US Approval of the GMO Salmon "Frankenfish" - Reasons for Continuous Caution Remain in the Absence of Added Value

Today, New Scientist reports about what looks like a landmark event in the USA and (due to the role of the US for the world economy, trade and global regulation affecting trade) global handling of the possibility of using genetically modified animals for food production. Other reports can be found here, here, here, here. The FDA, in a statement released on December 27, has cleared a particular brand of GM Salmon – dubbed the "Frankenfish" by my US bioethics colleague Art Caplan in a comment that is nevertheless cautiously positive of the development, at least from a food safety point of view – modified to internally produce more growth hormone and thus grow to full size faster on less feeding or larger size with maintained feeding levels. To forestall possible negative environmental impact, it has also been engineered to carry a sex-chromosome abnormality, rendering it sterile, and the production will take place in closed off settings, especially in its initial phases, where it will take place in tanks isolated from the natural environment. All of these things are expanded on in the NS piece and the links it provides. The proposal by the FDA will be open for public comment for 60 days.

Concerning the use of genetically modified organisms for food production, there are basically four issues to address: Is it good for anything, what is its benefits? How safe is it to eat and produce (in the same way as we would ask of any other crops or cattle)? How environmentally safe is it? Are the two safety levels mentioned sufficient to warrant production in light of the benefits? Art Caplan comments on the food safety side of the issue, something that has traditionally attracted lots of attention in the media. It is also angle often played by opponents of GMO for food, since immediate safety to consumers (and sometimes workers) is something that appeals very directly to people's sentiments and may thereby affect their moral and political views. However, the GMO industry likes the food safety side of the discussion very much as well, since – as a matter of fact – when assessed on the basis of actual evidence, GM food stands up pretty well compared to many more "traditionally" produced food. This is the point that Art is making and precisely for this reasons, I agree that food safety is not what the discussion should focus on with regard to GM food. However, this is far, far from deciding the issue, since there remains the environmental risk aspects of not the eating, but the actual production of the food. This has always and continue to be the overwhelming reason for a high degree of caution, skepticism and restraint in the GM food area.

In a very recent (and, I would say, seminal) book by David B. Resnik, Environmental Health Ethics, that I just finished reading and am about to review for the journal Public Health Ethics, this is the main conclusion to embrace, although it is held out that GM food may bring some rather particular food safety issues when the genetic modification concerns the production or resistance to toxic agents. Nevertheless, Resnik ends up supporting the notion of a regulated and supervised introduction of GM food, where a number of factors must be considered to decide an issue like that of the "Frankenfish" Salmon production. In my own thinking around the GM food issue – foremost in my book The Price of Precaution and the Ethics of Risk (in particular in chapter 6) – I reached a similar, yet slightly more specific, conclusion. One thing that Resnik lists among the factors to ponder is that of the value of the final product, however, there is not much of specific discussion of what the actual value of actual GM foods is (rather than what it may be). My own analysis, in contrast, takes this into account and ends up, because of this, in the position that, in fact, most actual GM food prospects are very difficult to justify in view of the environmental risks. This since most GM food provides no benefit whatsoever that cannot be had in other ways, besides a better profit margin for the producer.

So where do we end up regarding the GM salmon in light of this. Well, first of all, it should be underscored that the project has indeed put some impressive environmental safeguards in place. The environmental concerns with regard to GM food production are basically two, genetic leakage over species borders and (because of genetic leakage or other reason) ecological hazard, and these are indeed addressed by the sterility of the "Frankenfish" as well as the external measures, such as initial growth in isolated tanks. However, as we know, nature is a very complex system that we still understand only partially (to put is mildly), and there will of course be risks, uncertainties and things we currently don't know about remaining. The crucial question, therefore, is the last one formulated above, whether or not the added value of this particular product makes it worth allowing the introduction in view of the risks and uncertainties, given the safeguards described. It is here, that I become less optimistic than the FDA, Caplan and (possibly) Resnik. While there may certainly be envisioned a use of GMO technology to provide humanity with significant benefits to justify large scale introduction (under oversight) of GM food with safeguards of the sort described, the "Frankenfish" salmon, just as the "roundup ready" crops, does seem to provide benefit, first, merely of a monetary kind and, secondly, only to the producer. This is, in the GM salmon case, no different than the use of growth hormone or antibiotic feeding supplement in industrial farming. Therefore, I can see no added value of this product and thus it cannot justify its environmental risks, however small.