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The salmon from AquaBounty are genetically modified to grow twice as quickly, making them potentially lucrative in land-based fish farming. (AquaBounty)

Two scientists who helped review a risk assessment of a P.E.I. facility that produces genetically-modified salmon eggs are surprised there is no mention of export limits in Environment Canada's approval.

Dylan Fraser and David Meerburg are independent scientists who were part of a 23-member panel that reviewed a risk assessment document from the Department of Fisheries and Oceans. AquaBounty is producing eggs in Bay Fortune, P.E.I. for salmon that are genetically-modified to grow twice as fast as regular salmon.

The eggs are exported to Panama to be grown into full-size fish. The American company has applied to the U.S. FDA to be allowed to sell the fish as food in the U.S.

AquaBounty applied to Environment Canada to export the eggs commercially if it gets that FDA approval. The P.E.I. plant has been operating as a research facility, but Environment Canada has approved it for commercial production.

From the DFO risk assessment documents

"AquaBounty has indicated its intent … to export no more than 100,000 eggs annually to a contained, land-based grow-out facility … in Panama."

"No more than 100,000 eggs will be exported to Panama in any given year."

Fraser and Meerburg are puzzled that there is no mention of a limit on the number of eggs that can be exported.

The Department of Fisheries and Ocean's risk assessment of AquaBounty states twice that the company does not intend to ship more than 100,000 eggs to Panama a year. That limit is not included in the final requirements set by Environment Canada that AquaBounty will have to follow if it goes into commercial production.

Those rules do say, however, that any significant new activity at the facility would require further review.

Meerburg, scientific and policy advisor with the Atlantic Salmon Federation, said it was his understanding the project would involve a maximum of 100,000 eggs annually.

"Any number larger than that should be considered a significant new activity," he said.

Fraser, a fisheries biologist at Concordia University, said the risk assessment was based on producing 100,000 eggs a year.

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AquaBounty has applied to the U.S. FDA for approval to sell their salmon as food. (AquaBounty)

"I would imagine that a facility that was producing say ten times that many, a million eggs or ten million eggs, would probably require a reassessment to some degree," he said.

"The facility would need to be larger, there would be more manpower required to keep an eye on the equipment."

Expansion not an issue for Environment Canada

But Environment Canada says neither an expansion in production or expansion in the size of the Bay Fortune hatchery would require additional review.

Meerburg said he was a little surprised to see the 100,000 egg limit, because he said it doesn't sound like a lot for a commercial venture. For Fraser, however, 100,000 is a reasonable start-up number for genetically modified salmon.

Meerburg noted the DFO risk assessment is a scientific advisory document, and it is the responsibility of Environment Canada to lay down the final rules.

Environment Canada said the important criteria in its assessment is that all the fish must be produced in a closed environment, with redundant physical and chemical barriers to prevent the escape and survival of fish into the local environment. Only activities that do not have these protections in place must be notified and assessed.

AquaBounty CEO Ron Stotish said he isn't sure why the egg limit was in the DFO risk assessment in the first place.

"I don't think they set a limit. They simply describe the level of activity that had been taking place," said Stotish.

"It essentially says that the facility is safe for production, and it prescribes those activities that would require additional data."

DFO said the figure comes from the company's request for review to Environment Canada. CBC News has asked for a copy from AquaBounty, but so far has been refused.