Theresa Labriola

April 25, 2002

 The battle over genetically modified food has expanded from land to sea.   With the reality of genetically modified crops still difficult to swallow, custom-built fish may soon be on the dinner plate as well.   Genetically engineered ("GE") fish, modified with thehuman growth protein hGH, grow six times as fast and twice as large as, farm-raised salmon and require only three-quarters as much feed.[1]  The application to sell these salmon with super-growth genes now sits before U.S. federal regulators, who must decide if Frankenfish, as they are called by their critics, are safe for the dinner table.[2]  Producers must complete a New Animal Drug Application ("NADA") and demonstrate the safety of their product before receiving approval from the Food and Drug Administration ("FDA") to market GE fish. [3]  Yet the appropriateness of Frankenfish for human consumption is only one concern.  Globally, GE fish also threaten, sustainable fishing communities and the ecology of natural habitats,and wild fish populations, however, environmental review is not part of the NADA process.[4]

While proponents of Frankenfish charge that GE fish can alleviate harvest pressure on native species, opponents fear the engineered fish will hasten the demise of naturally grown species by causing habitat destruction and species cross-breeding.[5]  Opponents base their claim on an example too close to ignore-raising salmon in ocean pens-an undertaking that was supposed to preserve the wild stock and feed the world.  But all over the globe, industrial-style fish farming is threatening native fish and their habitats.[6]

The appropriation of natural resources and ecosystems by salmon aquaculture, leaves a large "ecological footprint," exceeding that of wild salmon fisheries by 50,000 times.[7]  Rather than removing pressure from wild stocks, industrial aquaculture consumes wild fish by converting them into fishmeal, which is mixed with agricultural products and therapeutics. [8]  When fed to caged fish, this mixture produces concentrated forms of waste that is continuously dispersed into the surrounding marine environment.[9]  More importantly, the constituents of the mixture of waste annihilates indigenous lifeforms in the surrounding waters.[10]  The contamination leaves the allocated space so polluted that the salmon farm must be relocated within fifteen years.uses.[11]

Also, monoculture salmon often escape enclosed sea pens as illustrated by the three following examples. First, in the Pacific Northwest 440,000 Atlantic Salmon have escaped from the pens so far, endangering their wild counterparts through cross-breeding and feeding on the eggs of the native species.[12]  Second, in Machias Bay, Maine, 170,000 one-year-old salmon escaped during a winter storm in December 2000.[13]  Third, according to the Canadian government, in the past decade nearly 400,000 farm-raised Atlantic Salmon escaped into British Columbia waters and began competing with wild species for food and habitat.  Their survival ended speculation about whether farm-raised Atlantic Salmon could make it on the lam.[14]

Instead of relieving the pressure on wild salmon, industrial fish farming has become one of their greatest threats.[15]  Besides mucking up the fish farm sites and passing lice and disease to wild fish, escaped farm-raised salmon threaten to out-compete an already stressed population of wild Salmon, replacing a diverse genetic pool with a single strain of invasive fish that may be ill-adapted for long-term survival.[16]  Eric Hallerman, a Virginia Tech scientist, voiced his concern that transgenic fish can "overwhelm the wild stock."[17]  He added, "If you have a net pen that has a hundred thousand fish and 15 percent escape, that's 15,000 fish.  The wild run might only be 300 fish."[18]  In other words, the escaped transgenic fish can consume the environment and pollute the gene pool, driving the wild Salmon to extinction.

Purdue University biologists recently described a scenario in which the transgenic fish would not only compete with wild fish but would also drive them to extinction.[19]  They call this the "Trojan gene" effect.  The transgenic fish in the scientists' model were altered to achieve rapid growth; the result was males that are larger at sexual maturity.[20]  These precocious fish would likely attract more than their share of wild mates, but their offspring would be less fit.[21]  The growing ratio of engineered to wild offspring could cause the extinction of an already endangered wild population as well as the less fit transgenic fish. [22]  To quantify this, the researchers modeling the Trojan gene effect tried to predict what would happen if sixty transgenic individuals joined a wild population of 60,000 fish.  The population became extinct within just forty generations.[23]  Even a single transgenic fish could have the same effect, although extinction would take longer.[24]

Proponents of GE fish argue that the type of ecological attack evinced in high-seas fish farming will not be repeated with GE salmon.  For example, proponents propose closed-system artificial ponds that would localize any ecological harm and prevent cross-breeding.[25]  Furthermore, open-ocean pens will only be stocked with triploid female fish, ninety-nine percent of which are sterile.[26]  Nevertheless, opponents contend that once the production of GE fish becomes commercialized, it will be impossible to control the whereabouts of every single fish and assure compliance with appropriate containment measures.[27]  The history of GE crops provides clear examples of where mistakes have occurred and where unapproved varieties have been illegally planted.[28]  "Mistakes will also be made in the case of GE fish with batches being accidentally mixed and GE fish finding their way into open water.  As GE fish are intended for use on a global scale, a reliable containment regime following commercialization is just not conceivable."[29]  Just recently, fertilized GE salmon eggs might have escaped into the environment.  New Zealand's Environmental Risk Management Authority attributed the release to design flaws in King Salmon Co.'s GE salmon tanks.[30]

What GE fish proponents call "advances" in aquaculture could further damage the fisheries and fishing communities they purport to protect.  Today, Alaska's wild salmon fishery ranks among the healthiest, best managed in the world, but farm-raised Atlantic Salmon now rule the global premium fish market.[31]  Chilean-raised Atlantic Salmon are sold so cheaply in the U.S.  That they are making it hard for Alaskan fishermen to make a living.  "When you've got Chilean filets hitting the Port of Miami at $2 a pound, raised by workers making $1.50 a day, that's when the WTO hits home," says John van Amerongen, editor of the Alaska Fishermen's Journal.[32]  This is the paradox of salmon farming.  "Aquaculture," writes Rosamond Naylor, of Stanford University, "is a possible solution, but also a contributing factor, to the collapse of fisheries stocks worldwide." [33]  Thus, while fish farms decrease pressure on wild salmon, its practice subjects economically viable, sustainable fisheries to new pressure.  As the Alaskan salmon industry begins to fetch less for each fish, the incentive will turn to catching more to maintain profits, a course which will end its sustainable ways.  

By focusing on "technological and management improvements" to maximize economic growth, GE food pushes the ecological and social systems to accept the logic, time scale, and control of global capitalist markets and their corporate captains.[34]  This focus pays little attention to the complex relationships between aquaculture activities and the larger ecological system in which they are conducted.  The claim that GE food will save the wild stock and feed the world ignores the growing evidence that genetic modification will hasten the collapse of the wild salmon population, the environment, and sustainable salmon industries.  Preventing the introduction of GE fish into our waters and markets is essential to the success of wild salmon.

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[1] Jean-Michel Cousteau, GE Fish: A Threat Disguised as a Solution to World Hunger, ENTL. NEWS NETWORK, July 20, 2000, available at http://www.organicconsumers.org/ge/gefish.cfm.

[2] Don Thompson, Ruling Awaited As to Whether Gene-Altered Salmon is Safe, THE TORONTO STAR, March 11, 2002, available at 2002 WL 14570189.

[3] The Center for Food Safety, Center for Food Safety, Frequently Asked Questions, at http://www.centerforfoodsafety.org/legal/questions/questions_answers.htm#3 (last visited on March 24, 2002).

[4] Id.

[5] Thompson, supra note 2.

[6] Bruce Barcott, Aquaculture's Troubled Harvest, MOTHER JONES, November/December 2001, available at 2001 WL 23053158.

[7] Sea Web, The Aquaculture Paradox, at http:www.dafni.com/gulfsave/SeaWeb%20-%20Aquaculture.html.html (last visited March 24, 2002).

[8] Dean Bavington, From Jigging to Farming, 27 ALTERNATIVES J.L (September 22, 2001), available in 2001 WL 12278671. 1.5 to 2.3 kilograms of wild fish are required to produce a half of a kilogram of farmed salmon.

[9] Mary Liz Brenninkmeyer, Note, The Ones That Got Away: Regulating Escaped Fish and Other Pollutants From Salmon Fish Farms, 27 B.C. ENV. AFFAIRS. L. REV. 75, 76 (1999).

[10] Bavington, supra note 8.

[11] Stephanie Roth, The Horrors of Intensive Salmon Farming, 31 THE ECOLOGIST (June 1, 2001), available at 2001 WL 155162265.

[12] Niaz Dorry, Wild vs. Farmed Fish; The Blue Revolution Blues, Fishermen's Voice, August 2001, available at http://www.factoryfarm.org/fishfarming.html.

[13] Id.

[14] Barcott, supra note 6 (indicating that number relies primarily on escapes reported by fish farmers; environmentalists put the actual figure closer to one million).

[15] Cousteau, supra note 1.

[16] W.M. Muir & R.D. Howard, Possible Ecological Risks of Transgenic Organism Release when Transgenes Affect Mating Success: Sexual Selection and the Trojan Gene Hypothesis, in 96 PROCEEDINGS OF THE NATIONAL ACADEMY OF SCIENCES 13853-56 (1999).

[17] Id. (speaking at the National Academy of Sciences Meeting, a Virginia Tech scientist).

[18] Morning Edition: Debate Over Genetically Altered Fish and Meat (NPR radio broadcast, December 12, 2001).

[19] Muir & Howard, supra note 16.

[20] Id.

[21] Id.

[22] Id.

[23] Id.

[24] Id.

[25] Garth L. Fletcher et al., Current Status of Transgenic Atlantic Salmon for Aquaculture, available at http://www.aquabounty.com (lasted visited on March 24, 2002).

[26] Arnold Sutterlin et al., Environmental Risks in Using GH Transgenic Altlantic Salmon and Rainbow Trout for Commercial Marine Production in Canada, available at http://www.aquabounty.com (lasted visited on March 24, 2002).

[27] Dr. Jan van Aken, Genetically Engineered Fish: Swimming Against the Tide of Reason, January 2000, at http://www.greenpeace.org.

[28] Mary MacArthur, Canola Seed Recalled Because of Genetic Contamination, THE WESTERN PRODUCER, April 24, 1997, available at http://www.btinternet.com/~nlpwessex/Documents/canola.htm.. (In 1997, Monsanto mistakenly sold unapproved GE canola (oilseed rape) varieties in Canada and had to recall some 60,000 bags, enough for sowing 600,000 acres. Some fields where the unapproved varieties had already been sown had to be ploughed up.)

[29] Van Aken, supra note 29.

[30] Concern at Genetic Salmon Egg Escape, NEWZ INDEX, Nov. 25, 1999, available at 1999 WL 26350311.

[31] Industrial Farms a Threat, CHARLESTON GAZETTE, October 28, 2001, available at 2001 WL 6696995. See also Seafood Watch Chart, Monterey Bay Aquarium (last visited April 10, 2002)(explaining that Alaska's wild salmon fishery was the first U.S. fishery to be certified sustainable by the Marine Stewardship Council), available at http://www.mbayaq.org/efc/efc_oc/dngr_food_watch_chart.asp..

[32] Id.

[33] Id.

[34] Bavington, supra note 8.