Benefits of GE Guidelines for the Algae Industry
by Dr. Mark Edwards
A lgae are an agricultural product and algae producers should consider the Genetically Modified Organism (GMO) guidelines developed in Europe and Asia as well as the US guidelines for genetic engineering (GE) of agricultural products. In 2009, about 93% of the US soybean crop and 80% of the US corn crop used transgenic seeds. Those transgenic food crops are integrated throughout both domestic and global food systems. While algaculture will probably have a larger non-GE component than field crops, the inertia in the food and biofuel industries seems to be building for substantial GE algal production.
Numerous reports from Canada, Europe and the US show that some transgenic characteristics (germplasm) appear in both wild weeds and food crop fields. Contamination comes from GE seeds spilled in transport, pollen drift and mechanical contamination from farm equipment. Experts agree that we lack the technology to keep spillover transgenic characteristics out of the food chain, even in Europe. Since transgenic leaks occur regularly in field crops, transgenic spillover will be even more common in algal production for all the reasons that make algae special.
The Uniform Commercial Code creates a potential choke point for GE algal producers. The Code imposes implied warranties or promises on producers and/or sellers. An implied warranty of fitness is imposed on the producer as seller if the seller has reason to know any particular purpose for which the goods are required or if the buyer is relying on the seller’s skill and judgment in providing the goods. This may be invoked against a producer if the conditions are met. A producer can disclaim or nullify an implied warranty of fitness but it takes a conspicuous, written provision in a contract — which would undermine consumer confidence. Therefore, algae producers should consider themselves providing an implied warranty for fitness of the product for its intended use.
An implied warranty means that a neutraceutical, pharmaceutical, medicine, health food, natural food, feed or fertilizer product should contain at least minimum threshold amounts of specific constituents and be free of contaminants or toxins. This will require constant algal culture monitoring, significant quality control measures and product traceability. Dr. Amha Belay, CEO of Earthrise Nutritionals has developed a comprehensive quality assurance program for natural (non-GE) food grade spirulina. Biofuel producers will need to provide the expected amount of energy and be free of residue that would foul the type of engines targeted for use.
The nature of algae
Public policy leaders in Texas have asked algal producers to follow the model used by field crops and seed vendors whereby all indigenous species in a specific ecosystem are identified so that new, possibly invasive species can be monitored. However, the nature of algae makes creating a list of the indigenous species problematic.
The latest algae textbook, Algae by Graham et. al., (2009) estimates there are possibly 10 million species of algae. Adding to this numerical complexity, many algal species can make rapid adaption based on critical cultural parameters that change the nature and often the composition of the organism. Scientists have no method for clearly defining what parameters constitute a different species that are sufficiently stable for algae. Since temperature or nutrient change may ignite adaptations that change the color, shape and composition of a particular species, identifying all species in a geography imperfect and impractical. In any algae culture outside a laboratory, there also will be a diversity of numerous other microorganisms algae attract including weed algae, yeast, fungi, bacteria, viruses, green slimes and others.
No one has proposed a practical mechanism for identifying all the algal species indigenous to a particular geography or state. New technologies like the FlowCam™ can photograph myriad species in a sample but automated systems can neither differentiate nor count species. The indigenous species count in any geography, even a field, is not stable because new algal cells arrive every second on the wind, water or wings. Unlike human immigrants, science has no way to tell indigenous species from new immigrants. The only way to identify GE species will be to use genetic markers that are stable.
Away from the ocean, most algae live in the top six inches of soils and in or on rocks, plants and trees. A tiny clover plant may hold 100 different algal species in its root system, mixed with several million individual alga cells. Identifying all the species is practically impossible because over 90% of the algal species in the soil may be dormant at any time, waiting for the right conditions to actively grow and propagate. Some forms of algae live symbiotically with other microorganisms such as fungi and algae that work together to create practically infinite forms of lichen. Other algae live symbiotically with plants, bacteria, corals and sponges.
Even if a master list of all algae were available for a geography, no one has proposed a mechanism, or even a theory, to determine what threshold levels of a species constitutes an invasion to an intended homogenous culture. The FDA constraint of 20% (also the just noticeable difference in science) does not work because algae grow based on local conditions. When the culture conditions are right, a species that represents 1% of the algal may flourish and quickly out-grow the desired species. The same constraints hold for all the other microorganisms that exist in field production algal cultures – invasive species, contaminates and predators.
Algae differ from seed crops
Land plants evolved from algae 500 million years ago and practically every constituent in land plants can be found in one and probably many algal species. Therefore, algae have the potential to replace food products made from food grains, food oils, protein, nutrients, vitamins, minerals and antioxidants. Genetic scientists believe that every growth and constituent parameter in algae can be expressed more efficiently and effectively with GE technologies. Consequently, algae – GE and natural – will probably become a major component of the future food and energy systems.
Algae are microorganisms with certain characteristics that are different from seed or field crops. Unlike a seed crop, an algal culture:
1. Cannot be produced as a pure homogenous crop in large-scale due to invasive indigenous species and algal predators.
- Open pond cultures are prone to contamination and even “pure” cultures contain a diversity of microorganisms. Open ponds must be restarted periodically to remove invasive “weed” algal species and the ever present algal predators.
- Closed systems moderate but do not eliminate culture contamination by invasive species or predators.
- Closed systems moderate but do not eliminate algal cells escaping the culture and flowing to other locations on winds, wings and water.
- Quality controls and processing which are standard in the modern food industry may enable algal producers to create 99.9% pure products.
2. Changes species characteristics with adaption to environmental change including light, temperature, nutrients, pH, mixing velocity and other production variables.
- Rapid algae adaption benefits producers in the sense that cultures can adapt and flourish in spite of changes in temperature and other variables.
- Rapid adaption may make it difficult to produce a stable culture if the adaption changes biomass constituents.
- Rapid adaption may make identifying indigenous and invasive algal species difficult.
- Rapid adaption may create problems differentiating indigenous versus GE species.
Consumers and producers will benefit from GE guidelines.
Benefits of GE guidelines
Consumer confidence. Consumers in Europe and Asia are more sensitive than US consumers regarding GE crops but US consumers want assurance of product safety too.
Producer confidence. If neighboring algae producers use GE and non-GE strains, the non-GE producer wants assurance that neither new GE strains nor transgenic characteristics invade their culture.
Health and safety. Consumers want to be able to track the health and safety records of algal products which require stable production with substantial quality control metrics.
Environmental safety. The ecological toll taken by modern agriculture with erosion, chemical runoff and pollution has been estimated at $64 billion annually. Environmentalists will be eager to trumpet natural algae blooms that cause problems and use fear mongering with terms like frankenscum. The only way algae producers can prove a better record than modern agriculture is to track ecological insults, when and where they occur.
Life cycle assessment. LCA can provide consumer confidence by assessing the environmental aspects and potential impacts associated with a product, process, or service. LCA is accomplished by compiling an inventory of relevant energy and material inputs and environmental releases and evaluating the potential environmental impacts associated with identified inputs and releases.
Product consistency. Producers want consistent product that meets their customers’ specific needs. The only way to assure consistency for producers and customers will be quality control metrics that track biomass composition.
Toxin avoidance. Producers and customers hold substantial fear that algal toxins may foul food or feed products or local ecosystems. Environmentalists will be quick to invoke scenes from Soylent Green (based upon the 1966 science fiction novel Make Room! Make Room!, by Harry Harrison) where algae ran amuck.
Pricing. Some algae producers may cultivate both GE and non-GE crops and will want to keep the cultures independent for differential pricing.
Organic. Some algae producers may cultivate industrial GE and non-GE algae as well as organic algal products and will want to keep the cultures independent for marketing purposes.
Non-GE algae producers
Algae producers who do not use GE species may take the following action:
- State that no GE species was cultured.
- Care was taken to avoid contamination.
- Quality control metrics are available on each batch sold.
Non-GE algae producers should be careful not to claim:
- The crop in question has no GE germ plasm.
- No contamination occurred in cultivation, harvest and extraction.
The set of language and protocols necessary to conduct business with GE algae will adapt as algal food and biofuels markets mature.