitiveness as I can imagine – lacking any peer-reviewed, published research into the matter by Aqua Bounty. I imagine that in a head-to-head competition, the GE salmon would eat the environment right out from under wild salmon, then eat the wild salmon.
Does this make my evolutionary arguments flawed? You state that you think I exaggerate the possible consequences of facilitated escape of GE salmon into the wild. Which speculated consequences have I mentioned that you think are outside the realm of possibility? I will grant that I tend to take a “worst-case” point-of-view when it comes to the release of genetically engineered predators into the wild. It is good practice to do so. Robert Oppenheimer worried about the possibility of an atmospheric atomic chain reaction devastating the Earth until he was shown that it wasn’t possible – so I keep good company.
Ewan, yes. I absolutely agree that additional research needs to be done – specifically upon the issues of fertile, diploid GE salmon breeding and competing with wild Atlantic salmon in a natural environment. That has always been my objection to immediate FDA approval of the Aqua Bounty application.
David: If there are no checks and balances in nature, exactly why aren’t wild salmon naturally 563% larger than they are? You seem to be under the misimpression that I am a Creationist, or that I think there is a natural “plan” or “order”, or other such gibberish. I assure you, when I mentioned checks and balances, I was referring to those evolutionary mechanisms which are responsible for the apparent response of one species to a competitive advantage by another. An eel cannot transfer genetic material into a salmon, unless that transfer is facilitated by genetic engineering. That is one check in nature – the inability (typically) for one species of higher organism to transfer genetic material into another species of higher organism. I mentioned the eel because its genetic material was used for the AA transgene. My point about Ventner was that he – a real genetic engineer and not a mere Internet enthusiast – has identified a long stretch of genetic material in human DNA from a prokaryote that was not sexually inherited. I suppose I didn’t make my point forcefully enough:
1. It’s not only possible, but instances have been identified of simpler organisms horizontally transferring their genetic material into higher organisms without using sexual heredity as the transfer mechanism.
2. It is virtually impossible for a gene from a higher species to be transferred into a different higher species.
3. An eel gene is part of the AA transgene that has been inserted into GE salmon. This would never (probably) happen in nature. Therefore, the AA transgene could NEVER be expected to occur in nature. I repeat – the AA transgene could NEVER appear naturally in wild salmon!
Is that clear enough for you? By the way, I apologize sincerely for my too-hasty comment of “Time to take your meds”. I have seen no evidence that you even have meds to take.
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I have a question: I know the Monterey Bay Aquarium Seafood Watch calls tanked salmon a “Best Choice” for people who eat salmon:
http://www.montereybayaquarium.org//cr/SeafoodWatch/web/sfw_factsheet.aspx?fid=133 (And then click the “Coho Salmon” in the second row for the details of why they say it is best.
Is your system the same as what they describe here, that has the benefits for the environment?
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That is a good question! It sounds like it would be better in the same way that inland tanks for Coho Salmon are. The Monterrey Bay Aquarium notes that ocean-farmed salmon is the worst choice. I wonder if tanks of Atlantic Salmon could take pressure off of ocean farming?
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Yeah, good follow up–does it also potentially encourage more of that if tanked growth is successful and efficient.
I would like to include the tank issue in my comment if it is the same thing as that Coho example.
I also saw a recent UK project on inland fish farming: Could Scottish salmon farming be transformed by moving to dry land?
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Monterrey Bay Aquarium Seafood Watch has a very extensive checklist of criteria for aquiculture.
Click to access MBA_SeafoodWatch_AquacultureCriteraMethodology.pdf
I would imagine that AquaBounty would have a hard time meeting the criteria for effective governmental regulation in the countries like Panama if that is the sorts of locations they seem to be targeting for these facilities.
Whether or not farmed fish take pressure off wild fish depends not only on how they are housed but also what they are fed. In many cases, forage fish are harvested from the oceans in a non sustainable manner to feed farmed fish.
There is a flip side to this, fish that eat a varied diet including other fish have more omega 3 oils. If you feed fish corn it is my understanding that you get a product that defeats from a taste and a nutritional perspective a lot of the point of eating fish in the first place. We need a better measure of nutritional quality for meat production than an ability to “pork on the pounds”.
While there may be more immediate impact on the oceans if the pens are in the ocean, runoff from pens can affect streams. Which eventually make it to the ocean and sometimes are spawning areas for ocean going fish.
I am interested in Kirby Carmichael’s comments above on the FDA process and will look into that.
As someone well aware of surreptitious stocking of fish into streams by wayward fishermen (women) I would strongly agree that Aqua Bounty would be unlikely not to experience poaching, and that this fish could be kept out of the wild.
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Scotland makes sense in a number of ways. For one thing they could keep the water cold. And Scotland is capable of solid regulation.
But why would they put what is essentially a huge factory into such an unfactory like place? From Mary’s Guardian link:
“It is also right on the boundary of one of Scotland’s most important sites for migrating geese, a heavily protected site of special scientific interest for Greenland white-fronted geese, and it borders a popular coastal path, promoted to tourists and walkers.”
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Mr. Stotish,
Have you any data on the protein-conversion efficiency of AquAdvantage salmon over conventional Atlantic salmon? If you can make big improvements in that ratio (and we still enjoy the eating), then we need to get you a “Sir Stotish”!
Also, is there any hope to design for a commercial fish that can grow on a diet that is “diluted” with plant crops? I.e., not 100% animal protein feed? Of course consumers must want to buy it in preference to the “bad old salmon”.
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Sorta related, but not exactly a hard question: has anyone seen this film?
Fish Meat. Since it’s Stotish’s biz maybe he has. I’m curious about how accurate it is.
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How will AquAdvantage be marketed? What specific labeling will be on the packages? Some companies provide additional info about their products on a website. Right now, the info on the AquaBounty website is fairly limited – do you have plans to add more? For example, Quorn is a product with a lot of “about” information and FAQs on their website. Their product is somewhat unique and complex so the additional info is useful. I think the same would be good for AquAdvantage.
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Since the deadline for the public comment period has been extended by two months by the FDA, I have let the question-gathering stand for longer. Before the end of the week, I plan to put them together and send them off. So get in your question ideas before the week is over!
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Hello, has this interview taken place and will it be published? Thanks.
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Hi! Thank you for Biofortified. I love reading the articles and forum.
Great opinion piece in the NYT on this subject.
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Thank you, and thanks for reading and giving us this link!
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hey,im doing a research project about this fish now. so i was wondering whether could you tell me more about how this fish is made in detail. thanks 🙂
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Best thing would be to read the FDA documents linked to.
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allright,i got it. thanks again 🙂
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