How to comment on frankensalmon

To the Editor:

On December 21, 2012, the U.S. Food and Drug Administration (FDA) issued a draft environmental assessment of the genetically engineered salmon in which they said that the salmon "would not have a significant impact on the U.S. environment." The FDA also concluded the salmon to be "as safe as food from conventional Atlantic salmon."

If all goes as expected, the salmon could be available for consumers by late next year. How will we know if it is GMO salmon if GMOs are not labeled yet?

This genetically engineered salmon will be the first GMO animal to be approved by the FDA. These genetically engineered salmon are Atlantic salmon that combines a growth hormone gene from Chinook salmon and a control gene from an eel-like fish called the ocean pout that cranks out the growth hormone.

The FDA chose to review AquaAdvantage (the patented name for this new "Frankenfish") as an animal drug, rather than a human food. In the FDA’s view, the refashioned DNA that is in every cell of the fish’s body is considered a drug, and that’s what the agency is regulating. If approved, the AquAdvantage salmon would not only be the first GE animal approved for human consumption, but also the first animal drug that’s theoretically capable of swimming off into the ocean and reproducing.

Michael Hansen, a scientist at the Consumers Union states, "We are deeply concerned that the potential of these fish to cause allergic reactions has not been adequately researched," and goes on to explain that "the FDA has allowed this fish to move forward based on tests of allergenicity of only six engineered fish, tests that actually did show an increase in allergy-causing potential."

Along with the concerns of the allergenicity of this GMO fish there are many others. There have been no long-term human feeding studies to find out what the consequences are of eating these fish. The FDA determined that GMO salmon are GRAS (generally recognized as safe) - like other GMO foods - which basically means that there is no requirement for further safety testing.

One can only wonder what the long-term health effects of eating genetically engineered sterile fish may be. Could it affect our ability to reproduce? We don’t know for sure... but we can look to the results of the rat feeding studies on other GMO foods which showed the potential for sterility in the second generation... and that was from eating GMO foods, not GMO sterile fish.

As to sterile fish, at present, there is no method to guarantee 100 percent sterility.

The FDA’s own study recently found that five percent of the animals were in fact fertile. If large numbers of fish escape, it doesn’t take a rocket scientist to deduce that some fertile fish might survive in the wild. Because AquaAdvantage fish grow many times faster, and become mature much more quickly than wild salmon, they may have the ability to outcompete wild salmon for food, and to reproduce at a much faster rate. There is no doubt that once the AquaAdvantage GMO salmon escape they will begin to rapidly diminish the wild population.

Research published in the Proceedings of the National Academy of Sciences found that a release of just 60 GE salmon into a wild population of 60,000 would lead to the extinction of the wild population in less than 40 fish generations. This is a horrible thought especially considering how we have been recently celebrating the regeneration of the local salmon population.

GMO salmon are unnecessary. They are a threat not only to the native salmon population and the fishing industry but most of all, to our biodiversity.

Once these GMO salmon escape into the wild there is no putting them back. It is like Pandora’s box, so to speak. What will happen when bears, eagles, otters and humans begin eating GMO salmon for the first time ever? We just don’t know, but one can only wonder if eating GMO salmon may potentially have the ability to alter the DNA of those consuming it. Studies regarding eating other types of GMO foods have clearly shown that this is entirely possible.

How do you feel about GMO salmon? If you think the FDA is making a short-sighted decision, please express your concerns before the FDA public comment period ends. Please comment before midnight Feb. 25 EST. You can comment at Search for docket # FDA-2011-N-0899. Click on the ‘comment now’ box.

Or comment by mail to: Division of Document Management (HFA 305)

Food and Drug Administration

5630 Fishers Ln. Room 1061

Rockville, MD 20852

Also, please join with us for a global action day event on Friday, Feb. 1 to call the FDA and say no to GMO salmon. Details are as follows. Call and email the FDA Center for Veterinarian Medicine. Phone: 1 (240) 276-9300 (9 a.m. to 5 p.m. EST) or toll free at 1-888-463-6332. When prompted, press 3 to speak with an FDA representative; then press 6 for animal, drugs and feed; this will take you to the office of FDA Center for Veterinarian Medicine. Leave your message with your concern about the approval of GMO salmon with a return number where you can be reached and email:

Find our event on facebook on SoHum Label GMOs Group page here

Email questions to

Isis Austin

Myers Flat