Lawsuit over FDA GMO salmon

SUBHEAD: Opponents are concerned about what will happen to wild salmon when the GMO fish reach to wild salmon.

By Chris D'Angelo on 31 March 2016 for Huffington Post -
(http://www.huffingtonpost.com/entry/fda-sued-over-genetically-engineered-salmon_us_56fd75f7e4b083f5c60730bc)


Image above: An AquAdvantage Salmon is pictured in this undated photo provided. Photo by AquaBounty Technologies. From original article.

• Plaintiffs argue the federal agency overstepped its authority in approving the GMO fish.
• AquaBounty Technologies' salmon are engineered to grow twice as fast as wild species.
• Critics worry engineered salmon could prove disastrous for wild salmon populations.

Nearly a dozen fishing and environmental groups have filed suit against the Food and Drug Administration in an effort to block its recent approval of genetically modified salmon.

The plaintiffs, represented by the Center for Food Safety and Earthjustice, argue that by green-lighting the first-ever genetically altered animal slated for human consumption, the FDA violated the law and ignored potential risks to wild salmon populations, the environment and fishing communities.
“That’s one of the major risks here, is the escape of these fish into the wild,” George Kimbrell, senior attorney for Center for Food Safety, told The Huffington Post. “It could be a final blow to our already imperiled salmon stocks.”

Produced by Massachusetts-based company AquaBounty Technologies, the AquAdvantage Salmon is an Atlantic salmon engineered with genes from a Pacific Chinook salmon and a deep water ocean eelpout to grow twice as fast as its conventional counterpart.

 

The 64-page lawsuit, filed in U.S. District Court for the Northern District of California, challenges whether the FDA has authority to regulate genetically modified animals as “animal drugs” under the 1938 Federal Food, Drug and Cosmetic Act. It also argues the agency failed to protect the environment and consult wildlife agencies in its review process, as required by federal law, CFS said in a release.

“I think it’s important to note that FDA has gone ahead with this approval over the objections of over two million Americans in the comment period,” Kimbrell told HuffPost.

In its approval announcement in November, the FDA said it determined “food from AquAdvantage Salmon is as safe to eat and as nutritious as food from other non-GE Atlantic salmon and that there are no biologically relevant differences in the nutritional profile of AquAdvantage Salmon compared to that of other farm-raised Atlantic salmon.”



Image above: Fresh Atlantic salmon steaks and fillets at Eastern Market in Washington, D.C. in 2013. Photo by SailLoeb. From original article.

FDA spokeswoman Juli Putnamn told HuffPost in an email that as a matter of policy, the federal agency does not comment on pending litigation.

 

The lawsuit is the latest development in an ongoing and heated debate over genetically modified organisms, their safety and whether genetically engineered foods should be labeled. While proponents say the technology allows agricultural farmers to be more efficient, opponents argue they result in heavy pesticide use and transgenic contamination.

In the case of its GE salmon, AquaBounty says the fish grows to market size using 25 percent less feed than any Atlantic salmon on the market today.

But if the engineered fish were to be released into the wild — a risk AquaBounty says is eliminated by raising them on land and away from the ocean — critics worry they might outcompete endangered wild salmon for food and introduce new diseases.

“Once they escape, you can’t put these transgenic fish back in the bag,” Dune Lankard, a salmon fisherman and the Center for Biological Diversity’s Alaska representative, said in a release. “They’re manufactured to outgrow wild salmon, and if they cross-breed, it could have irreversible impacts on the natural world. This kind of dangerous tinkering could easily morph into a disaster for wild salmon that will be impossible to undo.”

Plaintiffs in the case include Pacific Coast Federation of Fishermen’s Associations, Institute for Fisheries Resources, Golden Gate Salmon Association, Friends of Merrymeeting Bay and others.

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GE salmon - What could go wrong?

SUBHEAD: Genetically modified salmon will eventually escape and establish populations in the wild.

By Kurt Cobb on 22 November 2015 for Resource Insights -
(http://resourceinsights.blogspot.com/2015/11/genetically-engineered-salmon-what.html)


Image above: Salmon is native to the northern Atlantic Ocean, in rivers that flow into the north Atlantic and, due to human introduction, in the north Pacific Ocean. From (http://www.wikiwand.com/en/Atlantic_salmon).

[IB Publisher's note: Our best guess is that these GE salmon, like most fish farm operations, feed on GMO corn products - just like most dogs and cats are fed.]

As U.S. regulators cleared genetically engineered salmon for sale in the United States last week, they opened the door to what many scientists already feel is inevitable: The escape and reproduction of GE salmon in the wild and the possible destruction of competing wild species.

Under the U.S. Food and Drug Administration-approved application, the company behind the so-called AquAdvantage Salmon, Aqua Bounty, can only raise such salmon in land-based tanks with "multiple and redundant levels of physical barriers to prevent eggs and fish from escaping." These barriers are described in detail and suggest that it will be very difficult for any eggs or fish to escape into waterways.
The FDA said it considered four interrelated questions about confinement of the fish:

1. What is the likelihood that AquAdvantage Salmon will escape the conditions of confinement?
2. What is the likelihood that AquAdvantage Salmon will survive and disperse if they escape the conditions of confinement?
3. What is the likelihood that AquAdvantage Salmon will reproduce and establish if they escape the conditions of confinement?
4. What are the likely consequences to, or effects on, the environment of the United States should AquAdvantage Salmon escape the conditions of confinement?

Right away we can see that the FDA is asking these questions in the wrong way because it misunderstands the risks involved. It should be asking if there is ANY LIKELIHOOD WHATSOEVER that the salmon will escape, survive, disperse, reproduce and establish populations in the wild.

Why is it important to ask the question in this way? Because although the salmon are sterilized, the "sterilization technique is not foolproof," according to The New York Times.

So, here is the relevant principle: Any invention with a nonzero risk of systemic ruin and which is produced and deployed long enough will with almost 100 percent certainty create that ruin. Put more informally, if you keep repeating something that each time you repeat it has a small chance of creating catastrophe, eventually you will produce catastrophic conditions, that is, systemic ruin.

Systemic ruin in this case would be the ruination of the wild salmon fisheries overrun by the GE type.
And, the damage might include other harmful effects to waterways and their associated wildlife that we cannot now anticipate. Remember, this is a fish that we've never seen operate in any existing ecosystem. We have no empirical data about its possible effects; and, releasing such fish into the wild to obtain that data risks the very ruin we wish to avoid.

Now, there is one final question which the FDA asks: "What are the likely consequences to, or effects on, the environment of the United States should AquAdvantage Salmon escape the conditions of confinement?"

Again, this is the wrong way to ask the question. The effects would not be confined to the United States since the escape of one unsuccessfully sterilized salmon into the wild could lead to a worldwide infestation. (In any case, the facilities approved for farming the salmon are in Prince Edward Island, Canada and in Panama. But apparently, only the possible environmental effects in the United States were considered.)

Anything that is novel cannot by definition have a history to draw on. A novel invention might not alter the environment very much or it might alter it radically. We cannot know. To say that we should subject the world's salmon fisheries to the possibility of ruin in order to find out reveals a failure to understand that self-propagating, worldwide dangers do not lend themselves to cost-benefit analysis.

When the cost is the complete ruination of a system, we must judge costs to be incalculable. The complete destruction of the global wild salmon population is not 10 times worse than the destruction of 10 percent of that population. It is infinitely worse. It is infinitely worse because you cannot repopulate the world with an extinct species (except perhaps in science fiction movies). There is no remedy.

And, we must keep in mind that we do not now know how many other facilities like those built by Aqua Bounty will be constructed. The danger of release grows with each added facility. And, of course, we must assume that Aqua Bounty wants to expand as a company which implies many more facilities should the company become successful.

Also, keep in mind that such facilities, although on land, must have extensive plumbing and drains which must ultimately connect with the external world. Is it rational to believe that GE salmon or salmon eggs will never, ever make it into a waterway and survive, an event which must happen only once for a possible cascade of destruction of wild species to take place?

So, we should say that the risk is real and the scope and severity, if realized, would be catastrophic.
Understanding this allows us to see why the precautionary principle applies in this situation and in the cases of all genetically engineered plants and animals. Anything that is novel, self-propagating and worldwide in reach has the possibility of creating systemic ruin. Which leads us to another key principle: It does not matter how many times something succeeds if failure is too great to bear.*

In other words, it does not matter if millions upon millions of GE salmon are produced without any release into the environment when the inevitable release of one (by mistake, carelessness, accident or poor design) could create ruinous global consequences. (And, if the GE salmon industry grows, it is difficult to believe that there will be only one inadvertent release over time. Accidents happen--even when we think we have designed foolproof systems.)

Whether such a fish is safe for human consumption is not the key question--though the FDA answers that it is safe. That's what makes the announcement of the approval so misleading. What difference does it make if this GE salmon is safe to eat if, in the event of escape and propagation, it ultimately destroys the entire wild salmon fishery and has other unforeseen and catastrophic effects on marine life.
______________________________________________________
*This formulation comes from author and risk expert Nassim Nicholas Taleb, author of The Black Swan and many other works on risk.

See also:
Ea O Ka Aina: Unlabled GMO Frankenfish 11/20/15

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Farm tuna won't fly

SUBHEAD: Here are some sources of alternate opinions on advocacy of raising farmed bluefin tuna.

By Juan Wilson on 6 November 2014 for Island Breath -
(http://islandbreath.blogspot.com/2014/11/farm-tuna-wont-fly.html)


Image above: An aquapod designed by Ocean Farm Technologies being prepared for deployment. From (http://thinkprogress.org/climate/2014/04/21/3422486/big-ag-takes-to-the-ocean/).

Wild tuna are being fished into extinction by modern commercial fishing technology. The increasing demand for the fish is creating increasing competition between Japan, America and other Pacific nations.

It sure would be nice if Hawaii could grow large commercial fish like blue fin and yellow fin tuna in offshore farms? Some think so. The technical problems of raising large predators in densely populated cages are many. To name a few - food sources, waste management and healthcare are complicated and have not been solved in such a way as to be sustainable.

But advocates of tuna fish farming are moving forward in Hawaii. See the article at the bottom of this post that we got Lyn McNutt (http://www.fishupdate.com/sustainably-farmed-tuna-to-become-reality-in-hawaii/). It certainly puts the best face on a business model (farmed seafood) that has proved in most cases to be damaging to the ocean ecosystem and and unhealthy to consumers.

Fish Farm Feed
In general, the feed for farmed fish fall into two categories. For non predators, like tilapia, much of the feed is made up of GMO corn. For carnivorous fish like tuna the feed are small fish that taken in large quantities from wild sea creatures like seabirds, seals and whales.

Fish Farm Fix
The solution is to treat the fish with antibiotics and other medications. The tuna also get supplements like sex hormones to help with procreation in captivity. These chemicals not only affect the farmed tuna but nearby wild fish.

Fish Farm Feces
Farmed fish live in cages. This containment creates a concentrated waste stream that is toxic to the fish that produce it. This impairs the fish and creates health problems. It also pollutes the ocean bottom creatures.
Here are some sources of alternate opinions on advocacy of raising farmed bluefin tuna:


Farm-raised bluefin tuna spawn controversy
(http://www.mnn.com/earth-matters/wilderness-resources/stories/farm-raised-bluefin-tuna-spawn-controversy).

Bluefin Tuna And The Trouble With Fish Farms(http://indianapublicmedia.org/eartheats/bluefin-tuna-trouble-fish-farms/).

Farming The Bluefin Tuna Is Not Without A Price(http://www.npr.org/blogs/thesalt/2014/07/30/336339179/farming-the-bluefin-tuna-tiger-of-the-ocean-is-not-without-a-price)

Farm-Raised Tuna May Not Be the Answer to Overfishing
(http://www.businessweek.com/articles/2013-01-08/farm-raised-tuna-may-not-be-the-answer-to-overfishing)

This does not mean that fish farming cannot be done correctly. PrimeSeaFood.com has said:

We promote one brand of farm-raised Atlantic salmon, HiddenFjord premium salmon which is raised in the Faroe Islands (between Scotland and Iceland) and one brand of king salmon, Ora King Salmon which is raised in New Zealand.

But most "farmed" salmon can be dangerous to one's health. Just one meal a month can pose a high cancer risk.

For more see (http://www.primeseafood.com/farm_raised_salmon.html)

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Here's the article about tuna fish farming are moving forward in Hawaii.

Sustainably farmed tuna to become reality By Tim Siddons on 27 October 2014 for Fish Update  According to the United Nations Food Agriculture Organisation, most of the world’s tuna stocks are over-exploited and on the verge of collapse. Modern fishing methods used to catch tuna for canning increasingly catch juvenile yellow fin and big eye tuna before they have a chance to spawn, exacerbating the problem. Poor and simply disregarded conservation management efforts and high levels of illegal, unregulated and pirate fishing have further decimated wild caught tuna populations. Even the famed oceanographer, Sylvia Earl, no longer eats fish of any kind, stating that ‘We should think of fish primarily as wildlife, not food.’ Since 2006, Hawaii Oceanic Technology, Inc., has been on a mission to save tuna, or Ahi, as it is becoming known worldwide. The company’s goal is to demonstrate that deep ocean mariculture can help meet the world’s voracious demand for tuna, in an environmentally responsible and sustainable manner. After several years of compliance with an extensive array of regulatory requirements, the company is ready to fulfill its mission. Bill Spencer, co-founder of the company, with the help of a handful of investors, is committed to finding a way to prevent the disappearance of tuna in our lifetime. ‘Farming rather than hunting for seafood is the solution’, Spencer believes. ‘Mankind can no longer ignore the need to domesticate seafood production, and the open ocean is the best place for this to happen.’ He is further committed to farming tuna in the most environmentally sustainable manner possible. Fish farming has evolved to the point where most of the problems have been addressed. Recent evidence has shown that farming seafood in deep ocean settings results in lower food conversion ratios, faster growth, negligible environmental impact and no need for antibiotics because of reduced parasite loads and high water volumes. Spencer is intent on proving these tenets of sustainable fish farming at his company’s 250 acre (11 million square foot) ocean lease site, the largest fully permitted mariculture site in the United States. The depth at the site is almost 1,500 feet, assuring that no fish feed or other effluent from the farming activity will ever touch the ocean floor. The massive volume of water within the ocean column combined with a gentle current assures that effluent will be quickly mineralised and serve as nutrient for organisms such as phytoplankton and zooplanktons that make up the lowest level of the ocean food chain. The company is permitted to raise yellow fin and big eye tuna grown from eggs spawned in captivity and raised to fingerling size before being put in the company’s patented Oceansphere grow-out cages. Research conducted by the company over the last five years has demonstrated that yellow fin tuna can readily be spawned in captivity and that a consistent supply of fingerlings is possible to achieve. Eventually the company will grow its own tuna feed stock and formulate feed supplemented with omegas and protein from algae and other locally sourced nutrients. Assuring sustainable feed for fish farming is the company’s highest priority. ‘The misinformation on the topic of food conversion in fish farming is so pervasive that the general public is seriously confused about how efficient egg-to-plate fish farming actually is,’ Spencer contends. ‘Farmers of Atlantic Salmon, the predominant ocean farmed species, have achieved a 1:1 food conversion ratio, that is one pound of feed for every pound of growth. ‘This is because fish raised in a hatchery from eggs are weaned on highly nutritious formulated feed and do not have to scavenge for their meals.’ The same principle will be applied to Spencer’s tuna, branded as King Ahi. The tuna will be weaned on and trained to consume a highly nutritious diet that will contain some fish from sustainable stocks, but a very low amount compared to what is fed to fattened Blue Fin tuna or even wild caught tuna. Bill Spencer ‘In the wild, carnivorous species like tuna eat fish that have eaten fish all the way down the food chain, resulting in a massive food conversion ratio in terms of energy transfer’, Spencer explains. ‘This is also how mercury, PCBs and other toxins get concentrated into carnivorous species. The resulting food conversion ratio of a wild carnivorous fish can be as high as 100:1. ‘Even if one argues that it takes five pounds of baitfish for every one pound of farmed fish, it is still 20 times more efficient than in the wild. ‘To create a 10 lb mahi mahi in the wild it takes 1000 pounds of baitfish. To create a 10 lb. mahi mahi on a farm, it takes less than 50 lbs. ‘That comparison is still fairly conservative, as it does not include the by-catch involved in fishing or the higher efficiencies we see on modern fish farms. 'The implications should be clear, Spencer continues: ‘farming leaves far more baitfish remaining in the ocean ecosystem. Simply stated, farming seafood is the most efficient way to produce seafood protein. ‘Our ambition is to achieve a 1:1 food conversion ratio, which is even better than any land based protein production including chickens, pigs and cattle.’ Between Hawaii Oceanic Technology’s use of its highly efficient, high-tech Oceanspheres and operation in its 250 acre, 1,500 foot ocean column, the company is ready to prove that domesticating tuna farming is possible, practical and an imperative that must be embraced by the seafood industry.

See also:
Ea O Ka Aina: Governor Wrong on Aquaculture 7/29/11
Ea O Ka Aina: Kauai Shrimp Waste Dump 3/19/10
Ea O Ka Aina: Shrimp Effluent Permit 3/12/10
Island Breath: Something Fishy 7/12/08
Island Breath: Kauai Shrimp to dump in ocean 8/21/06
Island Breath: Kauai's Crustacean Crisis 4/23/04 .


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Kauai shrimp waste dump

SUBHEAD: The smell was overwhelming, the feces and dead shrimp attracted sharks, the canals were depleted, and it killed every single fish in the area.

By Juan Wilson on 19 March 2010 for Island Breath -
(http://islandbreath.blogspot.com/2010/03/kauai-shrimp-waste-dump.html)


Image above: Sign near entrance to Kawaiele wetland experiment managed by Hawaii DLNR. All photos by Juan Wilson 3/19/10  

 Rather than have an industrial shrimp farm that requires as much as 25 million gallons of noxious effluent flowing into the ocean in a day, why not expand the existing wetland sanctuary to handle a more natural way of breeding fish for the ocean's health and our own sustenance. A natural organic aquaculture would be a much better solution and return the Mana Plain back to the source of bird, plant and fish life that it once was.

As I have mentioned on this site before; the two greatest wetlands in the Hawaiian chain were both destroyed in the last century for money and power. One was Pearl Harbor - dredged out for the U.S. military. The other was the Mana Plain - filled in for industrial agriculture (and now the breeding ground for genetically modified crops).

 
Image above: Plants grow down into the brine wetland where fish are breeding.

The Kawaiele Sand Mine - Bird Sanctuary Project is only a few acres, but it demonstrates the beauty that was once adorned the western shores of Kauai. The Mana Plain had estuaries that teemed with fish and birds that allowed travel by canoe from Waimea past the town of Mana. Natural aquaculture is what we should be aspiring to. Restoring the wetlands and fishponds of the past would be a boon to the oceans. They would be breeding grounds for the reefs.

 
Image above: A Great Blue Heron hunts for fish in wetlands sanctuary.

he present strategy of industrial fish farming is destructive to local fisheries. Here is a quote from observations on shrimp farms on the Indian continent. See http://www.radford.edu/gmartin/Bangladesh%20photos%201.htm:

"The fishermen from a poor fishing village near Chittagong wade out to their boat when it comes back with its catch. The catches, they told us, are very slim compared to 15 years ago when there were plenty of fish. They rapidly walk with the fish in bamboo baskets resting on their shoulders the several kilometers to their village in order to try to sell it while it is still fresh." "In the same place where the poor fishermen were unloading their meager catch, the landscape was surreal, like a scene from some alien landscape. Giant earth moving machines were tearing at the tidal flats, creating vast holes and mountains of discarded mud. A commercial shrimp farm was being constructed." "These shrimp farms create food for export (not the local population) and destroy the mangrove coastal barriers that help prevent typhoon and storm damage and flooding on the land. These farms are being created all along the coasts of south India and Bangladesh. As usual, short term profits far outweigh the welfare of the local populations or future generations."

Will military wastelands, genetically mutated grasslands and dead ocean reefs be our legacy on the Mana Plain? By the way, there is a rumor among people who know the harbors on Kauai that the PMRF is interested in dredging the Bird Sanctuary for a dock site of their own. For more about the effluent request by Sunrise Capitol, read on.

  Video above: Dan Barber - How I fell in love with a fish farm. From (http://www.ted.com/talks/dan_barber_how_i_fell_in_love_with_a_fish.html)

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Shrimp farm to dump waste in ocean  By Coco Zickos on 19 March 2010 in Garden Island News -     (http://thegardenisland.com/news/local/article_2385f08a-3331-11df-91b3-001cc4c03286.html)  
Image above: Sign near the entrance of the Sunrise Capital shrimp farm nest to the Kekaha Landfill. 
 
All photos by Juan Wilson 3/19/10 Proposing to discharge up to 30 million gallons of wastewater effluent and treated shrimp remains into the ocean on a daily basis, Sunrise Capital has filed for a Draft National Pollutant Discharge Elimination permit with the state Department of Health, according to an e-mail from the DOH’s communications office Thursday.

Originally owned and operated by Ceatech USA, the Kekaha shrimp farm was acquired by Sunrise Capital in June 2005 and is currently operating at minimal capacity, said an e-mail from officials at the DOH’s Clean Water Branch. While this has “resulted in no discharge from the property” since 2004 after the “farm became infected with a shrimp virus,” Sunrise Capital seeks to increase its operating capacity which will likely generate a maximum of 23 million gallons of biological waste each day, according to CWB officials.

Messages left for Sunrise Capital Wednesday and Thursday were not returned. “The ocean is not a dump,” said environmental activist Dr. Gordon LaBedz of Surfrider Kaua‘i. Non-coastal shrimp farms can and do exist utilizing alternative methods of waste treatment and disposal, he said Thursday.

 
Image above: Pump aerator in middle of active shrimp basin lined with neoprene.  

When asked if generating fuel from the waste could be a possibility, LaBedz said the amount of discharge would be insufficient to make it economically viable. “I’m not against the shrimp farm,” said community activist Bruce Pleas. However, when the farm was operating at full capacity from February 2000 to December 2003, the “disastrous effects” of the waste in the sea were monumental, he said. The smell was overwhelming, the feces and dead shrimp attracted sharks, the canals were depleted, and it killed every single fish in the area, he said. In addition, the dumping affected surf spots known as Kinikinis, Major’s Bay and Family Housing. The current can carry the waste which would allow it to “travel miles,” LaBedz said.
 

Image above: A 12" PVC discharge pipe from shrimp basin flows into ditch headed to ocean. Note dead plants in ditch coated with white accretion. 

“The nutrient levels in the immediate vicinity of the discharge into the receiving ocean waters are expected to be elevated from ambient conditions,” the e-mail from the CWB said. “However, the adjacent coastal ocean area is not expected to have any noticeable effect associated with the shrimp-farm discharge.”

“Water monitoring” which occurred while the shrimp farm was operating at full capacity prior to 2004 “indicated that the discharge from the facility did not affect the water quality of the ocean area,” nor did it impact any adjacent biological communities, the e-mail went on to say. In addition, Sunrise Capital will reportedly apply “numerous waste-minimization” efforts, according to the CWB.

And based upon the “company’s operating history which showed no evidence of negative environmental impact..,” officials at the CWB said they are supportive of the operation’s intent to dispose between 20 million and 30 million gallons of biological waste into the ocean. To review a copy of the NPDES application visit http://www.hawaii.gov/health/environmental/water/cleanwater/index.html. One may also acquire a copy at the Kaua‘i District DOH office located at 3040 ‘Umi St. in Lihu‘e.

Comments may be sent no later than April 10 to Clean Water Branch, Environmental Management Division, Department of Health, 919 Ala Moana Blvd., Room 301, Honolulu, Hawaii, 96814-4920. Objections and requests for a public hearing should also be sent to that address.


See also:
Ea O Ka Aina: Shrimp Effluent Permit 3/12/10
Island Breath: Kauai Shrimp to dump in ocean 8/21/06
Island Breath: Kauai's Crustacean Crisis 4/23/04 .