Tell FDA: Do Not Approve Genetically Engineered Salmon!

RE: Docket No. FDA–2011-N-0899 Genetically Engineered Salmon

I am writing to express my opposition to the approval of AquaBounty’s genetically engineered, AquAdvantage salmon (Docket No. FDA-2011-N-0899). As the AquaBounty transgenic salmon is the first genetically engineered (GE) animal intended for human consumption, the importance of thorough human health, environmental, and economic impact studies cannot be overstated. This animal should not be approved for human consumption until further study indicates that they are safe for consumers and the environment. FDA’s cursory EA is inadequate, and a full environmental impact statement is necessary to properly study the potential impacts of this novel fish.

I am very concerned about the potential toxicity, allergenicity, and diseases posed by the commercialization of this transgenic fish. While data on human health impacts of GE fish is sparse, some recent studies have provided cause for serious concern. For example, scientists have asserted that foreign growth hormones in transgenic fish may increase production of other compounds such as insulin in the fish.

Genetically engineered fish also pose serious risks to our marine environment and wild populations of salmon, and the men and women who depend upon them for their livelihoods. Each year millions of farmed salmon escape, outcompeting wild populations for resources and straining ecosystems. Any approval of GE salmon would represent a serious threat to the survival of native salmon populations, many of which have already suffered severe declines related to salmon farms and other man-made impacts. Escaped GE salmon can pose an additional threat – genetic pollution resulting from what scientists call the “Trojan gene” effect.” Research published in the Proceedings of the National Academy of Sciences notes that a release of just sixty GE fish into a wild population of 60,000 would lead to the extinction of the wild population in less than 40 fish generations. This could be the last blow to wild salmon stocks.

Anticipating the stark danger to our ocean environments – and trying to circumvent analyses of those dangers – AquaBounty has claimed that they will only raise their fish in land-based facilities. However, once the production of GE fish becomes commercialized, it will be impossible to control the whereabouts of every single individual and assure compliance with appropriate containment measures.

The AquaBounty company also says that it will only produce sterile females; however fish are known to change sex and there is no guaranteed method to produce 100% sterility. Moreover, the company will need to keep stocks of fertile fish to produce additional offspring.

I strongly oppose the approval of these genetically engineered salmon and urge FDA to reject GE salmon. Should FDA decide to approve the AquAdvantage GE salmon despite overwhelming opposition, clear, mandatory labeling is an absolute must when marketing to fish farmers, fish retailers, food companies, restaurants, and consumers to allow people like myself to make informed purchasing decisions.
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