An Open Letter to the FDA

image courtesy of Keith 'Catfish' Sutton


Come on, FDA. What’s the hurry?

Your special committee is meeting right now to decide if we should eat genetically engineered salmon.
This is a really big decision. It will set a precedent for all future GE animals, and has implications that will ripple through the entire future of the U.S. food supply.
Obviously, you’ll want to set the bar high at the outset. This is not the time for a rubber stamp approval.

There are a couple of things bugging me about this approval process.

I feel like I’ve been ambushed.
You’ve spent the past decade prepping AquaBounty Technologies for this moment, but you gave the rest of us just two weeks to play catch-up before the public hearing. It’s hundreds of pages of technical information covering everything from allergens to ecosystems.
Can I have a minute to catch my breath?

And about that data…

I see that of the four studies submitted, three came directly from AquaBounty—you know, the guys that are $50 million in the hole while they wait for the big payday. And how about that fourth study; you couldn’t come up with a peer review a little fresher than an 18 year-old industry journal?

It troubles me that all the studies took place at AquaBounty’s facility on Prince Edward Island. If they’re going to be raising the fish in Panama, you’d think they would need at least a few test runs down there. And shouldn’t they tell you the actual location of the planned facility, although I think someone said something about being near a river. I guess you figure that Panama isn’t all that big and you’ll be able to find them when you want to check up on stuff like compliance. Oh, I forgot; you won’t be doing much of that since you don’t have any authority in Panama.

I was able to get through a few sections of the report. The study on the health of the fish was a piece of cake, being so skimpy and all. I would have thought that more than 120 fish, three to six at a time, would have been studied over the last 15 or so years. It sure doesn’t seem like a whole lot of fish for a company that already has 20 million eggs on order. I also expected that the studies would have used random samples, but I see that AquaBounty was allowed to weed out the fish they didn’t want to use. Wouldn’t you guys at the FDA want to know about the abnormalities? And doesn’t that skew the results in their favor?

I‘m going easy on you here.

I’m not going to talk about the way I get the willies at the thought of conger eel DNA spliced into my dinner (I know, it sounds nicer when you call it the ocean pout), or invoke the nickname Frankenfish (that one really bugs you). And I won’t even go after the special committee you assembled for the review process, with its lone fish expert and last minute addition of a former Monsanto employee, although I wish you had looked beyond your FDA buddies and enlisted some of the environmental and fisheries experts at other government agencies, like the U.S. Fish and Wildlife Service or the National Marine Fisheries Service.

You’re telling us that the FDA will continue to monitor how the fish perform over time.
I think that now is the time to scrutinize the data and ask the hard questions; not after the approval process.
As guardians of the public health, I respectfully suggest that you get up off of your FDA asses and do your job.



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20 Responses to An Open Letter to the FDA

  1. Well, this is a late post…it’s now April, 2011. Well put article. Why not suggest to the company making the GM fish to eat them first….for a couple of years and see what happens to them. I bet you THEY won’t even eat the fish. Let’s get Mikey!

  2. Pingback: Obama's Farm Policy | Gigabiting

  3. By far the most concise and up to date information I found on this topic.

  4. Engrossing article. I know I’m a little late in posting my comment but the article was to the point and just the information I was looking for. I can’t say that I agree with all you mentioned but it was unquestionably enlightening! BTW…I found your site through a Google search. I’m an occasional visitor to your blog and will be back soon.

  5. I absolutely adore reading your blog posts, the variety of writing is smashing.This blog as usual was educational, I have had to bookmark your site and subscribe to your feed in ifeed. Your theme looks lovely.

  6. Tania Rauth says:

    WELL SAID! I’m so concerned about the future of fish, not to mention, FOOD, in this country. No one knows what the true effects are of GM foods, but why do we have to be the guinea pigs? If this gets approved I will never eat salmon again!

  7. Great blog and I share the author’s point of view – especially on the lack of proper peer review of the data submitted by Aquabounty – is FDA working for them or for us consumers? – if you are on Facebook – like this: Say NO to FrankenSalmon! Label ALL Genetically Modified Food

  8. The way that the FDA can jut push food through without adequate testing drives me crazy….. it’s not that GMOs are definitely bad for us, its just that we currently don’t have the data to show if they are safe or not!

  9. annuaire says:

    I like this. Bookmarked!

  10. suembala says:

    Guardians of the public health. Sarcasm at its best! What a great post.

    Ever wonder why wheat, peanut, soy and milk allergies have increased substantially? Way back when the Human Genome Project was launched, experts expressed concern over allergens from these GMO’s. And don’t even get me started on Monsanto! They sold the recombinant bovine growth hormone (rBGH) which has been linked to breast cancer and guess who makes the breast cancer chemo drugs as well… If you’re looking for more information about the health ramifications of GMO’s check out

    Spice Sherpa’s comment, “What’s most troublesome is the lack of humility we have as a species when it comes to our delusions of being able to successfully manipulate and control natural processes” really resonates with me.

  11. Jennifer says:

    You rock as always. Glad to hear another drum beating against the GE Salmon.

  12. Kirby Carmichael says:

    Up to 5% of the eyed-eggs will hatch into fertile, diploid salmon capable of breeding with, at the least, Atlantic salmon. AquaBounty’s Environmental Assessment shows that these fertile transgenic fish grow at a rate 563% of wild salmon, and over 3X the rate of the sterile, triploid salmon that AquaBounty and the FDA seem adamant about limiting the discussion to.

    The fertile, diploid salmon, when released into wild salmon habitat, will (according to AQ EA) eat a wider variety of foods and forage in a wider variety of places. Since the fertiles will mature within 5-7 months of hatching in freshwaters, they will consume food and dissolved oxygen at the rate of mature wild salmon – wild salmon that are mature do not forage in freshwaters. Additionally, since the triploid sterile salmon utilize 160% of the dissolved oxygen that wild salmon do, we can expect the fertile, mature diploid GM salmon to utilize over 300-500% of the dissolved oxygen that wild salmon utilize in freshwaters.

    What does this portend? Fresh water streams and tributaries depleted of most biota with the exception – in the worst case – of red, toxic anaerobic bacteria. Kiss the rivers, streams and tributaries of Northern Europe and the Atlantic Coast goodbye.

  13. Excellent, excellent, excellent. Baring my spice-laden soul open here: I cry in frustration when I realize government STILL doesn’t understand the concept of basic ecological systems. Bt corn proved to be a quiet disaster–why would salmon be any different? What’s most troublesome is the lack of humility we have as a species when it comes to our dillusions of being able to successfully manipulate and control natural processes.

  14. Sam says:

    Great post! Curious about other such reactions to the politics behind it, both from the company (such skewed research from AquaBounty? Really) and from the FDA (make a wiki, fools, use your resources)

    My two biggest issues are about the ecology, this GMO fish in an outside context where it will, no matter what happens, find a way into the wild and spawns with wild salmon

    1. What, biologically, will happen? Can it spawn with other salmon species? Will that spawn be infertile, like a mule? Will those GMO genese take over the gene pool, as the frankenfish is bred to put on weight and, thus, has an advantage in the wild?

    2. What about intellectual property? We’ve all heard about the GMO corn blowing into a neighbor’s field and the agro business lawyers showing up to fine, sue, and claim the completely uncontrollable consequences of nature as a profit generator. The same could happen here: when AquaBounty’s proprietary salmon genes find their way into wild populations, will they technically own those fish? What if they decide to put a ‘terminator’ gene in, to force aquaculturists to buy fresh stock for each generation. Would that be transferable?

    Would love to see more food policy content, fire-breathing editorial or otherwise.


  15. Elisabeth says:

    If that happens, I hope they label it as such! I will have to go on a fishing cruise ship to Alaska, where they catch the best salmon, or move to Norway! Great letter to the FDA!

  16. G Martin says:

    Well, I guess I won’t be buying anymore salmon.

  17. Susi says:

    Whatever happened to natural and wholesome? As much as I love salmon, I’d rather never eat it again than put something “genetically engineered” into my body! This is taking food a little too far!

  18. Janice says:

    Scary stuff, isn’t it.
    There’s a great explanation on Salmon Nation

  19. I completely agree. Big food companies are normally on the boards when it comes to voting for things like this or things as important. It’s absolutely right that the FDA should know about anomalies.

  20. “genetically engineered salmon”? What exactly does the term mean? Are they all manipulated by some so-called experts?
    No wonder food these days doesn’t taste like how I remembered as a kid.

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