Something Fishy: Difficulty Labeling Genetically Engineered Salmon

We may be one step closer to genetically modified salmon appearing in our food supply. Over the past three days, the US Food and Drug Administration (FDA) held public hearings on genetically engineered (GE) salmon.

How will we as consumers be able to distinguish non-GE salmon from GE salmon?  The answer is simple, label GE salmon.  However, AquaBounty Technologies seeks to push its  genetically engineered “AquAadvantage” salmon through to market, sans labeling.

While there is questionable science in regards to safety of GE salmon, let us focus on labeling logistics.  The question remains, should labeling of GE salmon be mandatory? Most folks would love to see labels on GE salmon.  But our hands appear tied with respect to the law.

The FDA has five key principles, based on federal laws, applicable to food labeling of GE animals:

1)  The law prohibits labeling that is false.
2)  The law prohibits labeling that is misleading.
3)  The law allows voluntary labeling about production methods.
4)  The law requires that the label includes a name that describes the basic nature of the food.
5)  The FDA cannot require additional labeling about production methods unless it is necessary to ensure that the labeling is not false or misleading.

Let us see if we can make a case for labeling GE salmon within the bounds of the the FDA guidelines.

Labeling of Production Methods
Opponents may argue, while the production process of obtaining GE salmon versus salmon differ, the end product is the same.  Allegedly, their is no difference between flesh garnered from either GE salmon or salmon.  Sadly, the process of labeling production methods cannot be mandated.  The good news is that production method labeling is voluntary.  Wild caught salmon or farm raised salmon can be touted as such.  However, this still leaves GE salmon unchecked and unlabeled.

False or Misleading Labels
Would labeling GE salmon as just salmon provide false or misleading information?  AquaBounty has itself a dilemma here.  If the company says GE salmon is different than salmon, then it must label its product accordingly.  Its product must be differentiated from salmon.  However, If the company says GE salmon is the same thing as salmon, then what is the point of developing GE salmon in the first place?  Why not just stick with what nature has given us, non-genetically engineered salmon?

Describing Basic Nature of the Food
If we break GE salmon down to its bare essentials, namely its DNA, is GE salmon still really salmon?  GE salmon has genes from an eel-like ocean pout, which allows it to grow more rapidly than salmon.  This would make GE salmon no longer exclusive to the salmon genome, but a genetically engineered hybrid of salmon and ocean pout. The two cannot mate in the wild, but their genes can cross in a test tube.  The basic nature of the salmon has been altered.

Moving Forward
Can you think of strong arguments for labeling GE salmon within the of the FDA’s five key principles?  Perhaps our hands are not tied after all.  I’d be curious to hear your comments.  And I bet the FDA would love to hear your arguments too.  We have until November 22 to provide written comments to the FDA.

Jonathan Mariano is an MBA candidate with the Presidio Graduate School in San Francisco, CA. His interests include the convergence between lean & green and pursuing free-market based sustainable solutions.

16 responses

  1. I think this is horrible. It’s being forced on the American public, and often times, nobody knows about it until it’s too late.

    It’s becoming increasingly difficult for the lower to middle class to find food that won’t make them sick.

    What a shame. Our FDA is run by Monsanto and Dupont and they have the president in their pockets.

    1. Hi Anna, Assuming that there is collusion between the FDA and corporations, what is the point of having an FDA at the federal level in the first place? It is difficult to stop collusion especially if there is a monopoly agency making decisions about how to label our food supply.

      I wonder if we opened up competition in labeling standards, instead of having a monopoly deal with, would this still be an issue?

  2. I opted 0ut of eating meat, dairy, meat bi-products, GMO, GE foods about 10 years ago. I don’t buy manufactured foods packaged in boxes, plastic coated cans(BPA), plactic bottles(more BPA). I forage for dandelions and other eatables that grow naturally in my yard and so on. Outcome: I gained a better weight; normal blood pressure;cancer disappeared and hasn’t returned no – thanks to the pharmaceutical companies. Shopping for groceries is less stressfl because choices are so limited in the reglar supermarkets should know now that they will continue to exploit the earth with all kinds of poisons until we show we are not willing to be exploited. Solution – don’t buy the stuff. I’m going to get off of my soap box here however I have to say the solution lies with each of us. We have to make some very strong stand and refuse to buy. It will hard for most of us who are so accustomed to having things our way however, we can train our children. Lets do it for the fture world. Don’t be exploited!!!

  3. This is criminal and insane. The FDA needed to be investigated by Congress. This is a dangerous agency. The USA people do not know that the FDA has already allowed some form of genetic warped food already.

    This will cause a cancer problem for decades! A filmmaker has been reversing diabetes and obesity in now 10 countries WITHOUT DRUGS AND and has revealed the danger of genetic food just google SPIRIT HAPPY DIET

  4. I am a student at Kaplan University and I am currently writing a paper on Genetically Engineered Foods. Would the FDA be interested in knowing that not one GE product that is on the market today has ever been tested or studied on humans? Dr. Pusztai studies on the GE tomato and potato both came back with almost the same results. These foods are not safe. There are no known long term side effects of these foods because there has never been a study done on them. If rats and other lab animals fed these GE foods are coming back with stomach lesions, lower birth weights, cancer, and even death; who is to say the same thing is not happening to humans? Has the cancer rate gone up drastically since the early 90’s? Yes. Have there been reports about stomach problems and over all health problems rising? Yes. Do we have a clear understanding of why these numbers are increasing? No. Why not? Because the studies have never been performed. And now they want to introduce another GE product. If this continues, all of our food will become GE. Americans health will drastically worsen, death tolls will be at an all time high, birth rates will be very low, and our country as a whole will be in trouble. All because someone wants to make a pretty penny. The FDA along with our government should set up a division designed specifically to test these foods instead of relying solely on the test results of the companies that are producing them. It is by belief that the test results submitted to the FDA can not be accurate when compared to studies like the one performed by Dr. Pusztai. By the way, the products that he tested are on our market today. None of these foods are labeled.

  5. Tracy: That sounds like a fascinating paper. I wonder if the FDA knows about this or even they are keeping it under wraps.

    I would advocate one step further, where testing of these foods are done by a third party other than the government/fda or the makers of the product themselves. It seems that the government/fda and the corporate interest, in this case, are tightly intertwined, that perhaps more government would provide further suppression rather than transparency.

    1. You’re correct. We can’t trust government because theirs isn’t a profit-based motive. They “earn” their money by policing us and the industry against our will. Have you ever heard of anyone seriously questioning Underwriters Laboratory’s motives in evaluating the safety of a toaster? Do you not look for the UL seal when buying a potentially dangerous small appliance? We need less government “protecting” us.

  6. If the FDA doesn’t require a GE label, then I think there is a marketing opportunity for those who provide wild caught salmon to change their labels to state it is wild caught or non-GE. If those providers team up with groups like Foods and Water Watch to educate the public to only buy salmon labeled wild caught or non-GE, we could stop GE meat by voting with our dollars. This would be similar to all the dairy products out there that tout how they are not produced from cows treated with BGH.

    I’d still prefer the FDA to do its job and protect us from untested GE products, but if they don’t, we need to find another way.

      1. And as so many people believe that non-GE salmon is superior, the companies could charge more for their “wild” product and earn a higher profit.So too, the GE product might be less and more people might buy it thereby earning the GE producer more profit. Either way, it should be up to the manufacturers not the government.

  7. I’m no doctor but it really just doesn’t seem smart to put something on the market that’s relatively new on the food scene. At this point we really have no idea how GE foods are going to effect our bodies over an extended period of consumption. GE foods are purely a byproduct of greed and wanting more from less. I’m much more likely to trust proven organic foods over something engineered in a lab but the poor and misinformed are likely to swing the other way.

  8. If salmon is not labeled caught/wild or farm raised, it must be assumed that the salmon is GM/GE/produced. The federal laws are not designed for consumer information even though the government pushes consumers to be informed about food and make healthful choices.

  9. If this fish is not labeled as G.E., then I will no longer be eating salmon.

    We should have the right to know what we consume.

    This is definitely the workings of big business.

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