Open Comment on GE Salmon Production

9 April 2013


The FDA is poised to approve genetically engineered (GE) salmon for human consumption this year. Thanks to the efforts of individuals and organizations across the country, the FDA has extended its comment period an additional 60 days, until April 26, 2013. If you would like to urge the FDA to reject the approval of GE salmon, please submit a comment online here.

Or, submit by mail to: Division of Dockets Management (HFA- 305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852.


Docket # FDA2011N0899

Dear Commissioner Hamburg:

The Community Food and Justice Coalition urges the Food and Drug Administration to reject the approval of production of genetically engineered salmon, the first genetically modified animal intended for human consumption. We are deeply concerned of the negative impact that AquaBounty GE salmon will have on fishing communities, native salmon species, the marine environment, and public health.

GE salmon poses a threat to wild salmon species and the marine environment. The AquaBounty application submitted to the FDA assumes that the escapement of GE salmon is unlikely, and therefore does not pose a threat to native salmon populations or the marine environment. However, existing aquaculture sites show that escape from fish farms happens, and is indeed very likely. Escaped GE salmon would pose an imminent threat to wild salmon species by wasting valuable reproductive efforts of native salmon species, contributing to the increasing decline of an already threatened or endangered population. Wild salmon species would also be at a competitive disadvantage against GE salmon, which grow twice the speed and consume twice the amount of food, straining an already compromised marine habitat.

The public health impacts of farming and consuming GE salmon is also unknown. AquaBounty claims that GE salmon is safe to eat and yet studies show a likely increase in growth hormone levels and allergies among those who eat GE fish. Without rigorous independent scientific testing conducted to measure the impacts of GE salmon, the product continues to pose an unknown threat, likely resulting in unintended consequences.

The introduction of GE salmon into our food system will negatively impact the economic and cultural integrity of fishing communities across the country. If GE salmon is allowed to be sold in the US, fishermen and coastal communities will suffer job loss and economic hardship. Furthermore, these negative impacts will cause more hardship if GE salmon is not required to be clearly labeled.

Should the FDA approve AquaBounty GE salmon despite its negative impacts, the Community Food and Justice Coalition believes it is essential that such fish be labeled. It is unacceptable for GE fish to enter our food supply without being labeled; consumers have the right to know what is in their food and how it is produced.

The FDA is required to put the health and well-being of the public first, and we ask that you give the same regard for our environment, fishing communities, and native salmon species. We strongly urge you not to approve AquaBounty’s pending application for the production of GE salmon.


[Your Name]

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CFJC promotes the basic human right to healthy food while advancing social, agricultural, environmental and economic justice. Through advocacy, organizing and education, we collaborate with community-based efforts to create a sustainable food supply. We envision a food system in which all activities, from farm to table, are equitable, healthful, regenerative and community-driven.

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