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Debate: Genetically modified salmon

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Should the FDA approve the sale of genetically modified salmon in the US?


Background and context

GM salmon contains DNA from Pacific Chinook salmon and an eel-like fish. The modification allows it to produce growth hormone year-round, so GM Salmon grows to market size in 16-18 months rather than the 3 years in which normal salmon mature. GM salmon does not grow larger than conventional salmon.

AquaBounty Technologies Inc. is a biotechnology company founded in 1991 focused on improving productivity in the commercial aquaculture business. AquaBounty produces AquAdvantage Salmon and has been attempting to secure Food and Drug Administration (FDA) approval to market the product since 1995. The company submitted latest New Animal Drug Application to FDA in September.


What are the potential health or nutritional effects of genetically modified salmon?


There are no biologically relevant differences. AquAdvantage salmon contained the expected amounts of nutritionally important omega-3 and omega-6 fatty acids at the appropriate ratio for a fish source. People who are allergic to Atlantic salmon will likely be allergic to AquAdvantage Salmon because it is a finfish-- one of the eight most allergenic foods in the US-- not because it has been genetically engineered.

Moreover, increased salmon consumption leads to lowered risk of heart disease. Coronary heart disease is the number one cause of death in U.S. (National Center for Health Statistics, 2000). A study by Lutter and Tucker (2003) revealed that the marketing of GM salmon will lower salmon prices and increase consumption of salmon, an exceptionally good source of omega-3 fatty acids linked to lower risk of heart disease. The resulting increase in omega-3 intake will prevent 600 to 2600 deaths per year in the U.S.

Lutter and Tucker (2003): A 1% change in salmon consumption should increase total n-3 intake by 8.2%, assuming n-3 intake from other sources is unchanged. Empirical research suggests that a 1% decline in the price of farm-bred salmon leads to a 1% increase in consumption. In French fish markets, a 1% drop in international salmon prices lowers retail prices by 0.165%. A 1% decrease in the cost of farmed salmon will lead to a .165% drop in the retail price of salmon.

GM salmon would reduce the risks of fatal CHD by about 0.2%. Since about 720,000 Americans aged 35 and older died from heart disease in 1999 (National Center for Health Statistics, 2000), a reduction of 0.2% amounts to about 1400 deaths per year.


Willingness to pay: $8.22 to reduce risk of heart disease by 1 in 1 million (Cameron, DeShazo, Johnson, 2009)

VSL calculation: 8.22/.000001=$8,220,000

GM salmon reduces fatalities by 1440

1440*8,220,000 = $11.84 billion (value of lives saved)


Health Risks
1) Increase Cancer Risks
AquaBounty has reported that AquAdvantage salmon has 35% higher levels of IGF-1 (a growth hormone) than natural salmon. This is problematic because studies show that there are connections between increased levels of IGF-1 in blood and risk of colon, prostate, and premenopausal breast cancer. Similar levels of IGF-1 have been found in milk due to the bovine growth hormone rGBH which has caused cancer in humans. rGBH is now banned in the EU, much of the rest of the developed world, and many U.S. grocery chains will not carry it.

Currently, 1 in 6 men in the United States will be diagnosed with prostate cancer during his lifetime and 1 in 8 women in the United States will be diagnosed with breast cancer during her lifetime. According to a recent study, men who were given IGF-1 as an aging supplement had almost twice the risk of cancer death. This finding is consistent with breast cancer in women.

If we assume there is even a 1% cancer increase for high consumption salmon eaters, we see increased numbers of cases and additional healthcare costs:

Men High risk of cancer (salmon consumption 8x/month): 150 cases of prostate cancer. Moderate risk of cancer (salmon consumption 1x/month): 2,300 cases of prostate cancer. Healthcare costs: $42,750 to treat prostate cancer and $25,000 quality of life costs including additional healthcare interventions and side effects.

Women High risk of cancer (salmon consumption 8x/month): 113 cases of breast cancer. Moderate risk of cancer (salmon consumption 1x/month): 1910 cases of breast cancer. Healthcare costs: $60,000 to treat, $25,000 quality of life costs (e.g. breast reconstruction and physical therapy).

Total Cost of Salmon-related Cancer cases Men: $166 million Women: $162 million

2) Antibiotic Resistant Bacteria (ARB) Growing resistance to antibiotics are dangerous because ARBs can be transferred from fish to human. ARB transfers are already reported from livestock to humans. Due to this transfer of bacteria, there is a $4 billion annual increase in healthcare costs. Assuming each American eats 182.5 lbs of meat per year, there would be an additional $22 million spent on healthcare costs per lb. Assuming ARB transfers from salmon at same rate and GM salmon becomes 50% of national supply in 5 years, the average GM salmon consumption per person per year would be 1 lb. Annual healthcare costs will increase by $22 million.


Randall Lutter and Katherine Tucker, "Unacknowledged Health Benefits of Genetically Modified Food: Salmon and Heart Disease Deaths", AEI-Brookings Joint Center for Regulatory Studies; Tufts University

Insulin-like growth factor 1 (IGF1), IGF binding protein 3 (IGFBP3), and breast cancer risk: pooled individual data analysis of 17 prospective studies. The Lancet Oncology, Volume 11, Issue 6, Pages 530 - 542, June 2010

Antibiotics used in meat pose a threat to public health, admits FDA. October 22, 2010 David Gutierrez

Cancer Prevention Coalition Hormone Thought to Slow Aging Associated With Increased Risk of Cancer Death: March 10, 2010.

How might genetically modified salmon affect the environment?


Current System for Farming Salmon relies heavily on Ocean Penning

Land based egg production, spawning, and growth of salmon would reduce disease introduction, lower interactions with natural population, and create regional markets where carbon footprint could be lowered. GM salmon production may lower pressure on natural fish populations as well.

Egg Production Facilities (Prince Edward Island) and Growing Facilities (Panama) have 3 or 4 layers of physical containment

Transport of Eggs is in Secure Transport

In the event of escape or release into the wild,

Chance of Survival at Both Locations Limited by Temp., Salinity, Age

Shipments of Eggs for Growing Must be at least 95% Infertile

All Female Population

No natural Salmon Populations Near Either Facility

Minimal Risk of Reproduction


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Environmental Risks

When AquaBounty’s monopoly ends new companies will enter the market, and it will be increasingly difficult to regulate the containment of GM salmon. Competing firms will be incentivized to lower their marginal costs, creating an environment that is innovative and less risk averse. Fish will inevitably escape.

What happens when a fish escapes? GM salmon grow more rapidly causing an increased appetite and aggression. As the food supply dwindles they eat other fish, natural salmon and other GM salmon. A high risk of extinction of wild and natural salmon species would result. In order to try to monetize this potentially catastrophic and irreversible consequence, we used use value and existence value estimates.

Use Value for commercial and recreational salmon fishing in the Pacific Northwest: $1 Billion in regional income and 60,000 jobs.

Existence Value: Contingent valuation surveys indicate WTP for saving an endangered species like the Chinook salmon, range from $6 to $95. Assuming there are 223 million adults in the U.S., and the low CV estimate, we assume $1.3 Billion lost.

Precautionary Principle: “Action should be taken to correct a problem as soon as there is evidence that harm may occur, not after the harm has already occurred.” --Cass Sunstein

What is the potential economic effect of genetically modified salmon entering the marketplace?


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Several contingent valuation (CV) surveys indicate willingness to pay (WTP) for saving an endangered species range from $6 to $95 depending on species. Assuming 223 million adults in the United States.

Value of Wild Salmon LOW CV at $6 $1.3 Billion HIGH CV at $95 $21.2 Billion

Another economic issue with legalizing GM salmon is that since AquaBounty (AB) currently holds the patent rights to produce GM salmon, AB will be a price setter because they have the patent rights. AB has no incentive to lower price until competing GM salmon enters the market. The overall price for salmon will not lower right away.



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