I am writing to urge you to do a thorough assessment of the environmental impacts of genetically engineered (GE) salmon. The draft environmental assessment (Docket # FDA2011N0899) released in December does not adequately examine the risks posed by the potential commercialization of the first genetically engineered food animal.
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The draft environmental assessment fails to adequately address the many potential food safety risks posed by GE salmon, including the potential human health impacts of GE salmon's higher hormone levels and increased allergenicity.
The draft environmental assessment also fails to adequately address the major environmental impacts of GE salmon, completely ignoring the possibility that GE salmon may be raised in systems other than those specified in the original drug application. The standard for raising farmed salmon is open net pens in the open ocean, not the type of facility spelled out in the drug application for GE salmon. The persistent problem of escaped fish and the spread of diseases like infectious salmon anemia from commercial salmon farms where this GE salmon could one day be produced must be evaluated.
Finally, the agency has ignored the fact that this new genetically engineered fish is not needed or desired by consumers, and the fish may not even live up to claims about increased growth rates, the whole reason it is being proposed. There is no need to put human health and the environment at risk for GE salmon.
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