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Tell the FDA to Reject AquaBounty’s Expansion of GMO Salmon Operations
Tell the FDA to Reject AquaBounty’s Expansion of GMO Salmon Operations on Prince Edward Island, Canada
The U.S. Food and Drug Administration (FDA) is seeking public comments on its “Draft Amended Environmental Assessment for Production of AquAdvantage Salmon at the Bay Fortune and Rollo Bay Facilities on Prince Edward Island (PEI), Canada”. The FDA has announced it will support expansions of AquaBounty’s genetically engineered (GE) AquAdvantage salmon operations despite AquaBounty’s history of violations and lies.
AquaBounty intends to expand operations not only on PEI, but also in Pioneer, Ohio. AquaBounty’s GE salmon threatens wild Atlantic salmon and the livelihoods of Indigenous communities. The company’s operations also pose health and environmental threats to the local communities where their facilities are sited. FDA’s assessments fail to properly take these threats into consideration and fail to take into account the company’s sordid track record.
A recent report by the #BlockCorporateSalmon campaign outlines in detail why AquaBounty’s facilities should be shut down, instead of being allowed to expand. The report includes testimony and photographic and video evidence of egregious health and environmentally concerning practices, submitted by Braydon Humphrey, a former AquaBounty employee turned whistleblower.
Some of the most concerning details are provided below. The full report can be viewed HERE.
Urge the FDA to not only reject AquaBounty’s expansion, but to investigate AquaBounty’s violations and practices at all of their facilities.
AQUABOUNTY CANNOT BE TRUSTED
AquaBounty’s transgenic GE salmon was created by adding genes from Chinook salmon and ocean eelpout to Atlantic salmon to cause the salmon to grow faster.
This is NOT Atlantic salmon! Yet AquaBounty claims they are “responsibly raising Atlantic salmon” and “raising nutritious salmon that is free of antibiotics and other contaminants,” and that their system is “designed to prevent disease.” This is far from the truth. Evidence shows an alarming history of food safety concerns and toxic conditions happening at the AquaBounty facility in Indiana that should make consumers, investors, and regulators question AquaBounty’s ability to be trusted as a safe or successful producer of a fish intended for human consumption.
The company can’t even get it right in a smaller facility and should not be allowed to expand their operations.
TOXIC TANK WATER & DECEPTION:
- An abundance of fiberglass particles, excessive toxins, chemicals and heavy metals in the tank waters have been documented by the whistleblower. AquaBounty actively hides the failure of their system from investors, the public, and onsite visitors. According to the whistleblower, AquaBounty lost one third of their initial fish stock during their first-feeding systems due to a fungus that completely covered fish gills in a sticky gray mucus. The Indiana facility continues to experience high mortalities. AquaBounty’s operation does not in fact prevent disease, but rather harbors it.
- Daily testing of the water produced routine “abnormal” or “toxicological” water quality results, not only exceeding AquaBounty’s own set limits for water toxicity, but also regularly going over the range of what the lab’s refractometer could even measure. The intensive amount of fish excrement and fish feed within the overcrowded fish rearing system caused highly toxic concentrations of total ammonia nitrogen levels in the water. This further led to toxic levels of nitrite that were regularly present.
- Another water contamination issue was caused by the amount of fish mortalities. Some corpses were so decomposed that their skin and meat would cause clouds of organic matter to recirculate through the system. Images and text exchanges show high level management describing the decomposition of dead fish as “sludge of [...] old fish” and show evidence of fish corpses clogging screens and lining the bottom of fish tanks where they were left to rot.
- AquaBounty claims they do not use chemicals. However, due to these toxic water conditions the water must be treated. Water treatment involved regulating water pH levels using hydrochloric acid, a harsh chemical.
- AquaBounty seems far more concerned with impressing and deceiving the public and regulatory agencies than it is about the quality and condition of their salmon. The whistleblower recounts that “so much of what tours were seeing was very different from our typical day”. Employees were regularly instructed to stop feeding the fish 24 hours before on-site visits, as well as to introduce extra fresh water into the tanks in order to make the water look clearer than it normally was. Evidence in text messages between employees shows high level management (CFO & Farm Manager) instructing employees to obscure the reality of the amount of fish mortalities and quality of water prior to a tour visit, such as by turning around buckets dedicated for dead fish to hide the label that said “morts”, or to pause on removing morts from tanks using a lift (not approved by the FDA), because of how it would stir up clouds of decomposed corpses and cloud the water in the system. Employees were also told to hide away large trash cans that were used to hold mortalities so people would not realize just how many fish were dying.
NUTRIENT-DEFICIENT, UNHEALTHY, POTENTIALLY TOXIC FISH
- Rupturing Stomachs from Abnormal Growth: AquaBounty genetically modified their fish to grow abnormally fast as a way to reduce the amount of feed and time needed to reach market size. As explained to Humphrey by the hatchery manager, Tess Boyer, this physiology caused common occurrences of ruptured stomachs. This led to many mortalities at the Indiana farm.
- AquaBounty’s GE fish lack the nutritional value eaters expect to find in salmon. The difference between the Omega 3/Omega 6 fatty acid profiles between wild caught salmon, farmed salmon and AquAdvantage salmon is striking. Wild caught salmon’s ratio is 12 to 1, non-GE farmed salmon is 4 to 1, and AquAdvantage GE salmon is 3.8 to 1. Many people eat salmon for its heart healthy Omega 3 anti-inflammatory properties, while Omega 6 causes inflammation. According to Policy Director at the Center for Food Safety, Jaydee Hansen, “AquAdvantage has the poorest ratio of good fats to bad fats of all salmon.” This can be attributed to the fact that the feed given to GE salmon does not nutritionally compare to what wild salmon eat throughout their lives. The GE fish also contain 5% less protein, but 58% more total fat content compared to conventionally farmed salmon. In addition, GE salmon have less percentages of a wide array of vitamins, minerals and essential amino acids than non-GE salmon. Further, as is common with other farm-raised salmon, AquaBounty also uses pigmenting supplements to give their GE salmon a pink color as opposed to what would otherwise be gray flesh.
- There is also evidence that raises major red flags if GE salmon is even a safe choice of food. According to the FDA’s assessment of GE salmon, the product contains “40% higher levels of a hormone called insulin-like growth factor 1”, which has been shown to increase the risk of certain cancers. Additionally, GE salmon “exhibited as much as 52% higher levels of ‘allergenic potency,’ which indicates possible allergic reactions from consumers.”
- Weeks before harvest, AquaBounty and other intensive/indoor aquaculture farms are required to pump large amounts of fresh water to fish tanks in order to wash out the high concentrations of ammonia that seeps into the meat during their captive lives.
RISKS TO COMMUNITIES & ENVIRONMENT
- Due to the high ammonia levels and toxicological water conditions in the fish rearing system, AquaBounty has received several notices of noncompliance with regard to their wastewater. In October 2019, the Indiana facility received a letter of noncompliance from the Indiana Department of Environmental Management where the ammonia levels in their waste lagoons were 5% over the permitted limit. While in this case the levels are not dramatically over the limit, what is concerning is that, according to the whistleblower, during this time AquaBounty was operating at less than half capacity and still could not handle the amount of toxins that the fish created. In July 2020, May 2021, and June 2021, AquaBounty received several other notices of noncompliance for their wastewater being significantly over the limit of ammonia those entire months.
- In March 2021, AquaBounty issued an incident report with the Indiana Department of Environmental Management where the plant spilled an estimated 15,000 gallons of tank water around the lift station near the rearing areas. This was a serious containment violation with tank water full of fiberglass particles, fish corpses, and fish waste spilling to the ground of the facility.
- Photographic evidence shows an instance of a tank of caustic water with a leaking valve placed outside the main production building and allowed to drain. The whistleblower notes there is a neighbor that grows crops immediately adjacent to the AquaBounty property.
- With the construction of a new and much larger AquaBounty facility in Pioneer, Ohio, the spread of water pollution enters another community. The village of Pioneer sits on top of the Michindoh Aquifer which provides clean drinking water to communities in three different states - Michigan, Indiana, and Ohio. As one community member from Pioneer describes it, “[The] water is currently so pure, it does not need to be filtered. [I] don’t want to use it to fill a fish tank and dump it every day.” AquaBounty should not be given any benefit of the doubt on managing their wastewater for this new facility since their past history is rife with irresponsible actions and their impact on local waterways.
RISKS TO WILD SALMON & OTHER ANIMALS
- AquaBounty claims their system is “designed to prevent escapement and impacts on the broader ecosystem” and that there is no risk of escape because the GE fish grow in a land-based facility. However, the company’s reckless management of their Indiana facility includes dangerous fish handling practices that do not properly contain their GE fish and reveals the irresponsibility of this corporation. Photos show many instances of containment breaches and fish escaping from tanks as well as use of water flow and drainage practices in violation of FDA containment regulation.
- Because of the high level of mortality and sick fish, tons of fish routinely end up in the farm’s dumpsters, some possibly still alive. There are no special containment practices when the GE fish are disposed of in the dumpster outside the facility. Raccoons and other wild animals have often been spotted foraging fish from the facility’s dumpsters. It would not be hard for a wild animal to drag and release a GE fish into a nearby body of water. And in at least one severely concerning incident (not witnessed directly by Humphrey but recounted by another employee that was present), during a fish transfer from one building to another, a major spill occurred that landed many GE fish on the ground within 20 feet of the wastewater drainage for the entire facility risking the escape of these GE fish into the local waterway. Despite AquaBounty’s claims of its systems being “designed to prevent disease”, disease was prevalent amongst the cohorts of fish raised as the high level of mortality and other evidence suggests. If the fish do escape from these conditions, their diseases and altered genetics escape with them, putting wild salmon and the environment further at risk.
INHUMANE TREATMENT OF FISH
- Unnatural Confinement & Inhumane Fish Density: AquaBounty claims their fish “school naturally.” However, the truth is these fish are barely surviving horrible tank conditions with inhumane fish density. While salmon do school naturally in the wild, they school loosely. According to the whistleblower, there were many cases of fish fin erosion caused by the high density in the tanks.
- Suffering & Inhumane Killing: AquaBounty claims that its GE salmon is cared for “in the most humane way possible.” However, the Indiana farm had persistent contamination from deteriorating fiberglass of the tanks likely to cause eye, skin, gill, and intestinal irritation. The evidence shows injuries, high mortalities, and preventable suffering. With water quality being so low, workers could not keep track of individual fish health and many fish could not be effectively euthanized if ill or suffering from pain. This led to countless dead fish regularly covering the bottom of tanks.
- AquaBounty also has a track record of using unnecessary, abusive and inhumane methods of impromptu killing of fish by stomping on them, using hammers, or whacking them on the side of tanks.
NOT CLIMATE-FRIENDLY OR SUSTAINABLE
- Huge Energy & Water Usage: These types of facilities have tremendous energy bills in order to operate around the clock electrical demands, including but not limited to: lighting, water pumps, water chillers, heating, air conditioning, etc. AquaBounty’s Indiana farm has electrical bills (supplied by coal) that are on average over $10,000 every month. The Indiana facility has a 1,200 metric ton capacity. The new AquaBounty facility under construction in Ohio aims to produce 10,000 metric tons of GE fish per year. If the current smaller facility requires such high energy consumption, what will the energy usage of this new much larger facility be?
- The Indiana farm requires 1.45 million gallons per day (MGD) of water to operate. The GE fish are forced to survive in unnatural high-density tanks with poor water conditions that require enormous water usage to flush the foul water in the tanks. The larger planned Ohio facility intends to pump 3 to 5 MGD from the Michindoh Aquifer and dump wastewater into the St. Joseph river. AquaBounty is currently seeking approval for a second water withdrawal permit from the Ohio Dept. of Natural Resources to increase their allotment to up to 5.25 MGD. AquaBounty claims it is possible for these systems to recirculate 99% of the water and they claim to have “greater than 95% of water recycled”. The whistleblower said that AquaBounty’s system does not perform to their stated claims.
FAILURES AT THE FDA
- Indigenous communities who have stewarded wild salmon and their waters since time immemorial, and whose ways of life are deeply and inextricably connected to the wild salmon and the waters, should be centered in these assessments. The Muckleshoot Indian Tribe and the Affiliated Tribes of Northwest Indians called on the FDA to deny all applications to distribute genetically engineered salmon in the U.S. without prior completion of an Environmental Impact Statement and scientific review that sufficiently consulted with Northwest Treaty Tribes. This legal requirement was not honored. The National Congress of American Indians joined this effort, and passed a resolution to “oppose the introduction of and sale of genetically engineered salmon in the United States if the FDA decides to allow it and requests tribal consultation on the matter before any action by the FDA.” Tribes were never consulted.
- In July 2016, Quinault Indian Nation (consisting of the Quinault and Queets tribes and descendants of five other coastal tribes in Washington state) joined 11 other organizations to bring a lawsuit against the FDA for approving AquaBounty’s genetically engineered salmon. In 2020, a federal court decision ruled the approval of GE salmon unlawful, violating the National Environmental Policy Act and the Endangered Species Act, and requiring the FDA to go back and conduct a full environmental impact review. FDA's 2022 draft assessment is still woefully inadequate and does not thoroughly assess environmental and health concerns. Despite this, AquaBounty’s GE salmon is currently allowed to be on the market and the company says it is harvesting and selling GE salmon. It is not known who is currently purchasing these harvests or where they are being sold, and AquaBounty refuses to be transparent.
- Recent investigations into the FDA have found that the FDA is failing to meet American consumers’ expectations on food safety and nutrition and that the FDA’s food division is dysfunctional and ineffective. The basis of the FDA’s assessment of GE salmon is quite troubling. GE salmon is currently regulated as a veterinary drug rather than a food. The scientists who reviewed the assessment had backgrounds in veterinary medicine and biotechnology instead of nutrition or food sciences. A comprehensive study to assess potential human health risks from eating this product has not been conducted. It is dangerous to not employ the precautionary principle for the first ever genetically engineered animal intended for human consumption.
- GMO labeling of GE salmon will only be required if sold in grocery or retail stores, but does not apply to GE salmon sold at restaurants or food service establishments. This is concerning as AquaBounty seems to be targeting their sales to the restaurant industry where their product will not have to be labeled. Consumers eating at restaurants, hotels, and schools will not know they are eating GE salmon.
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