The Development of Genetically Modified (GM) in Canada

In late 2013, Environment Canada approved the commercial production of genetically modified (GM, also called genetically engineered), in Canada. In November 2015 it was approved for human consumption in the United States and then in May 2016, it was approved for human consumption in Canada, making it the first genetically modified food animal approved anywhere in the world.

The US company, AquaBounty (now a majority owned subsidiary of Intrexon), currently runs a facility in PEI where it has been producing GM salmon eggs for research. The company plans to produce GM salmon eggs in PEI and ship the eggs to Panama for commercial grow-out and processing, but Environment Canada’s approval also allows the company to grow out the fish in Canada. The company has also signaled its interest in expanding facilities to other countries and has started trials in Brazil and Argentina.

The Atlantic salmon was genetically engineered with a growth hormone from and genetic material from ocean pout (an eel-like fish), to grow faster than other farmed salmon. Canadian research indicates that GM salmon could out- compete wild Atlantic salmon for food and other resources.

All regulatory decisions on genetically modified organisms in Canada are made without public consultation.

Environmental Threats

Genetic modification/engineering allows for the transfer of genetic material directly from one organism to another, across the species and kingdom barriers (for example from plant to animal) at the molecular level, and is dramatically different from traditional animal breeding. It can have unpredictable impacts on the organism and carries unknown risks for the ecosystem if the animal escapes into the wild.

The primary concern is that the GM salmon poses risks to wild Atlantic salmon populations, which are already endangered. The main threat is genetic contamination: up to 5% of AquaBounty’s salmon will be able to reproduce. If an escape were to occur (and escapes from land-based facilities are a known and documented risk), interbreeding could occur with wild salmon and some trout species. This could lead to the permanent loss of wild Atlantic salmon as a species through genetic contamination.

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The Scale of Operations

• AquaBounty’s original application was to produce 100,000 eggs at their PEI facility. In a recent application to expand their facilities in PEI, the company said it wants to scale up to produce 10 million eggs per year for brood stock alone. • The number of spawning wild Atlantic salmon in 2014 was less than 87,000 in all of North America. • The GM salmon eggs will travel 4000 kilometres (one-way) for grow out in Panama. Then the processed fillets will travel back to North America for sale. That is twice the distance wild Atlantic salmon travel to their feeding grounds in Greenland from the waters near PEI.

Legal Challenge in Canada

Two environmental groups – Ecology Action Centre (NS) and Living Oceans Society (BC) are taking the Canadian government to court for violating the Canadian Environmental Protection Act when it permitted the manufacture of the GM Atlantic salmon eggs. The groups assert the Government failed to assess whether the new species could become invasive. Ecojustice is providing legal representation.

The Situation in the US

Soon after the approval for human consumption was granted, the US Food and Drug Administration (FDA) placed a temporary ban on GM salmon imports from Canada due to lack of clarity of GM labelling laws in the US. The issue is that under current laws, consumers will not know which salmon products are genetically modified. This ban will remain in place until a course of action on labelling laws is decided.

A coalition of consumer groups, fisher, and environmental organizations also initiated a lawsuit against the FDA in the US over its approval of GM salmon for human consumption. They argue that the agency failed to analyze and prevent the risks to wild salmon and the environment, as well as fishing communities. The lawsuit also highlights the FDA’s failure to protect the environment and consult wildlife agencies in its review process, as required by federal law. Ecology Action Centre is part of that coalition.

Lack of consultation

There was no public consultation about the approval of GM salmon in Canada. The government made the decision to consider AquaBounty’s application for approval without consulting Canadians. It also appears that there has been little to no consultation with Indigenous peoples on the use of this new technology despite the fact that many aboriginal communities have an interest in the health of wild salmon populations, through legally acquired fishing rights, as well as in the use of Atlantic

2 salmon for food and cultural purposes. The economic benefits of GM salmon--a fish that arguably grows faster-- are may be limited.

Seafood Labelling

There is a growing distrust among North American consumers related to seafood, as much of it is either mislabelled or inadequately labelled in stores.. In other jurisdictions, notably Australia and the European Union, seafood labels are more comprehensive and provide consumers with the information they need to make confident and informed choices. Consumer choices are influenced by a variety of factors, from environmental and health issues, to social justice and human rights abuses.

In the EU, the information on the label includes: the commercial and scientific name of the species; whether the product was caught at sea or in freshwater, or farmed; the catch or production area; and the type of fishing gear used to catch the product.

Incorporating this information onto seafood labels in Canada, as well as whether or not it is a Genetically Modified product, allows consumers to make their own ethical choices about the seafood they want to buy, and encourages more transparency within the complex seafood supply chain.

Research Studies

Ecology Action Centre bases its work on science and we look to government and university research to assess environmental concerns.

Some of the papers we have used are listed here:

Summary of the Environmental and Indirect Human Health Risk Assessment of AquAdvantage ® Salmon - and Oceans Canada, Canadian Science Advisory Secretariat, Science Response 2013 http://www.dfo-mpo.gc.ca/csas-sccs/Publications/ScR-RS/2013/2013_023-eng.pdf • Page 21 of this summary explains how any change to the containment of level of activity would change the risk assessment of this organism.

Draft Environmental Assessment for AquAdvantage Salmon and Preliminary Finding of No Significant Impact, Dated 4 May 2012, Kapuscinski and Sundström, https://envs.dartmouth.edu/sites/envs.dartmouth.edu/files/comments.pdf • The opening paragraphs explain the scientists’ concerns with the Food and Drug Administration’s risk assessment and how it failed to use modern techniques.

Is GM Legislation Precautionary Enough? By Emma Issatt http://docslide.us/documents/is-gm-aquaculture-legislation-precautionary-enough- emma-issatt-asfpg-19-21.html

3 • Slide 9 points out that even in a scenario where escaped salmon eventually die out, it may still shock wild Atlantic salmon populations into extinction

Who we are

Ecology Action Centre is a membership-driven environmental organization operating out of Halifax, Nova Scotia. We have over 4500 members spread across the Maritimes, with the majority in Nova Scotia. Our vision is for a society in Nova Scotia that respects and protects nature and provides environmentally and economically sustainable solutions for its citizens. EAC is an independent organization that strives to work with partners to: provide up-to-date environmental information; pursue researched solutions; and act as a watch-dog for the Nova Scotia environment.

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