AquAdvantage Salmon Environmental Assessment

The AquAdvantage Salmon Environmental Assessment examines how the production of the AquAdvantage salmon, a genetically engineered (GE) salmon produced by AquaBounty Technologies, would impact the environment. Some of the main concerns addressed in the Environmental Assessment (EA) is the ability of the salmon to escape, survive in the wild, and breed with its wild counterparts. The EA was submitted with the AquAdvantage salmon's New Animal Drug Application (NADA) as part of the AquAdvantage Salmon FDA approval process.

About AquAdvantage Salmon
AquAdvantage salmon grow to market size in 16 to 18 months instead of the usual 30 required for Atlantic salmon. In early September 2010, the FDA announced findings that the GE salmon is safe to eat. If approved, the fish will be the first genetically engineered animal commercially sold as food in the United States. AquAdvantage salmon are identified as "Triploid hemizygous, all-female Atlantic salmon (Salmo salar) bearing a single copy of the α-form of the opAFP-GHc2 rDNA construct at the α-locus in the EO-1α lineage." In other words, the salmon will each have three complete sets of chromosomes instead of two, and all of the fish will be females.

Environmental Assessment
Prior to FDA approval, the AquAdvantage was required to undergo an Environmental Assessment (EA). One of the main concerns addressed in the assessment is the potential for the GE salmon to escape into the wild, particularly if it would be able to survive there and compete with wild populations and/or interbreed with wild populations.

Survival in the Wild
Could the GE salmon, if it escaped, survive in the wild? The Environmental Assessment (EA) notes the following differences in behavior between the GE salmon and its non-GE counterpart that would impact the answer to this question: "Differences appear to occur in the scale of trait expression rather than in the scope or character of the trait expressed. Major behavioral changes in GH-transgenic fish include significantly enhanced feeding motivation, increased predation mortality, reduced discrimination of prey choice, and reduced schooling tendency (Devlin et al., 2006).  The complexity of the interactions between these effects and, in turn, their interactions with the environment, makes it difficult to predict the overall fitness of GH-transgenic salmon in the environment relative to their wild counterparts."

In other words, the fast-growing transgenic salmon is more aggressive and less picky in pursuing food. Due to the high oxygen and food needs of the GE fish, the EA predicts the GE salmon would be less likely to survive in the wild compared to a non-GE Atlantic salmon: "Although these AquAdvantage relatives have demonstrated an ability to reduce their metabolic rate in response to starvation, their enhanced metabolic profile and lower initial energy reserves greatly reduce the likelihood of their growing rapidly, or even surviving, outside of the highly supportive conditions provided by commercial farming (Hallerman et al., 2007)."

Also, as noted below, salmon require temperatures ranging from about 0C to somewhere in between 23C to 28C in order to survive. (While there is documentation of salmon surviving above 23C, there is also evidence that the fish stop feeding and would eventually starve if kept in an environment above 23C long enough.)

Biological Containment
The AquAdvantage salmon will all be female triploids (fish with three compete sets of chromosomes instead of two). According to the EA: "The induction of triploidy is the only accepted method currently available for sterilizing fish on a commercial scale." However, the EA later notes that triploidy is not 100% successful at producing sterility in GE fish.

One potential problem is the possibility that some fish will not successfully become triploids. According to the EA, AquaBounty Technologies examined its effectiveness at inducing triploidy at its Prince Edward Island facility and found that it successfully averaged batches that are 99.8% triploids (with a range from 98.9% to 100%). AquaBounty Technologies plans to perform quality control tests, ensuring that "the likelihood of releasing a batch of eyed-eggs that are not at least 95% triploid is less than 0.05." (To extrapolate from these numbers, if the company produces one million fish and 98.9 percent of them are triploids, then 11,000 fish will not be triploids and, thus, will not be sterile.)

In tests, producing sterility by inducing triploidy is more successful in female fish than in males. (And all of the AquAdvantage salmon will be female.) Thus, AquaBounty is relying on the fact that all of the fish will be female as well as triploids to further prevent them from reproducing, should any of the fish actually be fertile.

Physical Containment
The application for commercialization of AquAdvantage is for only two facilities: one in Prince Edward Island, Canada (PEI) that will produce eyed-eggs, and one in Panama that will raise the GE salmon from the eyed-egg stage to market size.

At the PEI facility, any eggs that are not hatched will be incinerated. Any GE fish that are culled will be frozen and then incinerated en masse. To prevent fish from escaping with effluent, all effluent at the PEI facility will first pass through screens and filters, and will then be treated with high temperatures and chlorine. Effluent will be disposed of into local waterways.

From PEI, the eyed eggs will be shipped to Panama, "packed in a hard-plastic “Igloo” cooler containing alternating trays of eggs and wet-ice; the cooler will be bound with packing straps and further secured in a heavy-cardboard shipping container." The containers will bear bilingual warnings that say "Live Animal Product," "Not for Resale," and the following:
 * "These fish must be reared in land-based, highly contained systems that prevent their release into the environment"
 * "These fish cannot be reared in conventional cages or net pens deployed in open bodies of water"
 * "Morbid or dead fish should be disposed of in a manner consistent with local regulations."

The Panama facility will physically prevent the GE salmon from escape in a number of ways. First, the site is "located in a remote, highland area with very limited access." The facility will be surrounded by an 8 foot security fence topped with barbed wire, and entry requires going through security. Additionally, entrance gates will be locked and the area will be protected by dogs and overseen by management living on-site in an adjacent private residence.

The salmon will be raised to the fry stage in indoor tanks, later transferring to outdoor tanks. All tanks will be covered with nets to prevent fish from jumping out (or predation by birds). The water leaving the tanks passes through filters (to prevent escape by the fish), traveling to settling ponds, and eventually to local rivers.

Any dead or culled fish to be disposed of at the Panama facility will be buried on-site as follows: "Each burial pit will be excavated to an initial depth of 1.0 m (0.5-0.75 m diameter). As dead fish are deposited, they will be covered with caustic lime, followed by another layer of dead fish and caustic lime, etc., until the burial pit is ~0.5 m deep, at which point it will sealed with plastic and covered with soil. Successive pits will be located at a minimum distance of 0.5-1.0 m from those used previously; the aggregate collection of such pits will be located on high ground that is not within the 100-year flood plain... In the event that disposal capacity at the site is inadequate to handle the immediate or aggregate waste volume, alternative means of disposal will be sought."

Environment in Panama
If a fish were to escape in Panama, it would find itself in a high-elevation landlocked area of Panama, adjacent to a river that flows into the Pacific Ocean. Currently, three hydro-electric dams "divert a significant portion of the aggregate water flow from the river for power generation, returning effluent to the watershed further downstream." If diverted through these canals, the salmon would find low food availability. Four additional dams are planned. According to the EA, current and future dams and canals "constitute a significant, but not complete, barrier to fish migration to the Pacific Ocean."

Were a salmon to escape, water temperatures in the highlands would be hospitable to its survival (around 15-16 degrees C), but as it migrated towards the Pacific Ocean, ultimately it would face water temperatures approaching (or slightly above) 28C. At that temperature, it would likely be impossible for the salmon to survive.

Related SourceWatch articles

 * Biotechnology
 * Veterinary Medicine Advisory Committee
 * AquAdvantage salmon
 * AquAdvantage Salmon FDA Approval Process
 * Concerns About Science Justifying the Safety of AquAdvantage Salmon

External resources

 * Briefing Packet for AquAdvantage Salmon Veterinary Medicine Advisory Committee (PDF - 2506KB), U.S. FDA, September 20, 2010.
 * Background Document: The VMAC Meeting on Science-Based Issues Associated with AquAdvantage Salmon, U.S. FDA.
 * Environmental Assessment for AquAdvantage Salmon (Aqua Bounty Technologies, Inc.) (PDF - 1095KB), U.S. FDA.
 * Consumers Union’s Senior Scientist to Appear at Veterinary Medicine Advisory Committee Meeting on Genetically Engineered Salmon, September 19-20: Data Suggests Increased Allergy Risk; FDA Needs Much More Data Before Approval, Consumers' Union, September 17, 2010.
 * Letter from Consumers Union to FDA About Concerns On VMAC Committee Members for GE Salmon Hearing, Consumers' Union, September 15, 2010.
 * Peter Bridson, Re: FDA Veterinary Medicine Advisory Committee (VMAC) hearing September 19-20, 2010. AquAdvantage genetically engineered salmon, Seafood Watch Program, Center for the Future of the Oceans, Monterey Bay Aquarium, September 14, 2010.
 * "FDA Isn’t Fishing for Feedback on GE Salmon", Food and Water Watch, September 7, 2010.
 * FDA Regulatory Fish Encyclopedia (RFE), U.S. FDA.

External articles

 * Susan Heavey, Biotech Salmon Leaves Many Questions, Planet Ark World Environmental News, September 22, 2010.
 * Andrew Zajac, No agreement imminent on salmon labeling, Los Angeles Times, September 22, 2010.
 * Marion Nestle, The GM Salmon Saga Continues, FoodPolitics.com, September 21, 2010.
 * Mary Clare Jalonick, Modified salmon needs more tests, FDA panel says, SFGate.com, September 21, 2010.
 * Paul Voosen, Panel Advises More Aggressive FDA Analysis of Engineered Salmon, New York Times, September 21, 2010.
 * Bryan Walsh, Food: Why the Debate Over GM Salmon Misses the Point, Time, September 21, 2010
 * Lyndsey Layton, Fears over modified salmon voiced, Washington Post, September 21, 2010.
 * Jill Richardson, Why is the FDA About to Rubber Stamp GE Salmon?, Grist, September 20, 2010.
 * Andrew Pollack, Panel Leans in Favor of Engineered Salmon, New York Times, September 20, 2010.
 * Meredith Melnick, 'Frankenfish' May Soon Be Spawning: Is Genetically Modified Salmon Safe?, Time, September 19, 2010.
 * Jill Richardson, "The Creepy Science Behind Genetically Engineered "Frankenfish" About to Enter Our Food Supply Unlabeled", AlterNet, September 13, 2010.
 * "Will FDA Approve Genetically Modified Salmon?", All Things Considered, NPR, September 7, 2010.
 * Dan Kennedy, "Who dares question the industrial food system over GM salmon?", The Guardian, September 7, 2010.
 * Andrew Pollack, "Modified Salmon Is Safe, F.D.A. Says", New York Times, September 3, 2010.
 * FrankenFish: How Genetically Engineered Salmon Could Hurt Our Health and Environment, Food and Water Watch, September 2010.