Friday, 28 December 2012

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.


  1. I agree most new developements are motivated purely by greed but isnt that how humanity travels? I personnaly dont like GMO but love humans. How do we modify the aggressive/ greedy type without castrating ourselves?

    1. The trick is to make greed work for the good, I would say - that's what regulation is for. In other words, if what is profitable also has some substantial benefit for mankind, the picture would change, and saying no to GMO would become more difficult, especially with all the sort of safeguards mentioned here in place.

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    3. Rainer from Germany14 January 2013 at 11:42

      I don´t think "people who oppose GMOs are, as a bulk, opposed on unreasonable grounds, paranoia, spiritual concepts and anti-science however".
      Just look at the history of civil use of nuclear power. Scientists say it is risky but we can handle all the problems. The chance for a nuclear accident is maybe 1 in 10000 years or something like that. Now we have had big accidents in Harrisburg, Tschernobyl and Fukushima within the last 35 years. Not to mention the huge number of smaller accidents within that time. And this happened in so-called developed countries, dangers and so on where well known.
      And to mention this was human fault and basically there is nothing wrong with nuclear power plants doesn´t help because it can´t change the fact that scientists predictions were wrong. It seems they calculated wrong, or didn´t use the wright data for there predictions, or didn´t think of human failure, or whatever.
      So "whatever the academic credentials", why believe a schientist when she says it´s ok.

      Besides that we still have the question "cui bono?". Did all the improvements in aggriculture actually help reduce the hunger problems in the world?
      It may depend on the statistic you consult if you think the world has made any progress. But the total number of people suffering from hunger according to the UN is about 1 Billion. So whoever benefits from an advanced aggriculture, it is not them who need food. And telling the public that things get better while 1 Billion people suffer from hunger is imho not true.
      So i agree with the original article in this point, why take a risk that is good for nothing.

  2. It's been a while (like 10 years) since my college ethics courses, so you'll have to be patient with me. But one of the biggest things I took from my studies is the idea that another human being should never be viewed or treated as a means to an end, but always as an end. That has been a guiding moral standard for me since I read it forever ago.

    I have a tendency to apply that to creatures as well, and not just because I love furry mammals. What I see in the news & in the world around me (I grew up on & around farms) is that when people reduce animals to commodities, it becomes immoral. It becomes disgusting when the the farmers or the scientists exploit the animal farther and farther to create greater profit margins.

    I'm not terribly concerned about the food safety; everything I've read indicates GMO's are pretty safe. I'm not okay with people manufacturing animals. There are lots of ways we can feed hungry people that don't require the use of genetically modified fish.

  3. The problem from a layman's point of view is that the government ok's things from big lobbyists, and we simple folk think just because they say ok, it's because it's really safe, as opposed to really just financially lucrative for the company.

  4. GMOs have no spot in our current food sources. There is so little true testing and I don't believe the general public would ever hear about any negatives that came out.

  5. "To forestall possible negative environmental
    impact, it has also been engineered to carry a sex-chromosome abnormality, rendering it sterile"

    I may be a touch naive, but IMHO this is just your basic 'copyright'. When people create, say, a fish that grows faster and bigger, they don't want others to have it for free - instead, they want to sell it. So there you have your 'safeguard'.
    I am afraid it has nothing to do with actual safety (as in - preventing something universally bad for humanity) instead, it has everything to do with profits and 'fear of the unknown' that marketing departments everywhere use as a gold mine.

    1. Thanks for this comment! To be sure, this is probably the reason for the producers, but hardly why the FDA pays attention to it in its assessment. This just goes to show that the presence of profit motives as such need not be contrary to adhering to requirements of responsible risk management. For the fact is that the sterility of the "Frankenfish" salmon, while indeed having the function you mention, also drastically decreases the environmental risk of genetic leakage.

  6. Yes, of course. I might be getting ahead of myself in stressing this particular detail, but I am concerned that the more products like this are introduced to consumer market, the more dependent the market as a whole becomes. Currently you can see this happening in vegetable and grains production. Most commercially popular species are unable to reproduce naturally, so farmers are forced to buy new seeds every year, as opposed to saving some seeds from previous year's produce. Not much of a free market in this situation.

    I can (somewhat vaguely) understand environmental concerns, but we should not underestimate those other dangers. I hope that sterility of GMOs is not going to become basic requirement for approval.

  7. I don't know how to put this diplomatically, so I am going to state it outright: In my view the methodology of bioethics as a field is very poor, as the grasp of science is very weak and it looks to be a publication industry more than genuine philosophy, whatever the academic credentials. The concerns can easily be disregarded on a priori grounds, for example in the case of health problems as noted in this article and these are speculative at best. It is generally understood in the field of biology that tamed animals tend to be less resilient, hence there is no reason to believe a risk likely. For example these salmon are more likely to be caught, being larger, therefore not likelier to out-compete. The reason profit is the only motive in my view is that it becomes expensive based on a campaign by the public against GMOs that increased compliance costs. It could be considered that a certain space limit might exist within which discourse can occur. How well considered is the possibility that the discourse relating to GMOs pushes out the thought of other issues? It would be a basic ad populum fallacy to think that the popularity of this issue meant it had a genuine importance, yet, while unstated, this seems to be the only reason to think of this area of bioethics as being important.

  8. A learned article and very good points made. But I think what the scientists are targeting is not only production of a few items but they want to keep developing the science into the future where they will be able to bring dramatic improvements in the things.

    In your current evaluation when you list down benefits and risks, the benefits are too small. But if they produce it and learn from the mistakes or the experience, and then keep improving it, after some years they will reach a product which when you will evaluate, you will find the benefits much larger than the risks!

    As such I am personally against tampering of nature in this manner since it involves "life". I know it is moral stand but I don't feel comfortable with these areas.