As U.S. regulators cleared genetically engineered salmon for sale in the United States last week, they opened the door to what many scientists already feel is inevitable: The escape and reproduction of GE salmon in the wild and the possible destruction of competing wild species.
Under the U.S. Food and Drug Administration-approved application, the company behind the so-called AquAdvantage Salmon, Aqua Bounty, can only raise such salmon in land-based tanks with "multiple and redundant levels of physical barriers to prevent eggs and fish from escaping." These barriers are described in detail and suggest that it will be very difficult for any eggs or fish to escape into waterways.
The FDA said it considered four interrelated questions about confinement of the fish:
- What is the likelihood that AquAdvantage Salmon will escape the conditions of confinement?
- What is the likelihood that AquAdvantage Salmon will survive and disperse if they escape the conditions of confinement?
- What is the likelihood that AquAdvantage Salmon will reproduce and establish if they escape the conditions of confinement?
- What are the likely consequences to, or effects on, the environment of the United States should AquAdvantage Salmon escape the conditions of confinement?
Right away we can see that the FDA is asking these questions in the wrong way because it misunderstands the risks involved. It should be asking if there is ANY LIKELIHOOD WHATSOEVER that the salmon will escape, survive, disperse, reproduce and establish populations in the wild.
Why is it important to ask the question in this way? Because although the salmon are sterilized, the "sterilization technique is not foolproof," according to The New York Times.
So, here is the relevant principle: Any invention with a nonzero risk of systemic ruin and which is produced and deployed long enough will with almost 100 percent certainty create that ruin. Put more informally, if you keep repeating something that each time you repeat it has a small chance of creating catastrophe, eventually you will produce catastrophic conditions, that is, systemic ruin. Systemic ruin in this case would be the ruination of the wild salmon fisheries overrun by the GE type.
And, the damage might include other harmful effects to waterways and their associated wildlife that we cannot now anticipate. Remember, this is a fish that we’ve never seen operate in any existing ecosystem. We have no empirical data about its possible effects; and, releasing such fish into the wild to obtain that data risks the very ruin we wish to avoid.
Now, there is one final question which the FDA asks: "What are the likely consequences to, or effects on, the environment of the United States should AquAdvantage Salmon escape the conditions of confinement?"
Again, this is the wrong way to ask the question. The effects would not be confined to the United States since the escape of one unsuccessfully sterilized salmon into the wild could lead to a worldwide infestation. (In any case, the facilities approved for farming the salmon are in Prince Edward Island, Canada and in Panama. But apparently, only the possible environmental effects in the United States were considered.)
Anything that is novel cannot by definition have a history to draw on. A novel invention might not alter the environment very much or it might alter it radically. We cannot know. To say that we should subject the world’s salmon fisheries to the possibility of ruin in order to find out reveals a failure to understand that self-propagating, worldwide dangers do not lend themselves to cost-benefit analysis.
When the cost is the complete ruination of a system, we must judge costs to be incalculable. The complete destruction of the global wild salmon population is not 10 times worse than the destruction of 10 percent of that population. It is infinitely worse. It is infinitely worse because you cannot repopulate the world with an extinct species (except perhaps in science fiction movies). There is no remedy.
And, we must keep in mind that we do not now know how many other facilities like those built by Aqua Bounty will be constructed. The danger of release grows with each added facility. And, of course, we must assume that Aqua Bounty wants to expand as a company which implies many more facilities should the company become successful. Also, keep in mind that such facilities, although on land, must have extensive plumbing and drains which must ultimately connect with the external world. Is it rational to believe that GE salmon or salmon eggs will never, ever make it into a waterway and survive, an event which must happen only once for a possible cascade of destruction of wild species to take place?
So, we should say that the risk is real and the scope and severity, if realized, would be catastrophic.
Understanding this allows us to see why the precautionary principle applies in this situation and in the cases of all genetically engineered plants and animals. Anything that is novel, self-propagating and worldwide in reach has the possibility of creating systemic ruin. Which leads us to another key principle: It does not matter how many times something succeeds if failure is too great to bear.* In other words, it does not matter if millions upon millions of GE salmon are produced without any release into the environment when the inevitable release of one (by mistake, carelessness, accident or poor design) could create ruinous global consequences. (And, if the GE salmon industry grows, it is difficult to believe that there will be only one inadvertent release over time. Accidents happen–even when we think we have designed foolproof systems.)
Whether such a fish is safe for human consumption is not the key question–though the FDA answers that it is safe. That’s what makes the announcement of the approval so misleading. What difference does it make if this GE salmon is safe to eat if, in the event of escape and propagation, it ultimately destroys the entire wild salmon fishery and has other unforeseen and catastrophic effects on marine life.
*This formulation comes from author and risk expert Nassim Nicholas Taleb, author of The Black Swan and many other works on risk.
Image: Pacific salmon fish underwater (oncorhynchus). Knepp Timothy, U.S. Fish and Wildlife Service. Via Wikimedia Commons.