Campaign for Genetically-Engineered (GE)-Free ... AWS
Campaign for Genetically-Engineered (GE)-Free Seafood Action Kit
www.gefreeseafood.org
Friends of the Earth Friends of the Earth, as an outspoken leader in the environmental and progressive communities, seeks to change the perception of the public, media and policy makers — and effect policy change — with hard-hitting, well-reasoned policy analysis and advocacy campaigns that describe what needs to be done, rather than what is seen as politically feasible or politically correct. This hard-hitting advocacy has been the key to our successful campaigns over our 43-year history. Friends of the Earth is working to ensure our food system is just and sustainable. The campaigns within our food and technology project also pressure governments to embrace the safe and precautionary management of emerging technologies, including genetically engineered food and animals, nanotechnology, and synthetic biology, which are appearing in more consumer products such as food, each year.
Campaign for GE-Free Seafood Endorsing Organizations: Alaska Marine Conservation Council Alliance for Natural Health USA American Anti-Vivisection Society Animal Welfare Institute Cascadia Wildlands Center for Biological Diversity Center for Environmental Health Center for Food Safety Consumer Federation of America Consumers Union Food Democracy Now! Food & Water Watch Friends of the Earth Global Alliance Against Industrial Aquaculture Gloucester fishermen’s Wives Association
Go Wild Campaign Healthy Child Healthy World Humane Society of the United States Humane Society Veterinary Medical Association Institute for Agriculture and Trade Policy Institute for Responsible Technology Mangrove Action Project Massachusetts Fishermen’s Partnership National Family Farm Coalition National Organic Coalition Northwest Atlantic Marine Alliance Organic Consumers Association Sierra Club Waikiki Hawaiian Civic Club Wild Salmon First
www.gefreeseafood.org
Table of Contents Introduction ……………………………………………………………………………………….. 1 How to use this Action Kit and take action in your community ……………………………….. 2 Helpful hints for talking to store managers …………………………………………………….. 3 Helpful hints for tabling for the Campaign for GE-Free Seafood …………………….. 3 Materials: Letter to companies asking them to commit to not sell genetically engineered seafood …. 5 Pledge for GE-Free Seafood ……………………………………………………………………… 8 Genetically engineered fish issue brief ……………………………………………………... 9 Genetically engineered fish FAQ ………………………………………………………………... 12 “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet …………… 14 Petition for GE-Free Seafood to grocery stores, restaurants, chefs and seafood companies .. 15
www.gefreeseafood.org
Introduction The U.S. Food & Drug Administration recently announced it was coming to a decision on the approval of genetically engineered salmon for human consumption. If approved, it would be the first-ever genetically engineered animal to be approved to enter the U.S. food supply. This will set a precedent for other genetically engineered fish and animals (including cows, chickens and pigs) to enter the global food market. Genetically engineered salmon will be sold in stores and restaurants without adequate assessment and may pose risks to human health, the environment, endangered fish populations, animal welfare and the sustainable fishing industry. A sustainable seafood market is dependent upon knowing that the fish sold at market are harvested in ways that minimize impact to the environment and wild fish stocks. Since the risks of genetically engineered fish have yet to be properly studied, they cannot pass this test and should not be allowed into the marketplace. Consumer opposition to genetically engineered animals is strong. Polls show that 91 percent of Americans do not want the FDA to allow genetically engineered fish and meat into the marketplace, the majority of consumers won’t eat genetically engineered fish if it is available, and 95 percent of consumers believe genetically engineered food animals should be labeled if the government approves them against their wishes. A growing number of consumers are choosing to purchase sustainable seafood for their families, and according to a 2013 poll, 80 percent of Americans who regularly eat fish say that sustainable practices are "important" or "very important" to them. Genetically engineered salmon are not sustainable and threaten the safe, healthy seafood supply that consumers desire. To avoid confusion in the marketplace, and ensure the consumer’s right to know, we are asking grocery stores, seafood restaurants, chefs and seafood companies to demonstrate their commitment to sustainably produced seafood and consumer choice by joining our Pledge for GE-Free Seafood, a commitment to not knowingly purchase or sell genetically engineered salmon or other genetically engineered seafood should it come to market. With your help we can ensure that genetically engineered seafood is not sold in our favorite grocery stores or restaurants! Use this toolkit to help spread the word about the Pledge for GE-Free Seafood and to learn about simple actions you can take in your community to ensure that genetically engineered fish and other genetically engineered animals are not approved or sold in the U.S. Thank you for taking action!
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www.gefreeseafood.org
How to use this Action Kit to take action in your community Here are some simple ways you can take action where you live to keep genetically engineered seafood out of our grocery stores and off our dinner plates. Step 1: Print out this action kit, which includes the following: • Introduction letter to companies • Pledge for GE-Free Seafood • Genetically engineered fish fact sheet and issue brief • “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet • Petition to grocery stores, restaurants and chefs Step 2: Bring the letter to companies, the Pledge for GE Free Seafood and “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet to your favorite local grocery or restaurant and ask to speak with the manager. State how you are a loyal customer and that you do not want to unknowingly purchase genetically engineered fish from their company. Encourage them to sign the Pledge for GE-Free Seafood and, tell them you’re going to check back in a few weeks for their response (and follow up in a few weeks to see if they’ve made this commitment). Step 3: Email us [email protected] to let us know how it went! Step 4: Table in your community! Educate your neighbors and gather petition signatures to grocery stores, restaurants and chefs (see our tabling tips on page 3). Email a scan of the signed petitions to [email protected] or send them in the mail to: Pledge for GE-Free Seafood 1100 15th St NW 11th Floor Washington, DC 20005
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Here are a few helpful hints for talking to store managers about the Pledge for GE-Free Seafood Talking to store mangers at grocery stores or restaurants can lead to real changes in company policies — retailers really do care what their customers think. Face-to-face discussions are the most direct way companies have to interact with their loyal customers, and store managers pass the information shared in these conversations with corporate offices. 1. Staple campaign materials (included in this action kit) or put them in a folder so they do not easily get lost or separated, and bring an extra copy or two. (Bring the letter to companies, the Pledge for GE Free Seafood and “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet). 2. Request a meeting with your manager in person so you can explain the Pledge for GE-Free Seafood and why their store should join the pledge. 3. You can speak to the manager by yourself or with one or two other people, but do not bring a whole group — that might scare the manager off and make him or her feel defensive from the get-go. 4. Be sure to identify yourself as a valued customer in their store and read through the campaign materials so you can answer their questions about genetically engineered fish and why committing to not sell genetically engineered seafood is good business. 5. Be polite and friendly. You are a customer and a member of the community, and the stores want to hear about what their customers think. It is okay to say “I don’t know” to topics you’re unfamiliar with. Direct managers to our website (www. gefreeseafood.org) or have them e-mail questions to [email protected].
Helpful hints for tabling for the Campaign for GE-Free Seafood Tabling to gain visibility and support for the Campaign for GE-Free Seafood and our local partners is an important grassroots activity that can recruit additional strong volunteers, attract media attention, and gather more signatures for our on-going petition to grocery stores, restaurants, and chefs to apply needed pressure on these seafood sellers. If you’ve ever been to a community health fair or a local outdoor festival with tables with information on an organization (e.g. the local PTA) or a grassroots action (e.g. “please sign this petition to xxx”) then you’ve seen tabling in action. Tabling is a great organizing method; people can approach you to talk learn more about the issue, take some literature, sign up for e-mails and take action. Where Do I Table? You can either plug into an existing event (a community health fair, an Earth Day festival, etc.) or approach a local establishment (a church, a health food store, etc.) to table on your own. Contact the event organizer or the community education or public liaison for the establishment as far in advance if possible with your offer to table. (It doesn’t hurt to call last minute if you need to — there might be space for you!)
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www.gefreeseafood.org
What Materials Will I Need? Your table needs to draw people over to you to learn more about the Pledge for GE-Free Seafood, and once folks are there, you’ll need to have education and engagement. Please see our website (www.gefreeseafood.org) to download and print campaign materials at home. Tabling Checklist __ Banner/signs; Props/photos other attention getters __ Tape, stapler, safety pins __ Pens, clipboard __ Campaign for GE-free Seafood tabling materials (included in this action kit) __ Contact info for event organizer, other volunteers __ Snacks and water Tabling Tips • Familiarize yourself with the campaign materials and the issue. • Start conversations with a short and upbeat opening, like “Hello! Have you heard about the Pledge for GE-Free Seafood?” or “Hi! Did you know the FDA is about to approve the first-ever genetically engineered animal for food?” then ask them to learn more and sign the petition. • Make sure people sign up for our e-mail list so we can share important information and expand our network! Say something like, “We’re here today to collect signatures to send to grocery stores, restaurants and chefs asking them to commit to not sell genetically engineered seafood. Would you take a second to sign?” Most folks say yes, but if someone says no you can say, “Okay, here is some information about the issue. Please visit the website if you’re interested.” • It is okay to say “I don’t know” to topics you’re unfamiliar with. Direct people to our website (www.gefreeseafood.org) or have them e-mail questions to [email protected].
www.gefreeseafood.org
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Dear CEO, On behalf of 30 consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations, representing millions of supporters, we invite your company to join the Pledge for Genetically Engineered (GE)-Free Seafood. To avoid confusion in the market place, and ensure consumer right to know, we are asking grocery stores, seafood restaurants, chefs and seafood companies to demonstrate their commitment to sustainably produced seafood and consumer choice by joining our Pledge for GE-Free Seafood, a commitment to not knowingly purchase or sell genetically engineered salmon or other GE seafood should it come to market. As a top company dedicated to meeting consumer demand for sustainable healthy food, signing the Pledge for GE-Free Seafood would be consistent with your company’s commitment to sustainability and transparency in seafood sales. Consumer opposition to genetically engineered animals is high. Polls show that 91 percent of Americans do not want the FDA to allow GE fish and meat into the marketplace,i the majority of consumers won’t eat GE fish if it is available,ii and 95 percent of consumers believe GE food animals should be labeled if the government approves the fish against their wishes.iii Unfortunately, GE seafood will likely not be labeled as such since the FDA has already said it will not require labeling,iv providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. This may lead to market confusion and consumers choosing to avoid salmon entirely. A growing number of consumers are choosing to purchase sustainable seafood for their families, and according to a 2013 poll, 80 percent of Americans who regularly eat fish say that sustainable practices are “important” or “very important” to them.v Genetically engineered salmon are not sustainable and threaten the safe, healthy seafood supply that consumers desire. The U.S. Food & Drug Administration (FDA) is currently in the final stage of review of genetically engineered farmed salmon for human consumption. If approved, this would be the first-ever genetically engineered animal allowed by a regulator to enter the world food supply. At least 35 other species of GE fish are currently under development, including trout, catfish, tilapia, striped bass, flounder, and other salmon species.vi The FDA’s decision on this GE salmon application will set a precedent, for its approval will chart a path for other GE fish and animals to enter the market. This genetically engineered animal will be entering stores without adequate assessment and may pose risks to human health, the environment, endangered fish populations, animal welfare and the sustainable fishing industry. A sustainable seafood market is dependent upon knowing that the fish sold at market are harvested in ways that minimize impact to the environment and wild fish stocks. Since the risks of GE fish have yet to be properly studied, they cannot pass this test and should not be allowed into the marketplace. To date, nearly 400,000 public comments and joint letters from over 300 environmental, consumer, health, and animal welfare organizations, along with members of Congress, salmon and fishing groups and associations, scientists, food companies, chefs and restaurants, have been sent to the FDA demanding the agency reject this application and require mandatory labeling of this transgenic salmon should it decide to approve it.
1100 15th Street, NW • 11th Floor • Washington, D.C. 20005 202.783.7400 • 202.783.0444 fax • 877.843.8687 toll free • www.foe.org
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2150 Allston Way • Suite 240 • Berkeley, CA 94704 510.900.3150 • 510.900.3155 fax • 866.217.8499 toll free
Genetically engineered salmon pose numerous human health, environmental, animal welfare, and economic concerns that are of concern to consumers and other stakeholders: •
Unfortunately, the FDA decided these fish will be safe to eat based solely on data provided by the GE salmon company. Of potential concern to human health is the fact that, according to data submitted to FDA, overall all GE salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancersvii if absorbed and biologically active in the human body. In addition, the findings on allergy risk were based on only six fish.viii This is bad science and bad food.
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GE seafood will likely not be labeled as such since the FDA has already said it will not require labeling.ix Thus we will have consumer confusion unless companies are clear in their commitment to not sell these products.
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Escaped GE salmon could present significant risk to already imperiled Atlantic salmon populations,x and escaped fish could bring diseases with them. Infectious Salmon Anemia (ISA), an extremely deadly virus to salmon which devastated salmon farms in Chile and Scotland, was found in the GE salmon egg production facility in 2009xi and was not initially reported to the FDA.xii
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GE salmon are unhealthy and suffer from skeletal deformities, jaw erosions, inflammation, lesions, increased susceptibility to disease, and increased mortality, raising serious animal welfare issues and human health concerns from eating sick fish.xiii
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Economic harm to fishers and fishing communities on both coasts could occur if escaped fish lead to decreases in wild fish populations.xiv
We will promote all companies that join the pledge and make public their policy to not knowingly purchase or sell genetically engineered (GE) salmon or other GE seafood, should it come to market. These companies will be highlighted on our websites, in social media, and in the press, so that consumers can see for themselves where a company stands on GE salmon before they go grocery shopping or dine out. Please contact Eric Hoffman, Food and Technology Campaigner at Friends of the Earth ([email protected] or 202-222-0747) so that we may discuss your company’s current policies and how your company can show its leadership in corporate sustainability by pledging to not sell genetically engineered salmon or other seafood if approved by the FDA. Thank you for your attention to this important matter. We look forward to working with your company to ensure GE salmon and other seafood are not sold in the U.S., in order to protect our health, our environment and our wild fisheries, and we hope to be able to highlight your company as an industry leader. Sincerely, Erich Pica, President Friends of the Earth
Miyoko Sakashita, Oceans Director Center for Biological Diversity
Kelly Harrell, Executive Director Alaska Marine Conservation Council
Charles Margulis, Sustainable Food Program Director Center for Environmental Health
Gretchen DuBeau, Executive and Legal Director Alliance for Natural Health USA
Andrew Kimbrell, Executive Director Center for Food Safety
Sue Leary, President American Anti-Vivisection Society
Chris Waldrop, Director, The Food Policy Institute Consumer Federation of America
Cathy Liss, President Animal Welfare Institute
Michael Hansen, Ph.d. Senior Scientist Consumers Union
Bob Ferris, Executive Director Cascadia Wildlands
Dave Murphy, Executive Director Food Democracy Now!
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Wenonah Hauter, Executive Director Food & Water Watch
Alfredo Quarto, Executive Director Mangrove Action Project
Don Staniford, Director Global Alliance Against Industrial Aquaculture
Ed Barrett, President Massachusetts Fishermen’s Partnership
Angela Sanfilippo, President Gloucester fishermen’s Wives Association
Kathy Ozer, Executive Director National Family Farm Coalition
Anne Mosness, Director Go Wild Campaign
Liana Hoodes, Executive Director National Organic Coalition
Alexandra Zissu, Editorial Director Healthy Child Healthy World
Niaz Dorry, Executive Director Northwest Atlantic Marine Alliance
Michael Greger, Director, Public Health & Animal Agriculture Humane Society of the United States
Alexis Baden-Mayer, Political Director Organic Consumers Association
Pam Runquist, Director, Veterinary Advocacy Humane Society Veterinary Medical Association
Laurel Hopwood, Chair, Genetic Engineering Action Team Sierra Club
Jim Harkness, President Institute for Agriculture and Trade Policy
Malia Nobrega-Olivera, President Waikiki Hawaiian Civic Club
Jeffrey Smith, Founder Institute for Responsible Technology
Elena Edwards, Director Wild Salmon First
i. Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10. “Americans in near unanimity on their disapproval of genetically engineered fish and meat in the marketplace” ii. Consumer Reports National Research Center. CR Poll: Two-thirds of Americans Want FDA to Inspect Domestic, Foreign Food Supply Overwhelming Majority of Consumers Want Country of Origin Labeling Loopholes Closed; GE and Cloned Animals Labeled. Http://www. consumersunion.org/pub/core_food_safety/006298.html. Consumers Union, 11 Nov. 2008. iii. Ibid. iv. Background Document: Public Hearing on the Labeling of Food Made from the AquAdvantage Salmon. Aug. 2010. . v. Barclay, Eliza. “Most Americans Eager To Buy Seafood That’s ‘Sustainable’” National Public Radio, 12 Feb. 2013. vi. Genetically Engineered Fish. Issue brief. Center for Food Safety, Jan. 2013. . vii. Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. viii. Ibid. ix. Background Document: Public Hearing on the Labeling of Food Made from the AquAdvantage Salmon. x. Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. xi. “AquaAdvantage® Salmon Draft Environmental Assessment.” Center for Veterinary Medicine, US Food and Drug Administration. 4 May 2012. Page 43. xii. Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. xiii. “Briefing Packet – AquaAdvantage Salmon,” Food and Drug Administration, Center for Veterinary Medicine. 20 September 2010. p. 36-41. xiv. Bottemiller, Helena. “Enators Introduce Bill to Ban GE Salmon.” Food Safety News, 2 Feb. 2011. Web. .
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Pledge for GE-Free Seafood: It is our policy to not knowingly purchase or sell www.gefreeseafood.org genetically engineered (GE) salmon or other GE seafood, should it come to market. Company Name*
# of Stores
Company Official (Please Sign)
Address
Company Official (Please Print)
Phone
Title Date
Fax Email Address
Please return signed form to: Friends of the Earth Eric Hoffman 1100 15th St NW, 11th Floor Washington, DC 20005 Email: [email protected] Phone: 202-222-0747
Website URL* Public Comment (Optional: Please add additional relevant comments here that your company wants to share with the public regarding its commitment).*
*Only your company name, website, and comments will be made public. Your contact information will not be shared.
Alaska Marine Conservation Council · Alliance for Natural Health USA · American Anti-Vivisection Society · Animal Welfare Institute · Cascadia Wildlands · Center for Biological Diversity · Center for Environmental Health · Center for Food Safety Consumer Federation of America · Consumers Union · Food Democracy Now! · Food & Water Watch · Friends of the Earth Global Alliance Against Industrial Aquaculture · Gloucester fishermen’s Wives Association · Go Wild Campaign Healthy Child Healthy World · Humane Society of the United States · Humane Society Veterinary Medical Association Institute for Agriculture and Trade Policy · Institute for Responsible Technology · Mangrove Action Project Massachusetts Fishermen’s Partnership · National Family Farm Coalition · National Organic Coalition · Northwest Atlantic Marine Alliance · Organic Consumers Association · Sierra Club · Waikiki Hawaiian Civic Club · Wild Salmon First
Who created this pledge and why? Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment and labeling and poses risks to human health, the environment, animal welfare and a sustainable future for fish. A group of 30 consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations are working together to ask companies to avoid these products that consumers do not want and that raise unnecessary risks to the environment and wild fisheries. Why should your company sign this pledge? By signing this pledge, your company will signal to its customers that it is a leader in supporting consumers’ right to know what they are purchasing and supporting sustainable seafood production. Who can sign? Grocery stores, seafood restaurants, chefs, and seafood companies can all sign this pledge. How will signatories be recognized? Companies that sign the above pledge will be listed on our website and in other publications. We can work with you to highlight your participation in the press, online, and elsewhere to inform others of your leadership in a way that is consistent with your corporate values. You are sure to be in good company with other leading businesses that have committed to not sell genetically-engineered seafood.
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Issue Brief
Genetically engineered fish: An unnecessary risk to the environment, public health and fishing communities The U.S. Food & Drug Administration recently announced it was coming to a decision on approval of the “AquAdvantage Salmon,” an Atlantic salmon that has been genetically engineered to supposedly be faster-growing than other farmed salmon. If approved, this would be the first-ever genetically engineered animal allowed to enter the food supply by any regulatory agency in the world. At least 35 other species of genetically engineered fish are currently under development, including trout, tilapia, striped bass, flounder and other salmon species — all modified with genes from a variety of organisms, including other fish, coral, mice, bacteria and even humans.1 The FDA’s decision on the AquAdvantage genetically engineered salmon will set a precedent and could open the floodgates for other genetically engineered fish and animals (including cows, pigs and chickens) to enter the U.S. market.
Genetically engineered salmon on the path for FDA approval Despite insufficient food safety or environmental studies, the FDA announced that it is in the process of approving the AquAdvantage Salmon, a genetically engineered Atlantic salmon produced by AquaBounty Technologies. The company originally submitted its application to the FDA in 2001 and the FDA announced in the summer of 2010 it was considering approval of this genetically engineered fish — the first genetically engineered animal intended for human consumption. In December 2012, the FDA released its draft Environmental Assessment of this genetically engineered salmon, moving the agency one step closer towards a final decision on approval. The AquAdvantage Salmon was developed by artificially combining growth hormone genes from Pacific salmon and DNA from the anti-freeze genes of an eel-like ocean pout. This modification causes the production of growth hormone year-round, creating a fish that the company claims grows at twice the rate of conventionally farmed salmon.
Threats to the environment Unfortunately, the FDA’s environmental assessment does not properly look at the risks genetically engineered fish pose to the environment.
AquaBounty claims that it will only produce sterile females in order to mitigate the risks from escaped genetically engineered salmon. However, the project specifications AquaBounty submitted to the FDA only require 95 percent of the eggs produced to be sterile, meaning that up to 5 percent of the AquAdvantage Salmon produced in a commercial batch may be fertile.2 This not only calls into question FDA’s assumption about sterility, but raises concerns about the kinds of impacts these fish may have on the environment should they escape. For example, research published in the Proceedings Photo credit: E. Peter Steenstra/USFWS. of the National Academy of Sciences concluded that a release of just 60 genetically engineered fish in a population of 60,000 could lead to the extinction of the wild population in less than 40 generations. At a minimum the FDA should provide data showing how this relevant concern will not apply to this application. Even if escaped fish are sterile they may still cause serious harm to the environment and wild fish populations. The Canadian Department of Fisheries conducted research on Coho salmon with an engineered growth hormone similar to the AquAdvantage Salmon and found that genetically engineered salmon were more aggressive when searching for food (the growth hormone made them hungrier), and in some instances resorted to cannibalism.3 The aggressive
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behavior evident in genetically engineered Coho salmon led to population crashes and even the complete extinction of some wild salmon species in the study.4
Anticipating objections to its genetically engineered fish based on the risks to the environment, AquaBounty told the FDA that it would be raising the fish in land-based fish farms. As a result, the FDA limited its environmental review to two small, land-based facilities – an egg production facility on Prince Edward Island, in Canada, and a grow-out facility in Panama where fish are raised to market size. FDA’s narrow look at this application completely ignores the fact that AquaBounty has openly referred to its plans to raise genetically engineered fish all around the world.5 Once FDA approval is granted it will be extremely difficult to track the millions of genetically engineered fish and eggs produced as AquaBounty’s operations expand. It will be equally difficult to guarantee that genetically engineered fish are raised in secure inland tanks — a reliable containment system following commercialization is just not conceivable at this time. Even in land-based facilities, farmed salmon have the ability to escape into the wild where they are virtually impossible to recover.
In addition to contaminating the gene pools of wild salmon, genetically engineered fish can spread diseases to wild populations. In 2009, AquaBounty’s egg production facility on Prince Edward Island was infected with Infectious Salmon Anemia,6 which it failed to report to the FDA.7 ISA is an extremely deadly salmon virus that decimated the Chilean and Scottish salmon farming industries. If ISA or other diseases were to break out at genetically engineered fish farms and then those fish escaped, they could wreak havoc on wild populations.
The environmental risks genetically engineered salmon pose to oceans and fisheries demand a more thorough investigation by the FDA. The agency needs to complete an Environmental Impact Statement to look at the full range of environmental risks posed by genetically engineered salmon, including the impacts of global commercialization. In addition it should conduct a quantitative failure mode analysis, which would assess where containment measures are most likely to fail and the impacts of such failures.8
Potential threats to human health While data on the human health impacts of consuming genetically engineered fish is sparse, recent studies provide cause for concern. Genetically engineered salmon have higher levels of IGF-1 (a growth hormone that may increase risk of several types of cancer if absorbed and biologically active in the human body)9 as compared to conventional farmed salmon.10 There are also concerns about the possible increased risk of allergic reactions to eating genetically engineered salmon.11
Further concern relates to the routine use of antibiotics to control diseases often found in industrial fish farms. Farmed salmon are given more antibiotics than any other livestock by weight.12 Some of these antibiotics are toxic to humans.13 Others are used in human medicine. In both cases, eating farmed fish could mean ingesting those antibiotics, possibly leading to fatal allergic reactions in the first case, or antibiotic resistance in the second.14 Unfortunately, FDA’s draft EA does not provide adequate data on the type and amount of antibiotics used in the production of AquAdvantage Salmon. The FDA has nonetheless decided these fish were safe to eat based solely on data provided by AquaBounty, whose sample sizes were as small as six to 12 fish.15 This is bad science and bad food.
Lack of federal regulation of genetically engineered fish and animals Unfortunately, there are currently no U.S. laws specifically governing the production and sale of genetically engineered animals. Instead, the FDA regulates genetically engineered animals as “new animal drugs,” using laws written well before the advent of genetic engineering for such things as chicken feed additive and cow vaccines. To receive FDA approval to sell a genetically engineered fish for human food, producers must complete a New Animal Drug Application.16
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Approving a genetically engineered animal for food under the banner of a “drug” is extremely problematic. First, animal drug laws were not written to regulate living organisms that can reproduce and move of their own accord — both of which genetically engineered animals can do. Second, the new animal drug approval process is confidential and mostly closed to the public until complete, due to confidential information laws for drug products, severely limiting public participation in the regulatory process.
Instead of relying on antiquated laws for regulating animal drugs, the FDA must develop new regulations that are specific to genetically engineered animals and take into account the risks GE animals pose to the environment, human health and related socio-economic concerns.
Put the brakes on approval of genetically engineered salmon The FDA must put the brakes on the approval of genetically engineered salmon until it has conducted a comprehensive and independent Environmental Impact Statement, and until proper laws are on the books to deal with the novel risks to human health and the environment posed by genetically engineered fish and other genetically engineered animals.
Friends of the Earth strongly opposes the approval and commercialization of genetically engineered fish and is urging the FDA to reject AquaBounty’s genetically engineered salmon. Should the FDA decide to approve the AquAdvantage genetically engineered salmon despite widespread public opposition, clear, mandatory labeling is an absolute must, in order to allow consumers to make informed purchasing decisions.
How to get involved Visit our website at www.foe.org/gefreeseafood where you can download campaign materials and read about ways to take action. You can also write to your favorite grocery stores, restaurants and chefs and ask them to join the Campaign for GE-Free Seafood. Visit the website at www.gefreeseafood.org to learn more! Companies can also visit www.gefreeseafood.org to learn more about the Pledge for GE-Free Seafood and why grocery stores, restaurants and chefs should sign the pledge!
(Endnotes) 1 Genetically Engineered Fish. Rep. Center for Food Safety, Jan. 2013. . 2 Food and Drug Administration-VMAC Briefing Packet, 2010, p.128. 3 Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. 4 Ibid. 5 Pollack, Andrew. “Engineered Fish Moves a Step Closer to Approval.” New York Times, 21 Dec. 2012. 6 “AquaAdvantage® Salmon Draft Environmental Assessment.” Page 43. 7 Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. 8 Kapuscinski, Anne, and Fredrik Sundström. Comments on Environmental Assessment for AquAdvantage Salmon and Briefing Packet on AquAdvantage Salmon for the Veterinary Medicine Advisory Committee. 9 Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. 10 Hansen, Michael. Comments of Consumers Union on Genetically Engineered Salmon, Food and Drug Administration Docket No. FDA-201034-N-0001, Veterinary Medicine Advisory Committee Meeting. Rep. Consumers Union, 16 Sept. 2010. Web. . 11 Ibid. 12 “Farmed Salmon Facts.” Wild Pacific Salmon LLC. 13 Rebecca Goldberg and Tracy Triplett. Murky Waters: The Environmental Effects of Aquaculture in the U.S. (p 44). Environmental Defense Fund (1997). 14 Hernández Serrano, Pilar. and Food and Agriculture Organization of the United Nations and Food and Agriculture Organization of the United Nations. Fish Utilization and Marketing Service Responsible use of antibiotics in aquaculture / by Pilar Hernández Serrano FAO, Rome : 2005. 15 Ibid. 16 Briefing Packet – AquaAdvantage Salmon,” Food and Drug Administration, Center for Veterinary Medicine.
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Genetically engineered fish: Frequently asked questions Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment of possible risks to human health, the environment, fish populations, animal welfare, fishing communities on both coasts and a sustainable future for fish. The U.S. Food & Drug Administration recently announced it was in the final stages of approving the genetically engineered AquAdvantage Salmon. If approved, this would be the first-ever genetically engineered animal allowed to enter the U.S. food supply. The FDA’s decision on the AquAdvantage Salmon will set a precedent and could open the floodgates for other genetically engineered fish and animals (including cows, pigs and chickens) to enter the U.S. market. What is genetically engineered salmon? The AquAdvantage Salmon is an Atlantic salmon developed by the biotech company AquaBounty Technologies by artificially combining growth hormone genes from Chinook salmon and DNA from the anti-freeze genes of an eel-like ocean pout. This modification causes the production of growth hormone year-round, creating a fish that the company claims grows at twice the rate of conventionally farmed salmon. Does the public support the approval of genetically engineered fish and animals? Polls show that 91 percent of Americans do not want the FDA to allow GE fish and meat into the marketplace1 and 95 percent of consumers believe GE food animals should be labeled.2 To date, nearly 400,000 public comments and joint letters from over 300 environmental, consumer, health, and animal welfare organizations, along with members of Congress, salmon and fishing groups and associations, food companies, chefs and restaurants have been sent to the FDA demanding the agency reject this application and require mandatory labeling of genetically engineered fish if they are approved. Will genetically engineered fish harm the environment? FDA has not yet sufficiently studied the full range of risks escaped or released AquAdvantage Salmon may pose to the environment. Studies on Coho salmon with an engineered growth hormone similar to the AquAdvantage Salmon found that genetically engineered salmon were more aggressive when searching for food (the growth hormone made them hungrier), and in some instances resorted to cannibalism. 3 The aggressive behavior evident in genetically engineered salmon led to population crashes and even the complete extinction of some wild salmon species in the study.4 Other research has shown that a release of just 60 genetically engineered fish in a population of 60,000 could lead to the extinction of the wild population in less than 40 generations.5 FDA must more thoroughly consider these and other potential risks before allowing commercialization of AquAdvantage Salmon. AquaBounty’s egg production facility on Prince Edward Island was infected with Infectious Salmon Anemia in 2009,6 which it initially failed to report to the FDA.7 This virus is extremely deadly to salmon and has decimated the Chilean and Scottish salmon farming industries. If this or other diseases were to break out at genetically engineered fish farms and then those fish escaped, they could wreak havoc on wild fish populations. Declines in wild salmon could also cause massive harm to fishers and fishing communities on both coasts. Is genetically engineered fish safe to eat? Unfortunately, the FDA decided these fish will be safe to eat based solely on data provided by AquaBounty. Of potential concern to human health is the fact that, according to data submitted to FDA, overall all GE salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancers8 if absorbed and biologically active in the human body. In addition, the findings on allergy risk were based on only six fish. 9 The fact is that the science is simply not there to say whether or not genetically fish are safe to eat and further studies are needed.
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Many people eat salmon because of its health benefits, but unfortunately it appears that genetically engineered salmon is less nutritious than other salmon. Genetically engineered salmon have been found to have a lower omega-3 to omega-6 fatty acid ratio than other salmon, 15 percent less than conventionally farmed salmon and 65 percent less than wild salmon.10 Will genetically engineered fish be labeled? Probably not. The FDA has stated it will likely not require genetically engineered salmon to be labeled, providing consumers no way of knowing whether the fish sold at their grocery store is genetically engineered. This may lead to market confusion and people choosing to avoid salmon entirely. How can I take action? Visit our website, www.gefreeseafood.org to get involved! You can also write to your favorite grocery stores, restaurants, and chefs and ask them to sign the Pledge for Genetically Engineered-Free Seafood. You can also send comments to the FDA saying you do not want genetically engineered fish to be approved. Visit www.gefreeseafood.org to learn more!
(Endnotes) 1 Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10. “Americans in near unanimity on their disapproval of genetically engineered fish and meat in the marketplace” . 2 Consumer Reports National Research Center. CR Poll: Two-thirds of Americans Want FDA to Inspect Domestic, Foreign Food Supply Overwhelming Majority of Consumers Want Country of Origin Labeling Loopholes Closed; GE and Cloned Animals Labeled. Http://www.consumersunion.org/pub/ core_food_safety/006298.html. Consumers Union, 11 Nov. 2008. 3 Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. 4 Ibid. 5 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). 6 “AquaAdvantage® Salmon Draft Environmental Assessment.” Page 43. 7 Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. 8 Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. 9 Ibid. 10 Comments of Consumers Union on GeneticallyEngineered Salmon,. 16 Sept. 2010. .
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www.gefreeseafood.org
Why should your company sign the Pledge for GE-Free Seafood? www.gefreeseafood.org Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment and labeling and poses risks to human health, the environment, animal welfare and a sustainable future for fish. At least 35 other species of genetically engineered fish are currently under development, including trout, catfish, tilapia, striped bass, flounder, and other salmon species. The FDA’s decision on this genetically engineered salmon application will set a precedent, for its approval will chart a path for other genetically engineered fish and animals to enter the market. By signing the Pledge for GE-Free Seafood, your company will signal to its customers that it is a leader in supporting consumers’ right to know what they are purchasing and supporting sustainable seafood production. Consumers do not want to eat genetically engineered seafood • Ninty-one percent of Americans do not want the FDA to allow genetically engineered fish and meat into the marketplace; • The majority of consumers won’t eat genetically engineered fish if it is available; • Ninty-five percent of consumers believe genetically engineered food animals should be labeled if the government approves the fish against their wishes; and • Eighty percent of Americans who regularly eat fish say that sustainable practices are "important" or "very important" to them. Genetically engineered fish are not sustainable and threaten the safe, healthy seafood supply that consumers desire. Genetically engineered seafood will likely not be labeled, leading to market confusion and consumer rejection • Genetically engineered seafood will likely not be labeled as such since the FDA has already said it will not require labeling, providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. This may lead to market confusion and consumers choosing to avoid salmon entirely. GE seafood is bad for the environment and bad for fish • Escaped genetically engineered salmon could present significant risk to already imperiled Atlantic salmon populations, and escaped fish could bring diseases with them. Infectious Salmon Anemia, an extremely deadly virus to salmon which devastated salmon farms in Chile and Scotland, was found in the genetically engineered salmon egg production facility in 2009 and was not initially reported to the FDA; and • Genetically engineered salmon are unhealthy and suffer from skeletal deformities, jaw erosions, inflammation, lesions, increased susceptibility to disease, and increased mortality, raising serious animal welfare issues and human health concerns from eating sick fish. GE Fish is bad for consumers and fishermen • The safety of these genetically engineered fish will be based solely on data provided by the companies producing them; • Overall, all genetically engineered salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancers if absorbed and biologically active in the human body; and • The findings on allergy risk were based on only six fish. This is bad science and bad food. Sign the Pledge for GE-Free Seafood! We will promote all companies that join the pledge and make public their policy to not knowingly purchase or sell genetically engineered salmon or other seafood, should it come to market. These companies will be highlighted on our websites, in social media, and in the press, so that consumers can see for themselves where a company stands on genetically engineered salmon before they go grocery shopping or dine out. Visit www.gefreeseafood.org to learn more and to sign the Pledge for GE-Free Seafood! www.gefreeseafood.org
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Petition to grocery stores, restaurants and chefs: Sign the Pledge for GE-Free Seafood to protect the environment and consumer right-to-know! www.gefreeseafood.org Please join Friends of the Earth and a broad coalition of 30+ consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations, representing millions of members, by signing this petition. We’ll share the petition with grocery stores, restaurants and chefs that haven’t yet signed the Pledge for GE-Free Seafood, and ask them to join up. The U.S. Food & Drug Administration is in the final stages of reviewing genetically engineered salmon for human consumption. If approved, it would be the first-ever genetically engineered animal to enter the world food supply. Unfortunately, the FDA has already said it will likely not require genetically engineered fish to be labeled, providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. By signing the Pledge for GE-Free Seafood, retail providers can let customers know they can order fish at their stores without fear of unintentionally buying genetically engineered fish for their families. We, the undersigned, call on grocery stores, restaurants and chefs to protect their customers and the environment by signing the Pledge for GE-Free Seafood!
Name
Email (Join our advocacy network! We’ll e-mail State Zip code you campaign action alerts and updates.)
Please send completed petitions to: Friends of the Earth, 1100 15th St NW, 11th Floor, Washington, D.C. 20005; Fax: 202-783-0444
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www.gefreeseafood.org
www.gefreeseafood.org
Friends of the Earth Friends of the Earth, as an outspoken leader in the environmental and progressive communities, seeks to change the perception of the public, media and policy makers — and effect policy change — with hard-hitting, well-reasoned policy analysis and advocacy campaigns that describe what needs to be done, rather than what is seen as politically feasible or politically correct. This hard-hitting advocacy has been the key to our successful campaigns over our 43-year history. Friends of the Earth is working to ensure our food system is just and sustainable. The campaigns within our food and technology project also pressure governments to embrace the safe and precautionary management of emerging technologies, including genetically engineered food and animals, nanotechnology, and synthetic biology, which are appearing in more consumer products such as food, each year.
Campaign for GE-Free Seafood Endorsing Organizations: Alaska Marine Conservation Council Alliance for Natural Health USA American Anti-Vivisection Society Animal Welfare Institute Cascadia Wildlands Center for Biological Diversity Center for Environmental Health Center for Food Safety Consumer Federation of America Consumers Union Food Democracy Now! Food & Water Watch Friends of the Earth Global Alliance Against Industrial Aquaculture Gloucester fishermen’s Wives Association
Go Wild Campaign Healthy Child Healthy World Humane Society of the United States Humane Society Veterinary Medical Association Institute for Agriculture and Trade Policy Institute for Responsible Technology Mangrove Action Project Massachusetts Fishermen’s Partnership National Family Farm Coalition National Organic Coalition Northwest Atlantic Marine Alliance Organic Consumers Association Sierra Club Waikiki Hawaiian Civic Club Wild Salmon First
www.gefreeseafood.org
Table of Contents Introduction ……………………………………………………………………………………….. 1 How to use this Action Kit and take action in your community ……………………………….. 2 Helpful hints for talking to store managers …………………………………………………….. 3 Helpful hints for tabling for the Campaign for GE-Free Seafood …………………….. 3 Materials: Letter to companies asking them to commit to not sell genetically engineered seafood …. 5 Pledge for GE-Free Seafood ……………………………………………………………………… 8 Genetically engineered fish issue brief ……………………………………………………... 9 Genetically engineered fish FAQ ………………………………………………………………... 12 “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet …………… 14 Petition for GE-Free Seafood to grocery stores, restaurants, chefs and seafood companies .. 15
www.gefreeseafood.org
Introduction The U.S. Food & Drug Administration recently announced it was coming to a decision on the approval of genetically engineered salmon for human consumption. If approved, it would be the first-ever genetically engineered animal to be approved to enter the U.S. food supply. This will set a precedent for other genetically engineered fish and animals (including cows, chickens and pigs) to enter the global food market. Genetically engineered salmon will be sold in stores and restaurants without adequate assessment and may pose risks to human health, the environment, endangered fish populations, animal welfare and the sustainable fishing industry. A sustainable seafood market is dependent upon knowing that the fish sold at market are harvested in ways that minimize impact to the environment and wild fish stocks. Since the risks of genetically engineered fish have yet to be properly studied, they cannot pass this test and should not be allowed into the marketplace. Consumer opposition to genetically engineered animals is strong. Polls show that 91 percent of Americans do not want the FDA to allow genetically engineered fish and meat into the marketplace, the majority of consumers won’t eat genetically engineered fish if it is available, and 95 percent of consumers believe genetically engineered food animals should be labeled if the government approves them against their wishes. A growing number of consumers are choosing to purchase sustainable seafood for their families, and according to a 2013 poll, 80 percent of Americans who regularly eat fish say that sustainable practices are "important" or "very important" to them. Genetically engineered salmon are not sustainable and threaten the safe, healthy seafood supply that consumers desire. To avoid confusion in the marketplace, and ensure the consumer’s right to know, we are asking grocery stores, seafood restaurants, chefs and seafood companies to demonstrate their commitment to sustainably produced seafood and consumer choice by joining our Pledge for GE-Free Seafood, a commitment to not knowingly purchase or sell genetically engineered salmon or other genetically engineered seafood should it come to market. With your help we can ensure that genetically engineered seafood is not sold in our favorite grocery stores or restaurants! Use this toolkit to help spread the word about the Pledge for GE-Free Seafood and to learn about simple actions you can take in your community to ensure that genetically engineered fish and other genetically engineered animals are not approved or sold in the U.S. Thank you for taking action!
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How to use this Action Kit to take action in your community Here are some simple ways you can take action where you live to keep genetically engineered seafood out of our grocery stores and off our dinner plates. Step 1: Print out this action kit, which includes the following: • Introduction letter to companies • Pledge for GE-Free Seafood • Genetically engineered fish fact sheet and issue brief • “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet • Petition to grocery stores, restaurants and chefs Step 2: Bring the letter to companies, the Pledge for GE Free Seafood and “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet to your favorite local grocery or restaurant and ask to speak with the manager. State how you are a loyal customer and that you do not want to unknowingly purchase genetically engineered fish from their company. Encourage them to sign the Pledge for GE-Free Seafood and, tell them you’re going to check back in a few weeks for their response (and follow up in a few weeks to see if they’ve made this commitment). Step 3: Email us [email protected] to let us know how it went! Step 4: Table in your community! Educate your neighbors and gather petition signatures to grocery stores, restaurants and chefs (see our tabling tips on page 3). Email a scan of the signed petitions to [email protected] or send them in the mail to: Pledge for GE-Free Seafood 1100 15th St NW 11th Floor Washington, DC 20005
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Here are a few helpful hints for talking to store managers about the Pledge for GE-Free Seafood Talking to store mangers at grocery stores or restaurants can lead to real changes in company policies — retailers really do care what their customers think. Face-to-face discussions are the most direct way companies have to interact with their loyal customers, and store managers pass the information shared in these conversations with corporate offices. 1. Staple campaign materials (included in this action kit) or put them in a folder so they do not easily get lost or separated, and bring an extra copy or two. (Bring the letter to companies, the Pledge for GE Free Seafood and “Why should your company sign the Pledge for GE-Free Seafood?” fact sheet). 2. Request a meeting with your manager in person so you can explain the Pledge for GE-Free Seafood and why their store should join the pledge. 3. You can speak to the manager by yourself or with one or two other people, but do not bring a whole group — that might scare the manager off and make him or her feel defensive from the get-go. 4. Be sure to identify yourself as a valued customer in their store and read through the campaign materials so you can answer their questions about genetically engineered fish and why committing to not sell genetically engineered seafood is good business. 5. Be polite and friendly. You are a customer and a member of the community, and the stores want to hear about what their customers think. It is okay to say “I don’t know” to topics you’re unfamiliar with. Direct managers to our website (www. gefreeseafood.org) or have them e-mail questions to [email protected].
Helpful hints for tabling for the Campaign for GE-Free Seafood Tabling to gain visibility and support for the Campaign for GE-Free Seafood and our local partners is an important grassroots activity that can recruit additional strong volunteers, attract media attention, and gather more signatures for our on-going petition to grocery stores, restaurants, and chefs to apply needed pressure on these seafood sellers. If you’ve ever been to a community health fair or a local outdoor festival with tables with information on an organization (e.g. the local PTA) or a grassroots action (e.g. “please sign this petition to xxx”) then you’ve seen tabling in action. Tabling is a great organizing method; people can approach you to talk learn more about the issue, take some literature, sign up for e-mails and take action. Where Do I Table? You can either plug into an existing event (a community health fair, an Earth Day festival, etc.) or approach a local establishment (a church, a health food store, etc.) to table on your own. Contact the event organizer or the community education or public liaison for the establishment as far in advance if possible with your offer to table. (It doesn’t hurt to call last minute if you need to — there might be space for you!)
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What Materials Will I Need? Your table needs to draw people over to you to learn more about the Pledge for GE-Free Seafood, and once folks are there, you’ll need to have education and engagement. Please see our website (www.gefreeseafood.org) to download and print campaign materials at home. Tabling Checklist __ Banner/signs; Props/photos other attention getters __ Tape, stapler, safety pins __ Pens, clipboard __ Campaign for GE-free Seafood tabling materials (included in this action kit) __ Contact info for event organizer, other volunteers __ Snacks and water Tabling Tips • Familiarize yourself with the campaign materials and the issue. • Start conversations with a short and upbeat opening, like “Hello! Have you heard about the Pledge for GE-Free Seafood?” or “Hi! Did you know the FDA is about to approve the first-ever genetically engineered animal for food?” then ask them to learn more and sign the petition. • Make sure people sign up for our e-mail list so we can share important information and expand our network! Say something like, “We’re here today to collect signatures to send to grocery stores, restaurants and chefs asking them to commit to not sell genetically engineered seafood. Would you take a second to sign?” Most folks say yes, but if someone says no you can say, “Okay, here is some information about the issue. Please visit the website if you’re interested.” • It is okay to say “I don’t know” to topics you’re unfamiliar with. Direct people to our website (www.gefreeseafood.org) or have them e-mail questions to [email protected].
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Dear CEO, On behalf of 30 consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations, representing millions of supporters, we invite your company to join the Pledge for Genetically Engineered (GE)-Free Seafood. To avoid confusion in the market place, and ensure consumer right to know, we are asking grocery stores, seafood restaurants, chefs and seafood companies to demonstrate their commitment to sustainably produced seafood and consumer choice by joining our Pledge for GE-Free Seafood, a commitment to not knowingly purchase or sell genetically engineered salmon or other GE seafood should it come to market. As a top company dedicated to meeting consumer demand for sustainable healthy food, signing the Pledge for GE-Free Seafood would be consistent with your company’s commitment to sustainability and transparency in seafood sales. Consumer opposition to genetically engineered animals is high. Polls show that 91 percent of Americans do not want the FDA to allow GE fish and meat into the marketplace,i the majority of consumers won’t eat GE fish if it is available,ii and 95 percent of consumers believe GE food animals should be labeled if the government approves the fish against their wishes.iii Unfortunately, GE seafood will likely not be labeled as such since the FDA has already said it will not require labeling,iv providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. This may lead to market confusion and consumers choosing to avoid salmon entirely. A growing number of consumers are choosing to purchase sustainable seafood for their families, and according to a 2013 poll, 80 percent of Americans who regularly eat fish say that sustainable practices are “important” or “very important” to them.v Genetically engineered salmon are not sustainable and threaten the safe, healthy seafood supply that consumers desire. The U.S. Food & Drug Administration (FDA) is currently in the final stage of review of genetically engineered farmed salmon for human consumption. If approved, this would be the first-ever genetically engineered animal allowed by a regulator to enter the world food supply. At least 35 other species of GE fish are currently under development, including trout, catfish, tilapia, striped bass, flounder, and other salmon species.vi The FDA’s decision on this GE salmon application will set a precedent, for its approval will chart a path for other GE fish and animals to enter the market. This genetically engineered animal will be entering stores without adequate assessment and may pose risks to human health, the environment, endangered fish populations, animal welfare and the sustainable fishing industry. A sustainable seafood market is dependent upon knowing that the fish sold at market are harvested in ways that minimize impact to the environment and wild fish stocks. Since the risks of GE fish have yet to be properly studied, they cannot pass this test and should not be allowed into the marketplace. To date, nearly 400,000 public comments and joint letters from over 300 environmental, consumer, health, and animal welfare organizations, along with members of Congress, salmon and fishing groups and associations, scientists, food companies, chefs and restaurants, have been sent to the FDA demanding the agency reject this application and require mandatory labeling of this transgenic salmon should it decide to approve it.
1100 15th Street, NW • 11th Floor • Washington, D.C. 20005 202.783.7400 • 202.783.0444 fax • 877.843.8687 toll free • www.foe.org
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2150 Allston Way • Suite 240 • Berkeley, CA 94704 510.900.3150 • 510.900.3155 fax • 866.217.8499 toll free
Genetically engineered salmon pose numerous human health, environmental, animal welfare, and economic concerns that are of concern to consumers and other stakeholders: •
Unfortunately, the FDA decided these fish will be safe to eat based solely on data provided by the GE salmon company. Of potential concern to human health is the fact that, according to data submitted to FDA, overall all GE salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancersvii if absorbed and biologically active in the human body. In addition, the findings on allergy risk were based on only six fish.viii This is bad science and bad food.
•
GE seafood will likely not be labeled as such since the FDA has already said it will not require labeling.ix Thus we will have consumer confusion unless companies are clear in their commitment to not sell these products.
•
Escaped GE salmon could present significant risk to already imperiled Atlantic salmon populations,x and escaped fish could bring diseases with them. Infectious Salmon Anemia (ISA), an extremely deadly virus to salmon which devastated salmon farms in Chile and Scotland, was found in the GE salmon egg production facility in 2009xi and was not initially reported to the FDA.xii
•
GE salmon are unhealthy and suffer from skeletal deformities, jaw erosions, inflammation, lesions, increased susceptibility to disease, and increased mortality, raising serious animal welfare issues and human health concerns from eating sick fish.xiii
•
Economic harm to fishers and fishing communities on both coasts could occur if escaped fish lead to decreases in wild fish populations.xiv
We will promote all companies that join the pledge and make public their policy to not knowingly purchase or sell genetically engineered (GE) salmon or other GE seafood, should it come to market. These companies will be highlighted on our websites, in social media, and in the press, so that consumers can see for themselves where a company stands on GE salmon before they go grocery shopping or dine out. Please contact Eric Hoffman, Food and Technology Campaigner at Friends of the Earth ([email protected] or 202-222-0747) so that we may discuss your company’s current policies and how your company can show its leadership in corporate sustainability by pledging to not sell genetically engineered salmon or other seafood if approved by the FDA. Thank you for your attention to this important matter. We look forward to working with your company to ensure GE salmon and other seafood are not sold in the U.S., in order to protect our health, our environment and our wild fisheries, and we hope to be able to highlight your company as an industry leader. Sincerely, Erich Pica, President Friends of the Earth
Miyoko Sakashita, Oceans Director Center for Biological Diversity
Kelly Harrell, Executive Director Alaska Marine Conservation Council
Charles Margulis, Sustainable Food Program Director Center for Environmental Health
Gretchen DuBeau, Executive and Legal Director Alliance for Natural Health USA
Andrew Kimbrell, Executive Director Center for Food Safety
Sue Leary, President American Anti-Vivisection Society
Chris Waldrop, Director, The Food Policy Institute Consumer Federation of America
Cathy Liss, President Animal Welfare Institute
Michael Hansen, Ph.d. Senior Scientist Consumers Union
Bob Ferris, Executive Director Cascadia Wildlands
Dave Murphy, Executive Director Food Democracy Now!
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Wenonah Hauter, Executive Director Food & Water Watch
Alfredo Quarto, Executive Director Mangrove Action Project
Don Staniford, Director Global Alliance Against Industrial Aquaculture
Ed Barrett, President Massachusetts Fishermen’s Partnership
Angela Sanfilippo, President Gloucester fishermen’s Wives Association
Kathy Ozer, Executive Director National Family Farm Coalition
Anne Mosness, Director Go Wild Campaign
Liana Hoodes, Executive Director National Organic Coalition
Alexandra Zissu, Editorial Director Healthy Child Healthy World
Niaz Dorry, Executive Director Northwest Atlantic Marine Alliance
Michael Greger, Director, Public Health & Animal Agriculture Humane Society of the United States
Alexis Baden-Mayer, Political Director Organic Consumers Association
Pam Runquist, Director, Veterinary Advocacy Humane Society Veterinary Medical Association
Laurel Hopwood, Chair, Genetic Engineering Action Team Sierra Club
Jim Harkness, President Institute for Agriculture and Trade Policy
Malia Nobrega-Olivera, President Waikiki Hawaiian Civic Club
Jeffrey Smith, Founder Institute for Responsible Technology
Elena Edwards, Director Wild Salmon First
i. Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10. “Americans in near unanimity on their disapproval of genetically engineered fish and meat in the marketplace” ii. Consumer Reports National Research Center. CR Poll: Two-thirds of Americans Want FDA to Inspect Domestic, Foreign Food Supply Overwhelming Majority of Consumers Want Country of Origin Labeling Loopholes Closed; GE and Cloned Animals Labeled. Http://www. consumersunion.org/pub/core_food_safety/006298.html. Consumers Union, 11 Nov. 2008. iii. Ibid. iv. Background Document: Public Hearing on the Labeling of Food Made from the AquAdvantage Salmon. Aug. 2010. . v. Barclay, Eliza. “Most Americans Eager To Buy Seafood That’s ‘Sustainable’” National Public Radio, 12 Feb. 2013. vi. Genetically Engineered Fish. Issue brief. Center for Food Safety, Jan. 2013. . vii. Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. viii. Ibid. ix. Background Document: Public Hearing on the Labeling of Food Made from the AquAdvantage Salmon. x. Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. xi. “AquaAdvantage® Salmon Draft Environmental Assessment.” Center for Veterinary Medicine, US Food and Drug Administration. 4 May 2012. Page 43. xii. Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. xiii. “Briefing Packet – AquaAdvantage Salmon,” Food and Drug Administration, Center for Veterinary Medicine. 20 September 2010. p. 36-41. xiv. Bottemiller, Helena. “Enators Introduce Bill to Ban GE Salmon.” Food Safety News, 2 Feb. 2011. Web. .
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Pledge for GE-Free Seafood: It is our policy to not knowingly purchase or sell www.gefreeseafood.org genetically engineered (GE) salmon or other GE seafood, should it come to market. Company Name*
# of Stores
Company Official (Please Sign)
Address
Company Official (Please Print)
Phone
Title Date
Fax Email Address
Please return signed form to: Friends of the Earth Eric Hoffman 1100 15th St NW, 11th Floor Washington, DC 20005 Email: [email protected] Phone: 202-222-0747
Website URL* Public Comment (Optional: Please add additional relevant comments here that your company wants to share with the public regarding its commitment).*
*Only your company name, website, and comments will be made public. Your contact information will not be shared.
Alaska Marine Conservation Council · Alliance for Natural Health USA · American Anti-Vivisection Society · Animal Welfare Institute · Cascadia Wildlands · Center for Biological Diversity · Center for Environmental Health · Center for Food Safety Consumer Federation of America · Consumers Union · Food Democracy Now! · Food & Water Watch · Friends of the Earth Global Alliance Against Industrial Aquaculture · Gloucester fishermen’s Wives Association · Go Wild Campaign Healthy Child Healthy World · Humane Society of the United States · Humane Society Veterinary Medical Association Institute for Agriculture and Trade Policy · Institute for Responsible Technology · Mangrove Action Project Massachusetts Fishermen’s Partnership · National Family Farm Coalition · National Organic Coalition · Northwest Atlantic Marine Alliance · Organic Consumers Association · Sierra Club · Waikiki Hawaiian Civic Club · Wild Salmon First
Who created this pledge and why? Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment and labeling and poses risks to human health, the environment, animal welfare and a sustainable future for fish. A group of 30 consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations are working together to ask companies to avoid these products that consumers do not want and that raise unnecessary risks to the environment and wild fisheries. Why should your company sign this pledge? By signing this pledge, your company will signal to its customers that it is a leader in supporting consumers’ right to know what they are purchasing and supporting sustainable seafood production. Who can sign? Grocery stores, seafood restaurants, chefs, and seafood companies can all sign this pledge. How will signatories be recognized? Companies that sign the above pledge will be listed on our website and in other publications. We can work with you to highlight your participation in the press, online, and elsewhere to inform others of your leadership in a way that is consistent with your corporate values. You are sure to be in good company with other leading businesses that have committed to not sell genetically-engineered seafood.
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Issue Brief
Genetically engineered fish: An unnecessary risk to the environment, public health and fishing communities The U.S. Food & Drug Administration recently announced it was coming to a decision on approval of the “AquAdvantage Salmon,” an Atlantic salmon that has been genetically engineered to supposedly be faster-growing than other farmed salmon. If approved, this would be the first-ever genetically engineered animal allowed to enter the food supply by any regulatory agency in the world. At least 35 other species of genetically engineered fish are currently under development, including trout, tilapia, striped bass, flounder and other salmon species — all modified with genes from a variety of organisms, including other fish, coral, mice, bacteria and even humans.1 The FDA’s decision on the AquAdvantage genetically engineered salmon will set a precedent and could open the floodgates for other genetically engineered fish and animals (including cows, pigs and chickens) to enter the U.S. market.
Genetically engineered salmon on the path for FDA approval Despite insufficient food safety or environmental studies, the FDA announced that it is in the process of approving the AquAdvantage Salmon, a genetically engineered Atlantic salmon produced by AquaBounty Technologies. The company originally submitted its application to the FDA in 2001 and the FDA announced in the summer of 2010 it was considering approval of this genetically engineered fish — the first genetically engineered animal intended for human consumption. In December 2012, the FDA released its draft Environmental Assessment of this genetically engineered salmon, moving the agency one step closer towards a final decision on approval. The AquAdvantage Salmon was developed by artificially combining growth hormone genes from Pacific salmon and DNA from the anti-freeze genes of an eel-like ocean pout. This modification causes the production of growth hormone year-round, creating a fish that the company claims grows at twice the rate of conventionally farmed salmon.
Threats to the environment Unfortunately, the FDA’s environmental assessment does not properly look at the risks genetically engineered fish pose to the environment.
AquaBounty claims that it will only produce sterile females in order to mitigate the risks from escaped genetically engineered salmon. However, the project specifications AquaBounty submitted to the FDA only require 95 percent of the eggs produced to be sterile, meaning that up to 5 percent of the AquAdvantage Salmon produced in a commercial batch may be fertile.2 This not only calls into question FDA’s assumption about sterility, but raises concerns about the kinds of impacts these fish may have on the environment should they escape. For example, research published in the Proceedings Photo credit: E. Peter Steenstra/USFWS. of the National Academy of Sciences concluded that a release of just 60 genetically engineered fish in a population of 60,000 could lead to the extinction of the wild population in less than 40 generations. At a minimum the FDA should provide data showing how this relevant concern will not apply to this application. Even if escaped fish are sterile they may still cause serious harm to the environment and wild fish populations. The Canadian Department of Fisheries conducted research on Coho salmon with an engineered growth hormone similar to the AquAdvantage Salmon and found that genetically engineered salmon were more aggressive when searching for food (the growth hormone made them hungrier), and in some instances resorted to cannibalism.3 The aggressive
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behavior evident in genetically engineered Coho salmon led to population crashes and even the complete extinction of some wild salmon species in the study.4
Anticipating objections to its genetically engineered fish based on the risks to the environment, AquaBounty told the FDA that it would be raising the fish in land-based fish farms. As a result, the FDA limited its environmental review to two small, land-based facilities – an egg production facility on Prince Edward Island, in Canada, and a grow-out facility in Panama where fish are raised to market size. FDA’s narrow look at this application completely ignores the fact that AquaBounty has openly referred to its plans to raise genetically engineered fish all around the world.5 Once FDA approval is granted it will be extremely difficult to track the millions of genetically engineered fish and eggs produced as AquaBounty’s operations expand. It will be equally difficult to guarantee that genetically engineered fish are raised in secure inland tanks — a reliable containment system following commercialization is just not conceivable at this time. Even in land-based facilities, farmed salmon have the ability to escape into the wild where they are virtually impossible to recover.
In addition to contaminating the gene pools of wild salmon, genetically engineered fish can spread diseases to wild populations. In 2009, AquaBounty’s egg production facility on Prince Edward Island was infected with Infectious Salmon Anemia,6 which it failed to report to the FDA.7 ISA is an extremely deadly salmon virus that decimated the Chilean and Scottish salmon farming industries. If ISA or other diseases were to break out at genetically engineered fish farms and then those fish escaped, they could wreak havoc on wild populations.
The environmental risks genetically engineered salmon pose to oceans and fisheries demand a more thorough investigation by the FDA. The agency needs to complete an Environmental Impact Statement to look at the full range of environmental risks posed by genetically engineered salmon, including the impacts of global commercialization. In addition it should conduct a quantitative failure mode analysis, which would assess where containment measures are most likely to fail and the impacts of such failures.8
Potential threats to human health While data on the human health impacts of consuming genetically engineered fish is sparse, recent studies provide cause for concern. Genetically engineered salmon have higher levels of IGF-1 (a growth hormone that may increase risk of several types of cancer if absorbed and biologically active in the human body)9 as compared to conventional farmed salmon.10 There are also concerns about the possible increased risk of allergic reactions to eating genetically engineered salmon.11
Further concern relates to the routine use of antibiotics to control diseases often found in industrial fish farms. Farmed salmon are given more antibiotics than any other livestock by weight.12 Some of these antibiotics are toxic to humans.13 Others are used in human medicine. In both cases, eating farmed fish could mean ingesting those antibiotics, possibly leading to fatal allergic reactions in the first case, or antibiotic resistance in the second.14 Unfortunately, FDA’s draft EA does not provide adequate data on the type and amount of antibiotics used in the production of AquAdvantage Salmon. The FDA has nonetheless decided these fish were safe to eat based solely on data provided by AquaBounty, whose sample sizes were as small as six to 12 fish.15 This is bad science and bad food.
Lack of federal regulation of genetically engineered fish and animals Unfortunately, there are currently no U.S. laws specifically governing the production and sale of genetically engineered animals. Instead, the FDA regulates genetically engineered animals as “new animal drugs,” using laws written well before the advent of genetic engineering for such things as chicken feed additive and cow vaccines. To receive FDA approval to sell a genetically engineered fish for human food, producers must complete a New Animal Drug Application.16
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Approving a genetically engineered animal for food under the banner of a “drug” is extremely problematic. First, animal drug laws were not written to regulate living organisms that can reproduce and move of their own accord — both of which genetically engineered animals can do. Second, the new animal drug approval process is confidential and mostly closed to the public until complete, due to confidential information laws for drug products, severely limiting public participation in the regulatory process.
Instead of relying on antiquated laws for regulating animal drugs, the FDA must develop new regulations that are specific to genetically engineered animals and take into account the risks GE animals pose to the environment, human health and related socio-economic concerns.
Put the brakes on approval of genetically engineered salmon The FDA must put the brakes on the approval of genetically engineered salmon until it has conducted a comprehensive and independent Environmental Impact Statement, and until proper laws are on the books to deal with the novel risks to human health and the environment posed by genetically engineered fish and other genetically engineered animals.
Friends of the Earth strongly opposes the approval and commercialization of genetically engineered fish and is urging the FDA to reject AquaBounty’s genetically engineered salmon. Should the FDA decide to approve the AquAdvantage genetically engineered salmon despite widespread public opposition, clear, mandatory labeling is an absolute must, in order to allow consumers to make informed purchasing decisions.
How to get involved Visit our website at www.foe.org/gefreeseafood where you can download campaign materials and read about ways to take action. You can also write to your favorite grocery stores, restaurants and chefs and ask them to join the Campaign for GE-Free Seafood. Visit the website at www.gefreeseafood.org to learn more! Companies can also visit www.gefreeseafood.org to learn more about the Pledge for GE-Free Seafood and why grocery stores, restaurants and chefs should sign the pledge!
(Endnotes) 1 Genetically Engineered Fish. Rep. Center for Food Safety, Jan. 2013. . 2 Food and Drug Administration-VMAC Briefing Packet, 2010, p.128. 3 Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. 4 Ibid. 5 Pollack, Andrew. “Engineered Fish Moves a Step Closer to Approval.” New York Times, 21 Dec. 2012. 6 “AquaAdvantage® Salmon Draft Environmental Assessment.” Page 43. 7 Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. 8 Kapuscinski, Anne, and Fredrik Sundström. Comments on Environmental Assessment for AquAdvantage Salmon and Briefing Packet on AquAdvantage Salmon for the Veterinary Medicine Advisory Committee. 9 Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. 10 Hansen, Michael. Comments of Consumers Union on Genetically Engineered Salmon, Food and Drug Administration Docket No. FDA-201034-N-0001, Veterinary Medicine Advisory Committee Meeting. Rep. Consumers Union, 16 Sept. 2010. Web. . 11 Ibid. 12 “Farmed Salmon Facts.” Wild Pacific Salmon LLC. 13 Rebecca Goldberg and Tracy Triplett. Murky Waters: The Environmental Effects of Aquaculture in the U.S. (p 44). Environmental Defense Fund (1997). 14 Hernández Serrano, Pilar. and Food and Agriculture Organization of the United Nations and Food and Agriculture Organization of the United Nations. Fish Utilization and Marketing Service Responsible use of antibiotics in aquaculture / by Pilar Hernández Serrano FAO, Rome : 2005. 15 Ibid. 16 Briefing Packet – AquaAdvantage Salmon,” Food and Drug Administration, Center for Veterinary Medicine.
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Genetically engineered fish: Frequently asked questions Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment of possible risks to human health, the environment, fish populations, animal welfare, fishing communities on both coasts and a sustainable future for fish. The U.S. Food & Drug Administration recently announced it was in the final stages of approving the genetically engineered AquAdvantage Salmon. If approved, this would be the first-ever genetically engineered animal allowed to enter the U.S. food supply. The FDA’s decision on the AquAdvantage Salmon will set a precedent and could open the floodgates for other genetically engineered fish and animals (including cows, pigs and chickens) to enter the U.S. market. What is genetically engineered salmon? The AquAdvantage Salmon is an Atlantic salmon developed by the biotech company AquaBounty Technologies by artificially combining growth hormone genes from Chinook salmon and DNA from the anti-freeze genes of an eel-like ocean pout. This modification causes the production of growth hormone year-round, creating a fish that the company claims grows at twice the rate of conventionally farmed salmon. Does the public support the approval of genetically engineered fish and animals? Polls show that 91 percent of Americans do not want the FDA to allow GE fish and meat into the marketplace1 and 95 percent of consumers believe GE food animals should be labeled.2 To date, nearly 400,000 public comments and joint letters from over 300 environmental, consumer, health, and animal welfare organizations, along with members of Congress, salmon and fishing groups and associations, food companies, chefs and restaurants have been sent to the FDA demanding the agency reject this application and require mandatory labeling of genetically engineered fish if they are approved. Will genetically engineered fish harm the environment? FDA has not yet sufficiently studied the full range of risks escaped or released AquAdvantage Salmon may pose to the environment. Studies on Coho salmon with an engineered growth hormone similar to the AquAdvantage Salmon found that genetically engineered salmon were more aggressive when searching for food (the growth hormone made them hungrier), and in some instances resorted to cannibalism. 3 The aggressive behavior evident in genetically engineered salmon led to population crashes and even the complete extinction of some wild salmon species in the study.4 Other research has shown that a release of just 60 genetically engineered fish in a population of 60,000 could lead to the extinction of the wild population in less than 40 generations.5 FDA must more thoroughly consider these and other potential risks before allowing commercialization of AquAdvantage Salmon. AquaBounty’s egg production facility on Prince Edward Island was infected with Infectious Salmon Anemia in 2009,6 which it initially failed to report to the FDA.7 This virus is extremely deadly to salmon and has decimated the Chilean and Scottish salmon farming industries. If this or other diseases were to break out at genetically engineered fish farms and then those fish escaped, they could wreak havoc on wild fish populations. Declines in wild salmon could also cause massive harm to fishers and fishing communities on both coasts. Is genetically engineered fish safe to eat? Unfortunately, the FDA decided these fish will be safe to eat based solely on data provided by AquaBounty. Of potential concern to human health is the fact that, according to data submitted to FDA, overall all GE salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancers8 if absorbed and biologically active in the human body. In addition, the findings on allergy risk were based on only six fish. 9 The fact is that the science is simply not there to say whether or not genetically fish are safe to eat and further studies are needed.
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Many people eat salmon because of its health benefits, but unfortunately it appears that genetically engineered salmon is less nutritious than other salmon. Genetically engineered salmon have been found to have a lower omega-3 to omega-6 fatty acid ratio than other salmon, 15 percent less than conventionally farmed salmon and 65 percent less than wild salmon.10 Will genetically engineered fish be labeled? Probably not. The FDA has stated it will likely not require genetically engineered salmon to be labeled, providing consumers no way of knowing whether the fish sold at their grocery store is genetically engineered. This may lead to market confusion and people choosing to avoid salmon entirely. How can I take action? Visit our website, www.gefreeseafood.org to get involved! You can also write to your favorite grocery stores, restaurants, and chefs and ask them to sign the Pledge for Genetically Engineered-Free Seafood. You can also send comments to the FDA saying you do not want genetically engineered fish to be approved. Visit www.gefreeseafood.org to learn more!
(Endnotes) 1 Lake Research Partners, Commissioned by Food and Water Watch, 9/20/10. “Americans in near unanimity on their disapproval of genetically engineered fish and meat in the marketplace” . 2 Consumer Reports National Research Center. CR Poll: Two-thirds of Americans Want FDA to Inspect Domestic, Foreign Food Supply Overwhelming Majority of Consumers Want Country of Origin Labeling Loopholes Closed; GE and Cloned Animals Labeled. Http://www.consumersunion.org/pub/ core_food_safety/006298.html. Consumers Union, 11 Nov. 2008. 3 Devlin, R. H., Mark D’Andrade, Mitchell Uh, and Carlo A. Biagi. “Population Effects of Growth Hormone Transgenic Coho Salmon Depend on Food Availability and Genotype by Environment Interactions.” Proceedings of the National Academy of Sciences 101.25 (2004): 9303-308. 4 Ibid. 5 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). 6 “AquaAdvantage® Salmon Draft Environmental Assessment.” Page 43. 7 Entine, John. “Genetically Modified Salmon: AquAdvantage FDA Assessment Is Delayed Possibly by the White House.” Slate, 19 Dec. 2012. 8 Yu H. and T. Rohan. “Role of the Insulin-Like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute, vol. 92, iss. 18. September 20, 2000; and Moschos, S. and C. Mantzoros. “The Role of the IGF System in Cancer: From Basic to Clinical Studies and Clinical Applications.” Oncology, vol. 63 iss. 4. November 4, 2002. 9 Ibid. 10 Comments of Consumers Union on GeneticallyEngineered Salmon,. 16 Sept. 2010. .
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Why should your company sign the Pledge for GE-Free Seafood? www.gefreeseafood.org Genetically engineered salmon is poised to enter the U.S. marketplace without adequate assessment and labeling and poses risks to human health, the environment, animal welfare and a sustainable future for fish. At least 35 other species of genetically engineered fish are currently under development, including trout, catfish, tilapia, striped bass, flounder, and other salmon species. The FDA’s decision on this genetically engineered salmon application will set a precedent, for its approval will chart a path for other genetically engineered fish and animals to enter the market. By signing the Pledge for GE-Free Seafood, your company will signal to its customers that it is a leader in supporting consumers’ right to know what they are purchasing and supporting sustainable seafood production. Consumers do not want to eat genetically engineered seafood • Ninty-one percent of Americans do not want the FDA to allow genetically engineered fish and meat into the marketplace; • The majority of consumers won’t eat genetically engineered fish if it is available; • Ninty-five percent of consumers believe genetically engineered food animals should be labeled if the government approves the fish against their wishes; and • Eighty percent of Americans who regularly eat fish say that sustainable practices are "important" or "very important" to them. Genetically engineered fish are not sustainable and threaten the safe, healthy seafood supply that consumers desire. Genetically engineered seafood will likely not be labeled, leading to market confusion and consumer rejection • Genetically engineered seafood will likely not be labeled as such since the FDA has already said it will not require labeling, providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. This may lead to market confusion and consumers choosing to avoid salmon entirely. GE seafood is bad for the environment and bad for fish • Escaped genetically engineered salmon could present significant risk to already imperiled Atlantic salmon populations, and escaped fish could bring diseases with them. Infectious Salmon Anemia, an extremely deadly virus to salmon which devastated salmon farms in Chile and Scotland, was found in the genetically engineered salmon egg production facility in 2009 and was not initially reported to the FDA; and • Genetically engineered salmon are unhealthy and suffer from skeletal deformities, jaw erosions, inflammation, lesions, increased susceptibility to disease, and increased mortality, raising serious animal welfare issues and human health concerns from eating sick fish. GE Fish is bad for consumers and fishermen • The safety of these genetically engineered fish will be based solely on data provided by the companies producing them; • Overall, all genetically engineered salmon have 40 percent higher levels of the hormone called IGF-1 (insulin-like growth factor 1), which may increase the risk of certain cancers if absorbed and biologically active in the human body; and • The findings on allergy risk were based on only six fish. This is bad science and bad food. Sign the Pledge for GE-Free Seafood! We will promote all companies that join the pledge and make public their policy to not knowingly purchase or sell genetically engineered salmon or other seafood, should it come to market. These companies will be highlighted on our websites, in social media, and in the press, so that consumers can see for themselves where a company stands on genetically engineered salmon before they go grocery shopping or dine out. Visit www.gefreeseafood.org to learn more and to sign the Pledge for GE-Free Seafood! www.gefreeseafood.org
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Petition to grocery stores, restaurants and chefs: Sign the Pledge for GE-Free Seafood to protect the environment and consumer right-to-know! www.gefreeseafood.org Please join Friends of the Earth and a broad coalition of 30+ consumer, food safety, fishing, environmental, sustainable agriculture, parent, public health and animal health and welfare organizations, representing millions of members, by signing this petition. We’ll share the petition with grocery stores, restaurants and chefs that haven’t yet signed the Pledge for GE-Free Seafood, and ask them to join up. The U.S. Food & Drug Administration is in the final stages of reviewing genetically engineered salmon for human consumption. If approved, it would be the first-ever genetically engineered animal to enter the world food supply. Unfortunately, the FDA has already said it will likely not require genetically engineered fish to be labeled, providing consumers no way of knowing whether the salmon sold at the retail level is genetically engineered. By signing the Pledge for GE-Free Seafood, retail providers can let customers know they can order fish at their stores without fear of unintentionally buying genetically engineered fish for their families. We, the undersigned, call on grocery stores, restaurants and chefs to protect their customers and the environment by signing the Pledge for GE-Free Seafood!
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Please send completed petitions to: Friends of the Earth, 1100 15th St NW, 11th Floor, Washington, D.C. 20005; Fax: 202-783-0444
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