The FDA has initiated
a recall of half a billion eggs, the most extensive in history, because of
salmonella contamination that has already sickened 1,300. The head of the
agency, Margaret Hamburg, said in interviews that regulators "need additional
resources, we need additional authority [and] greater ability to trace back
products to their source so that we can identify how the contamination occurred
and what products are at risk."
A plea for more power and resources is bureaucrats' typical response to any
crisis, but ironically, unwise FDA policies place obstacles in the way of
technology to enhance disease resistance in eggs that could have prevented
the outbreak in the first place.
The FDA's regulation of "genetically engineered" (GE) animals tortures
the science and opts for the most stringent, stultifying regulatory approach
among the possible choices. After more than 20 years of deliberation, last
year the FDA's Centre for Veterinary Medicine chose to require that every
genetically engineered animal would be subject to the same pre-market approval
procedures and regulations for drugs, such as pain relievers and anti-flea
medicines, that are used to treat animal diseases. The rationale is that a
genetically engineered construct "that is in a GE animal and is intended
to affect the animal's structure or function meets the definition of an animal
drug."
But this explanation conveniently ignores the science, the FDA's own precedents,
and the availability of other, better regulatory options.
What kinds of animals are we talking about? One that has been awaiting an
FDA policy for a decade is an Atlantic salmon that contains a Chinook salmon
growth hormone gene that remains turned on all year (instead of during only
the warmer months, as in nature). This cuts the salmon's time to reach a marketable
adult weight from 30 months to 18. The extra gene confers no detectable differences
in the salmon's appearance, taste or nutritional value; it just grows faster
– a tremendous economic advantage to those farming the fish.
There are numerous other applications in various stages of research and development,
including livestock with leaner muscle mass and improved use of dietary phosphorus
to lessen the environmental impacts of animal manure.
The technology could also be used both to inhibit micro-organisms' ability
to grow within chickens and their eggs and to block the synthesis and action
of the bacterial toxins. This same technology can be employed to produce antibodies
that can be administered to infected patients to neutralise the toxins.
Until last year, the FDA had not regulated new lines of farm animals or, for
that matter, animals used for what might be termed "medical purposes".
For example, they still do not regulate German shepherds or golden retrievers
bred to enhance traits that make them better "seeing-eye" or companion
dogs. Likewise, the FDA has not asserted its jurisdiction over GE animals
crafted for research purposes, which includes hundreds of lines of rodents.
The lengthy, expensive pre-marketing approval requirement only applies if
the animal is crafted with state-of-the-art recombinant DNA ("gene-splicing")
techniques. So, for example, if the Atlantic-Chinook salmon described above
were to be the result of some sort of artificial insemination instead of recombinant
DNA techniques, it would be exempt from pre-approval evaluation.
In other words, the FDA's regulatory trigger is not the risk-related traits
of an animal, but the use of a certain technology – and the most precise
and predictable one, at that. That makes no sense.
The "new drug" paradigm does not fit GE animals well; the introduction
of a gene that affects some characteristic is not the same as the administration
of a drug. A more apposite model is the approach taken by FDA's food regulator,
the Centre for Food Safety and Nutrition, which does not perform case by case
reviews of every new product but limits them to products of non-negligible
risk. This approach has worked quite well over many years.
The result of the FDA's risk-averse approach to genetically engineered animals
is that yet another entire innovative business sector is burdened with an
excessively regulatory policy that inflates research and development costs
and inhibits innovation. Yet again, regulators on their faces.
Source:
Henry Miller (24.8.10). The FDA needs egging on. If we had a sensible
and safe policy that permitted more genetic engineering in farming, this egg
recall might have been avoided. The Guardian (http://www.guardian.co.uk/commentisfree/cifamerica/2010/aug/24/fda-egg-recall)
Reproduced by permission of the author.
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