ALEC Exposed: Warming Up to Climate Change

As the U.S. suffers through catastrophic tornadoes, heat waves, and other climate extremes – no doubt just a small taste of what the climate crisis will bring in the future – polluting industries and the politicians that serve them want to convince you that excess carbon dioxide in the atmosphere is actually a good thing.

Last December, almost like clockwork, Republican legislators in state houses across the nation sounded the alarm about an “out of control” Environmental Protection Agency (EPA). What had the EPA suddenly done to earn such criticism? The EPA had dared to take the first baby steps towards regulating greenhouse gas emissions.

By January 2011, Indiana became the first state to pass a resolution urging Congress to prohibit the EPA from regulating greenhouse gas emissions (by defunding the EPA if necessary), to impose a two year moratorium on any new air quality regulations, and urging the federal government to complete a study identifying all planned regulatory activity by the EPA and its impact on the economy, jobs, and American economic competitiveness.

Between February and May, 13 other states passed similar resolutions (AL, IA, KS, KY, MI, MO, MT, ND, PA, TX, UT, VA, and WY). Six more states had resolutions introduced that never passed (AK, FL, IL, MN, OH, and OK). Because the Center for Media and Democracy has now launched the ALEC Exposed archive, we can now trace the emergence of this rash of legislation to the bill factory know as the American Legislative Exchange Council (ALEC).

ALEC and Kyoto

ALEC’s campaign against any regulation of greenhouse gases began long ago, when the U.S. was in the midst of debating the Kyoto Protocol, an international effort to rein in greenhouse gas (GHG) emissions to control the climate crisis. In the spring of 1998, ALEC ratified a model resolution for states to pass calling on the U.S. to reject the Kyoto Protocol and banning states from regulating greenhouse gases in any way. With ALEC friend George W. Bush entering the White House in 2001, the energy interests that sit on ALEC’s Energy, Environment, and Agriculture Task Force – easily got their way on keeping the U.S. out of Kyoto. (more…)

Why Is The Monterey Bay Aquarium Greenwashing Sewage Sludge?

Journey Through Liquid Space - Monterey Bay Aquarium - Dec. 26, 2009
"Journey Through Liquid Space - Monterey Bay Aquarium - Dec. 26, 2009 by raider3_anime, on Flickr


Today, the nation’s major sustainable food writers and bloggers will converge on Monterey, CA for an incredible invite-only sustainable food conference. The event, Monterey Bay Aquarium’s Cooking for Solutions, which those who attend say is spectacular, has a new sponsor this year: Kellogg Garden Products. Yes, that Kellogg Garden Products. The very same company that has contaminated “organic” school gardens in Los Angeles with sewage sludge. The company’s Chief Sustainability Officer, Kathy Kellogg Johnson, has a knack for befriending “green” organizations and using them to promote her toxic, misleadingly labeled products to unsuspecting gardeners. In this case, she’s listed as a “Silver Sponsor.” How much did her company pay to give her such a nice platform, sitting on a panel with Grist’s sustainable food writer Tom Philpott and telling an all-media audience about the sustainability of Kellogg Garden Products?

Last week, I wrote to Monterey Bay Aquarium, informing them that Kellogg Garden Products sells compost made with sewage sludge, with the slogan “Quality organics since 1925″ on the label. After a few brief replies and a little prodding, here is the reply I received from Alison Barratt on Friday, May 13:

Dear Jill,

We were not actually aware of these allegations until you raised them. We met Kellogg at the EMA awards last year, and know that EMA vets all of its associates very carefully. They were independently invited to be a sponsor and speaker at the event. We do not offer a place on our panels to sponsors; we look for speakers with an interesting story to tell, and we believe this is an interesting story.

Having spoken at length with Kellogg yesterday regarding your allegations, we are perfectly comfortable with our decision to invite Kathy Kellogg Johnson to the event, and to have them as a sponsor.

Our event is about highlighting good work that companies and individuals are doing and no company will ever claim to be perfect, or totally sustainable, but that doesn’t mean they don’t have something unique to share, or valuable to our audience. This event is not about marketing companies or products, it’s about education and taking us towards solutions.

I am afraid on this issue we will have to agree to disagree and respectfully decline your request to attend.

Kind regards,



And The Razzie Goes To… Norman Lear’s EMA for Exposing Kids to Sewage Sludge and Not Coming Clean

For a non-actress surrounded by movie stars, Debbie Levin, President of the Environmental Media Association (EMA) – an organization founded by Norman Lear – is putting on quite a performance of her own. Too bad it’s more likely to win her a fraud charge than an Oscar, based on her May 6, 2011 letter to her Board provided to the Food Rights Network by a source inside EMA.

Over the past month, Levin has been confronted with ample evidence that the group she runs exposed school children (not to mention the Hollywood celebrities that serve on the group’s board) to toxic sewage sludge. In 2009, EMA began a partnership with several Los Angeles schools, securing the donation of thousands of dollars in compost and soil amendment products from Kellogg Garden Products for the schools’ organic gardens soon thereafter. In a sworn affidavit, former L.A. Unified School District garden advisor Mud Baron said that he informed Levin early on and repeatedly that Kellogg uses sewage sludge in many of its products, and sewage sludge is illegal for use in organic gardens. Yet on Friday, May 6, she emailed the board a message that reads, in part:

It’s unfortunate in the midst of this great success, some can try to find controversy where none exists. The standards of the gardening program and our relationship with Kellogg Garden Products have been called into question. A San Francisco-based blogger posted a story last week claiming that Kellogg’s nonorganic materials were being used in school garden programs. Following that, an environmental blog picked up the story and expanded upon it by questioning our relationship with Kellogg since the company sells products that aren’t considered environmentally correct. Let me walk you through some of the facts:

The stories claim that nonorganic materials were used at school sites. This is not accurate. Schools only have access to Kellogg organic materials. This misconception may come from the fact that shortly after our program started two years ago, one participating school reached out directly to Kellogg and obtained mulch that is not considered organic. We regret that one school acted on its own in securing nonorganic materials…


Lies, Dioxins, Sewage Sludge, Hollywood Celebs, And School Gardens

A story has been developing over the past month involving lies, toxic sludge, Hollywood celebrities, and poor, inner city school children. It centers around the Environmental Media Association (EMA), a group of environmentally conscious Hollywood celebs, and the “organic” school gardens they’ve been volunteering at for the past past couple years. Stars like Rosario Dawson, Amy Smart, Emmanuelle Chriqui, and Nicole Ritchie have generously adopted Los Angeles schools, visiting the schools and helping the children garden. What the celebs didn’t know is that their organization’s corporate donor – Kellogg Garden Products – sells both organic compost and soil amendments and ones made from sewage sludge. Seventy percent of Kellogg’s business is products made from sewage sludge. Sewage sludge is not allowed on organic farms and gardens.

In late March, the Center for Media & Democracy (CMD) wrote to EMA, alerting them that Kellogg products contain sludge, which may jeopardize the safety and the organic status of the gardens. As a result of the letter, John Stauber, founder of CMD, then met with Ed Begley, Jr., famous environmentalist and EMA board member, who was concerned about the possibility that sludge was used on the gardens.

Following that meeting, a reply came back from EMA’s President, Debbie Levin, who has been called “Hollywood’s Conscience,” asking CMD to stop communicating with Ed Begley, Jr. and to call off its public campaign against the use of Kellogg products on the LA school gardens. She asserted that her organization never claimed the gardens were organic. Then, in the next week, EMA removed the word “organic” from its webpage about its school garden program… but left it in on some pages. (See screenshots here) EMA refers to the gardens as “organic” in a fundraising form, leading donors to believe they are contributing to organic school gardens. Ironically, in 2003, EMA gave an award to King of the Hill for its episode titled “I Never Promised You an Organic Garden.” Talk about foreshadowing.

SFGate and Mother Jones each wrote articles on this story, published a few days after Levin’s initial email reply. The Mother Jones piece features a picture of Rosario Dawson gardening with children, with a bag of Kellogg’s Amend (made from sewage sludge and contaminated with dioxins and other hazardous material) behind them. The article says:

“This was one of those unfortunate weird things,” says EMA president Debbie Levin, who hadn’t known anything about Amend before the shoot. Amend, she later learned, is not approved for organic farming because it’s made from municipal sewage sludge.


So what to do if you’re a home gardener who wants compost without the sewage? Try checking the website of the Organic Materials Review Institute, which vets agricultural products used by certified organic farmers. That’s the preferred approach of Levin, who stresses that no Kellogg Amend was ever actually applied to EMA’s gardens (though one school may have inadvertently ordered a different sludge-based product). “Everything was according to what we asked for,” she says. “We use the organic stuff.”

That much is old news. According to Levin, she and EMA were unaware that Kellogg products contained sludge, but not to worry because the products in the photos were never used. (Does that mean the bags of Amend that appear in many pictures of the school gardens were brought in for use as props in photo ops and then removed? Even if that were the case, it’s unfortunate that an environmental organization is giving that sort of free publicity to an environmentally unsound product like Amend.)

Food Sunday: A Nasty Surprise In The Garden

garden surprise
garden surprise by jek in the box, on Flickr

Guess what today is? You might guess May Day and, well, you’d be right. But it’s also the first day of International Compost Awareness Week! Woohoo! And… you lucky reader of this blog you… yours truly has been hired by the Center for Media and Democracy to blog about it.

To start out our celebration, unfortunately, I have a very sad story to share. You see, yesterday I went to help out in a garden in San Diego. The garden belongs to a man who has undergone a series of surgeries in the past year and while he and his wife love the fresh, homegrown food, he’s limited physically as he recovers. So I go over there every now and again to help him out. Yesterday I brought over a bunch of tomatoes, melons, and squash seedlings to plant and, as I entered the garden, I stopped dead in my tracks.

This garden is mostly organic. It’s an attempt at biointensive gardening, as described by John Jeavons in his book How to Grow More Vegetables… But there, next to the patch where we were planting the peppers, was a half-full open bag of Kellogg’s Amend.

The man whose garden this is, he’s a smart guy. We talk a lot, and he’s pretty aware of what he’s doing in his garden. He probably read the label before purchasing Amend. What’s in it? The label says “Ingredients: Blended and screened forest products, composted rice hulls, compost, poultry manure, gypsum.” It also says “Quality Organics since 1925.” The bag tells how the product should be used in vegetable gardens, and how it is ideal for loosening up clay soil. What it doesn’t say is that it’s actually made from Los Angeles sewage sludge. You would have no way of knowing that if you read the label. And if you didn’t know to look for the term “OMRI Listed” (which means that a product is suitable for organic agriculture) you might think the product is organic.

“Oh god,” I said. I told him that Amend was made from sewage sludge. He said the nursery he got it from recommended the product, and he used half the bag on his citrus trees. He was upset that it was made from sewage sludge, and that he had no way of knowing that before buying it. He was upset that he has no way of knowing what the hell he’s put on his citrus trees. Sewage sludge can have any number of contaminants in it (and often does). Some, like heavy metals, flame retardants, nanosilver, and certain pharmaceuticals, are almost universally found in sewage sludge, even the treated stuff approved to be used in gardens and farms. Other contaminants, including dioxins, furans, pesticides, polycyclic aromatic hydrocarbons, phthalates, endotoxins, and more, are only found some of the time… but since they aren’t regulated, a gardener has no way of knowing if a bag of Amend contains them or not. Only 10 heavy metals, salmonella, and fecal coliform are regulated in the most strictly regulated sewage sludge, which is called Class A biosolids.

Food Sunday: I Dare You, Put Sewage Sludge In Your Mouth


A new Washington Post piece by Darryl Fears claims sewage sludge is safe enough to put in your mouth. Specifically, the statement was made about “Class A Biosolids,” the treated sewage sludge (renamed “biosolids” to make it sound less unpleasant) that has regulated amounts of 10 heavy metals, salmonella, and fecal coliform.

What else might you find in sewage sludge? Well… Alkylphenols and alkylphenol ethoxylates, dioxins and furans, flame retardants, heavy metals (including some that are not regulated), hormones, pesticides, perfluorinated compounds, pharmaceuticals, phthalates, polycyclic aromatic hydrogens, steroids, and more… Still wanna put that in your mouth?

Fears was not advocating that anyone put sewage sludge in their mouths… at least, not directly. The article was instead about how sludge should be used as fertilizer for food crops… which people would then put in their mouths.

For the past year, on and off, I’ve been working with the Center for Media & Democracy’s Food Rights Network, a group that opposes the use of sewage sludge as fertilizer on food crops. So, full disclosure, I’ve been getting paid to research the hell out of sewage sludge and to write about it. I’ve even been paid to go to my local Home Depot and buy three bags of sludge compost to send samples to a lab for testing. And let me tell you… if the long list of sludge contaminants and the EPA’s own record of what they found in sewage sludge doesn’t scare you off of using sludge as fertilizer, the smell of it will. It’s not a poop smell – it’s a chemical smell. An incredibly volatile, potent one.

The question is, of course, what are you putting in your mouth when you eat food grown in sludge? And the answers are: “We don’t know” and “That depends.” We don’t know because it’s entirely unregulated and because there are an awful lot of chemicals out there that just haven’t been studied well enough to have the answers. Additionally, once you finish studying each individual chemical, then you’d have to study all of the combinations to see what happens when you mix them together in a toxic goop and apply them to farms and gardens. And it depends because each batch of sewage sludge is different, based on which households, hospitals, and industries are contributing to the waste stream and what they’ve put down the drain that particular day or week.

For farmer Andy McElmurray, it depended that a Nutrasweet plant was dumping thallium (rat poison) – an unregulated contaminant in sewage sludge – into the waste stream. The thallium went from the sludge applied to his soil, to his forage crops, to his cows, and all the way to the milk he sold to grocery stores. He only found out about the hazards of sludge after an extensive investigation into why his cows were dropping dead one after the other. McElmurray and his dad both got sick from working around sludge, and the farm went out of business. Dairying isn’t very profitable when your cows are all dead.

Fears notes the sludge industry’s favorite talking point: We have all of this human waste, and what are we going to do with it? Well, what should we do with pesticides, perfluorinated compounds, and flame retardants? I don’t know. I don’t think there’s a good answer. In the case of some of the most common flame retardants (PBDEs), the world’s answer was to ban them in the Stockholm Convention on Persistent Organic Pollutants. I think that’s a step in the right direction. The problem is that “persistent” refers to the fact that this stuff doesn’t break down. The answers to the sludge problem are upstream ones. We shouldn’t make such toxic substances if we don’t have a way to dispose of them. So, sure, it’s a problem to figure out where to put all of the sewage sludge. But lying that it’s safe and then selling it to unsuspecting gardeners ain’t the answer.

Another favorite sludge talking point in the article is that manure, including human poop, is “the world’s original fertilizer.” And, sure, the Chinese were famous for using night soil as fertilizer (one reason why you don’t see salads on the menu at Chinese restaurants… all the veggies are cooked in Chinese cuisine). But the pre-industrial Chinese were not manufacturing and mixing toxic chemicals in with their night soil.


Book Review: Starved for Science

(Low res. image of book cover via Harvard Univ. Press under Fair Use)

Starved for Science: How Biotechnology is Being Kept Out of Africa was one of the most riveting works of fiction I have read all year! Oh wait… non-fiction, you say? Well, then it sucked.

I went into Starved for Science with as open a mind as I could. After all, my next book will be more or less a refutation of much of what Paarlberg promotes as the way to help the poor, starving farmers in the world, and it would not serve me well at all to read his book without giving it a fair chance. Perhaps there are good points to be made that support his point of view? I would look stupid in my own book if I were to ignore them. And, not only that, but helping the world’s most vulnerable people is far too serious a subject to allow ideology or ego to get in the way. If I’m wrong, I want to know it. I want to challenge everything I believe to be true and test it as much as possible, because if we don’t do that, we are less likely to solve the world’s problems. And it seems like a good way to challenge my point of view is to read a book – a rather well-respected book (by certain crowds… like the U.S. Senate) – that argues that everything I believe is wrong.

Paarlberg has a talent at blending cleverly selected facts, weasel-y statements that are technically true, and complete bull-pucky to construct his arguments. I cannot say why he does this, whether he’s funded by agribusiness, or owns a factory farm somewhere, or perhaps he’s just a really poor researcher who got it into his head that he knows what he’s talking about and ran with it without getting all of the information. Or maybe this is all just a way to win himself prestige within the academic world. He’s a political science professor, not an agronomist or ecologist.

He begins by explaining why the populations rich countries do not like genetic engineering. This is part of a larger argument of his that the same populations are made up of “food purists, environmentalists, populists, and agrarian romantics” who don’t like agricultural science (p. 77). And they do not like for a very specific reason: it gives them no tangible benefit. Having never experienced hunger (his statistics for the number of hungry in the U.S. are suspiciously low), they have no concept of what the starving farmers of Africa are going through. These elitists (although he doesn’t use that word) want lovely countrysides where they can see cows grazing and maybe take their children to let them experience collecting eggs from a henhouse. They want better quality food. And they foolishly buy organic to avoid pesticide residues, even though the government has set limits for pesticide residues in produce and the vast majority of food does not exceed those limits.   . . . (more…)

Food Sunday: Indigenous Agriculture in the Andes

[Ed. note: Welcome to the first MyFDL Food Sunday post! Give Jill a warm welcome home from the Andes in comments.]

This week, I arrived home from an exhilarating yet challenging trip to Bolivia, where I learned about their food and agriculture. I ended up getting a lot more than I bargained for out of the trip, including learning why the rainforest is being destroyed, how eco-tourism might save it, how Bolivia fits into the drug trade (and what the US does to try to stop cocaine production), and how global warming has already impacted Bolivia. Bolivian agriculture is surprisingly relevant to the U.S. because we’ve historically provided massive amounts of both food and agricultural aid to their country, as you will see below.

The trip was divided into roughly three parts: the Andes, the Amazon, and the Andes again. (As you can probably guess, this was a difficult trip to pack for, with temperatures going from literally below freezing to hot and humid with a risk of malaria!) The two stints in the Andes were different, agriculturally, because the first part was spent near Lake Titicaca – which is what this diary covers – and the second was several hours south of there. Lake Titicaca provides warmth and humidity to the area around it, allowing much more possibilities in terms of agriculture.

We spent three days in the indigenous community of Santiago de Okola, on the shores of Lake Titicaca. After a weaving workshop in the morning of our second day there, we were briefed on the community’s agriculture, which is described below.

After the weaving workshop, we followed the Secretary General of the Agricultural Syndicate, Don Juan, to his home for an agricultural Q&A. I don’t think he quite knew what he was getting in for. Bolivians – particularly the type of Bolivians we wanted to talk to – are suspicious of foreigners showing up and poking around their farms. And they are suspicious for a good reason, given the history of agricultural “aid” in Bolivia. Saying to a Bolivian, “Hi, I’m here to learn about your agriculture,” is roughly like a thief showing up to someone’s house and asking to see the jewelry. So, as tourists interested in food sovereignty and agriculture, the places where we could get into farms to meet indigenous people and learn about their agriculture tended to be eco-tourism operations. And my guess is that most of the tourists at these places aren’t quite as ag-focused as us.  . . . (more…)

Food Sunday: The Creepy Science Behind Genetically Engineered “Frankenfish” About to Enter Our Food Supply Unlabeled

I’ve spent much of this week up to my ears in the hundreds of pages of science justifying the "safety" of the AquAdvantage salmon, a genetically engineered (GE) salmon that is poised to become the first GE animal in our food supply. And I’ve spent even more time reviewing the backgrounds of the individuals on the committee that will make the decision and the comments submitted to the FDA on the subject of the GE salmon by consumer advocacy, conservation, and sustainable seafood organizations. The second half of my work should appear on Grist tomorrow, and the first half is below. It’s more than concerning. It’s truly outrageous. If you want to take action, please go here.

The Creepy Science Behind Genetically Engineered "Frankenfish" About to Enter Our Food Supply Unlabeled

Originally posted on Alternet

When the FDA announced it found the genetically engineered AquAdvantage salmon safe just before Labor Day, news headlines and even Alaska Senator Mark Begich called it a "frankenfish." A closer look at AquAdvantage makes it seem unlikely that Mary Shelley could have ever dreamed up anything as wild as the fast growing GE salmon. Even more worrisome is the science used to justify the salmon’s safety, which Consumers Union senior scientist Michael Hansen calls "sloppy," "misleading," and "woefully inadequate."

If approved, AquAdvantage will be the first genetically engineered animal to directly enter the U.S. food supply — a fact that raises the stakes of the FDA’s approval process, as it sets a precedent for all future GE animals. Because of a regulatory decision in the 1980s that no new laws are needed to regulate genetically engineered foods, the FDA is actually regulating the GE salmon as a drug. The next step in the approval process will be a series of public meetings held September 19-21. Already, a number of groups, including Food & Water Watch, the Center for Biological Diversity, Friends of the Earth, and Organic Consumers Association have written to President Obama, urging him to discontinue the approval process for the GE salmon. (Full disclosure: I serve on the Policy Advisory Board of the Organic Consumers Association, but I was not a part of the decision to sign onto this letter.)

The company that developed the GE salmon, AquaBounty Technologies, claims the fish grows to market weight in 16 to 18 months instead of the usual 30 required for farmed Atlantic salmon. The fish was created by inserting genetic material of both Chinook (the largest variety of Pacific salmon) and ocean pout (an eel-like fish) into the genome of Atlantic salmon. The commercialized fish will all be females, making them unable to breed. AquaBounty’s intellectual property will be further protected because the fish will be sterile, as they will all be triploids (fish with three complete sets of chromosomes instead of the usual two).

How to Make Frankenfish

To create the fish, AquaBounty begins with eggs of GE Atlantic salmon females and fertilizes them with irradiated sperm of another similar fish species, Arctic char. The eggs are then pressure-treated, causing them to produce diploid offspring (i.e. fish with two complete sets of chromosomes), with both sets of chromosomes originating from the GE female salmon. The all-female GE diploid salmon will then be treated with 17-methyltestosterone, a hormone that turns the fish into what AquaBounty calls "neomales" — genetically female fish that produce milt (sperm) instead of eggs. The milt from the GE neomales will fertilize the eggs of non-GE Atlantic salmon, and the resulting fertilized eggs will be treated with pressure to produce the final product, a line of all-female triploid GE Atlantic salmon.

According to AquaBounty’s plans, the GE salmon will begin their lives at a hatchery in Prince Edward Island, Canada and then transfer to a grow-out facility in Panama. Unlike most salmon, which begin their lives in freshwater before transferring to saltwater, the GE salmon will live their entire lives in freshwater. The good news is that currently there are no plans to raise the GE salmon in open net pens in the ocean, a method of salmon farming that has resulted in massive damage to wild salmon populations as well as frequent escapes of farmed salmon into the ocean.

Questionable Science

While farmed salmon have been an environmental catastrophe in countries like Canada and Norway, it seems that environmental concerns over AquAdvantage take a backseat to safety concerns. The science AquaBounty provided the FDA was sloppy in a number of ways, and yet the FDA accepted it and declared the fish safe. Because the approval of AquAdvantage salmon will set a precedent, it is important that the FDA set its bar for solid science high, signaling to any company that wishes to commercialize a genetically engineered animal that it must completely prove its safety if it hopes to put its product on the market. Instead, according to Hansen, "the FDA appears to have set its bar an inch from the ground."

AquaBounty tested its GE salmon and controls for physical and behavioral problems, differences in blood test results and hormone levels, and allergenicity to humans. Although the commercialized fish will all be female triploids, they often tested both males and females and both diploids and triploids of non-GE and GE salmon to determine whether any problem that showed up was due to the genetic engineering or due to the extra set of chromosomes.

However, in many of the tests, AquaBounty used sample sizes as low as six fish, much less than the minimum of 30 needed for the results to have statistical significance. Hansen said a small sample size might make sense if the animals were elephants, but there is no reason why AquaBounty should not have tested more fish. Moreover, in one of the tests, the six fish in each study group were selected from larger groups of 100 to 200 fish, and the report did not specify that they were chosen randomly. Additionally, AquaBounty admitted to culling deformed fish prior to selecting fish for inclusion in its studies. The company justified this by saying that culling is standard practice in the industry. That may be so, but for the purpose of comparing deformities between GE and non-GE salmon, the culling and sampling practices reduce the reliability of the results.

Another alarming practice — one Hansen felt qualifies as misleading — was AquaBounty’s reliance on 2007 data (the best year for the GE fish and simultaneously the worst year for non-GE fish) and its characterization of 2005 data (the worst year for the GE fish) as an outlier to be ignored. By using 2007 data for many of its studies, AquaBounty was able to compare its best group of both diploid and triploid GE salmon against the group of non-GE salmon with the highest frequency of physical deformities (compared to each of the other years of testing, 2003-2006).

On the other hand, in 2005, the GE fish exhibited an unusually high frequency of physical deformities (only 7.9 percent of triploid GE salmon and 17.2 percent of diploid GE salmon were judged to be free of any malformations), and AquaBounty provided several justifications for ignoring this data, suggesting that perhaps the small sample size (38 fish) of GE triploids was to blame. Hansen says if that were true, we would not also see such poor results in the diploid GE fish, which had a sample size of over 1,500 salmon.

The problem could have been environmental, offered AquaBounty. Maybe the problems were caused by nutrient deficiencies, exposure to antibiotics, contaminants in feed, parasites, or water temperature. Yet, if that were the case, notes Hansen, we would also see a high rate of malformations in non-GE fish in 2005, and we do not. Both the diploid and triploid groups of non-GE fish performed well in 2005, with 98.7 percent and 89.0 percent showing no malformations, respectively. Hansen also dismissed AquaBounty’s assertion that the extra chromosomes in the triploid salmon were responsible for the 2005 data, as both the diploid and triploid GE salmon performed poorly, but the non-GE triploids performed quite well.

Despite the problems noted above, the FDA concludes from the data that, "Analyses of the behavior and gross external abnormalities of market size (1,000-1,500 g) AquAdvantage Salmon show no demonstrable differences from the comparator fish population." One last flaw Hansen points out is the study’s examination only of adult fish, and not of fish in all life stages, beginning with the egg. The FDA, perhaps worried about this, and certainly worried about AquaBounty’s heavy culling of fish in early life stages (not to mention their lack of data on fish that were culled), called for a Durability Plan that includes "monitoring, data collection, and reporting of abnormalities observed under commercial production and grow-out conditions at the Panama facility where AquAdvantage Salmon will be reared" after the fish are approved and commercialized. Hansen feels this is insufficient, comparing it to allowing the fox to guard the henhouse and report if any chickens are being eaten.

Another area where the science is flawed is in AquaBounty’s examination of hormone levels in the fish. Of 73 fish tested (30 GE and 43 control), every single fish had growth hormone levels that fell below the detection limit. Hansen criticizes AquaBounty’s conclusion that there was no detectable difference in levels of growth hormone between GE and non-GE fish, comparing it to a cop with a radar gun that cannot detect speeds below 120 mph concluding the is no evidence of exceeding the speed limit. Additionally, only six of the 73 fish had detectable levels of T4 (a thyroid hormone), and only 17 had detectable levels of insulin like growth factor 1 (IGF1), a hormone that is potentially harmful to humans. Even with the small amount of data, the GE salmon that had detectable levels if IGF1 tested nearly 40 percent higher on average than the non-GE salmon with detectable levels of IGF1.

One last area to consider is the allergenicity testing of the GE salmon, as fish allergies are one of the eight most common allergies in the United States. For this, AquaBounty used sample sizes of six, testing GE diploids and triploids against non-GE diploids. They began by sending 18 blinded salmon fillet samples to a lab that treated them with liquid nitrogen to produce "frozen salmon-fillet homogenate." Then they unblinded the samples and tested each individual sample with sera from humans with salmon allergies and measured the magnitude of the allergic reaction to determine the "allergic potency" of the sample. AquaBounty then converted the data into an undefined estimated measure it called "relative potency," a term the lab was unable to define when asked by the FDA.

The FDA obtained the actual data tables from the test and concluded that, "The allergic potency of triploid [AquAdvantage] salmon is not significantly different from that of [the control group of non-GE] diploid salmon." Again, Hansen took issue with this conclusion in light of the small sample size in the study, the unblinding of the samples, and the fact that the allergic potency of all but two GE salmon were higher than the highest value of allergic potency for non-GE salmon.

Hansen felt that, while the use of actual human sera to test allergenicity was useful, it was insufficient given modern scientific techniques available to assess allergenicity. Scientists are aware of many proteins that cause salmon allergies and they could easily have analyzed the molecular structure of the fish to determine if those proteins were present. Although there was one attempt to do this for one protein, the testing technique was so crude and flawed (some of the data submitted was upside-down!) even the FDA did not accept it.

Why Consumers Should Be Concerned

Given the flawed science used to justify the safety of AquAdvantage salmon, what happens now? Currently, the FDA is preparing for its public meetings: The first meeting on Sept. 19th will review the science; the second meeting on Sept. 21st will cover labeling issues and offer an opportunity for public comment. FDA will also accept written comments until November 22.

There are a few more issues for consumers to consider should the GE salmon come to market. Under current law, genetically engineered foods are not required to be labeled as such. In fact, the only labeling one can expect on a genetically engineered salmon fillet is country-of-origin labeling, which is required on most (but not all) seafood. Since all of the AquAdvantage will be produced in Panama, an uncommon location for farmed salmon, consumers can be on the lookout for — and avoid if they wish — salmon from Panama. The exceptions will be salmon sold in fish markets and processed salmon, such as smoked salmon, which do not require country-of-origin labeling.

Hansen noted two reasons why consumers may wish to avoid the GE salmon. First, he notes that reports of increased inflammation in the tissues of the GE salmon may result in increased antibiotic use. Second, consumers who care about animal welfare may wish to avoid the salmon because even in the flawed tests that were performed, the GE salmon exhibited higher rates of physical deformities than non-GE salmon.

The bigger picture, of course, is the standard AquAdvantage salmon will set for future genetically engineered animals. Eeven if the AquAdvantage salmon proves to be safe in the long run, if sloppy and dishonest science is all that’s required to pass a product through the U.S. regulatory system, what other disasters lie in our future?

The Sloppy Science “Proving” Frankenfish is Safe

Try this recipe for your next dinner party: Begin with eggs from a genetically engineered (GE) female Atlantic salmon with DNA from both Chinook salmon and Ocean Pout (an eel-like fish). Add irradiated sperm from an Arctic Char (a different fish species), mix, and put under pressure to produce a generation of all-female GE salmon with two sets of chromosomes from their mother and none from the Arctic Char. Then add 17-methyltestosterone to turn the GE salmon females into "neomales" – genetically female fish that produce milt (sperm). Combine their milt with the eggs of non-GE Atlantic salmon females, place under pressure, and – voila! – you’ve got a batch of all-female, triploid (having three complete sets of chromosomes instead of two) GE Atlantic salmon. Yum! Smoke that up and put it on your bagel.

Doesn’t sound appealing? Well, that describes the new GE salmon AquaBounty Technologies seeks to commercialize as the AquAdvantage salmon – the first genetically engineered animal to directly enter the U.S. food supply. They claim it grows to market size in 16 to 18 months instead of the usual 30. And, just before Labor Day, the FDA ruled that it is safe.

Despite the obvious gross-out factor of the "neomales," the truly important thing to focus on is the quality of AquaBounty’s science ensuring us that their GE salmon are safe. They tested the fish for physical and behavioral problems, hormone levels, several chemistry and hematology components, and allergenicity to humans. Unfortunately, the science behind many of these tests was so sloppy that it’s hard to determine from them whether the GE fish are safe or not.  . . . (more…)