We recently published an article on a new report commissioned by the Salmon & Trout Association, which shows how the RSPCA has compromised itself in its ‘Freedom Food’ farm assurance and food labelling scheme for the farmed salmon food products of its member producers.
The scheme applies certain tests to member salmon farms before issuing what is presented as a gold standard assurance of exemplary animal welfare and environmental protection practices in farmed salmon production.
The Salmon and Trout Association’s report, commissioned from solicitor and member, Guy Linley-Adams, has a series of concerns. Chief of these perhaps is that the tests applied by the RSPCA’s Freedom Food before permitting its assurance label to be used are little different from those already applied in the salmon farming industry’s own relaxed code of good practice.
The RSPCA/Freedom Food responded to the article as below.
RSPCA/Freedom Food response
‘The RSPCA’s welfare standards – used by Freedom Food members – have been developed for farmed Atlantic salmon solely to improve the welfare of both the fish and the wildlife surrounding fish farms. Freedom Food is a charity and does not make a profit from salmon farms.
- Whilst Freedom Food is focussed on animal welfare, it requires its members to work in harmony with the marine environment. Members must maintain environmental impact and veterinary health plans in addition to adhering to the statutory requirements of the Scottish Environmental Protection Agency (SEPA) and Marine Scotland. All farms must also be fallowed after each production cycle. This varies according to tidal flows etc but means that at each re-stocking the area has been thoroughly cleaned.
- However, in any farming systems problems can occasionally arise. In the case of the marine environment, it is uniquely dynamic and changes rapidly beyond anyone’s control due to factors such as bad weather and the ubiquity of disease. Changes can occur very swiftly and temporarily impact on a farms compliance with wider environmental requirements. Where such changes do occur, Freedom Food scheme members must rectify the situation as quickly as possible through action plans that are carefully monitored by SEPA. It is worth noting that 87% of salmon farms in Scotland were rated by SEPA in 2011 as excellent, good or broadly compliant.
- We are extremely proud of the fact that Freedom Food has been awarded the Gold standard for fish welfare by the independent Marine Conservation Society (MCS) in their Principles and Criteria for Sustainable Fish Farming, and in Greenpeace’s report a Recipe for Disaster. The MCS also recognise that welfare can be of benefit for the environment.
- Both wild and farmed fish can be infected with sea lice and it is important that all measures are taken to reduce the risk of sea lice infestations – the RSPCA’s welfare standards call for adherence to the Aquaculture and Fisheries (Scotland) Act in this regard. In addition, we require the development of comprehensive integrated pest management programmes, through our mandatory Veterinary Health Plans.
- We are also working closely with Freedom Food members and academics in this country and overseas to look at new ways in which sea lice can be better controlled. This includes a two year trial with Freedom Food salmon farming members, who apply for permission, to experiment with using wrasse – known as ‘cleaner fish’ – to control lice on salmon. The wrasse live with the salmon and feed off the sea lice. However, before we can incorporate the use of wrasse formally into our welfare standards, considerably more data needs to be gathered to ensure optimum welfare for both the salmon and the wrasse themselves.
- The RSPCA and Freedom Food are one hundred per cent committed to improving the welfare of all animals – in tandem with respect for the marine environment – it is the sole reason the RSPCA exists.’
Questions arising from this response
We noted that the claim in the response that: ‘at each re-stocking the area has been thoroughly cleaned’ was unsupported by evidence or detail of the practice of how this is done.
It is, in fact, highly misleading.
Nobody cleans the seabed – nor can one rely on natural processes to do so.
Fallowing – the period a salmon cage is taken out of use before restocking – takes place for a minimum of six weeks.
In this time the massive accumulation of faeces etc on the seabed – which may be 1m deep – is very unlikely to be fully dispersed. This is particularly true of ‘slacker’ locations where there is limited tidal flushing.
It is also worth noting that fallowing generally takes place in winter when, given the low water temperature, biological breakdown of the sludge deposited on the seabed will be minimal.
What tests are applied by salmon farmers to support the claim that ‘the area has been thoroughly cleaned’ before restocking? Are divers, for example, sent down to assess the sea bed and collect samples for laboratory testing?
We understand from the Salmon & Trout Association’s own discussions with salmon farmers, that no tests are carried out to establish the ‘cleanness’ of the sea bed; and that no divers are sent down to check it.
Can a salmon farm effectively license itself to restock after fallowing – or does SEPA, for example, have to be given test results and show a red or green light?
Farms are permitted to stock with fish for 22 months out of 24 – there are no other restrictions and they do not have to demonstrate in any way that the fallowing has ‘cleaned’ the seabed.
Animal welfare issues
In its recommendations, the Salmon & Trout Association’s commissioned report includes the following:
’9.5 The RSPCA should consider dropping all environmental standards from Freedom Food certification, concentrating solely on animal welfare issues relating to the farmed fish, with the corollary that no certified farm or retail market outlet may make environmental claims based on Freedom Food certification or use the certification in such a way as to mislead consumers that the certification implies good environmental performance.
’9.6 Alternatively, the RSPCA must dramatically improve and make far more stringent those standards in the Freedom Food scheme concerning wider environmental impact and impact on wild fish, in consultation with wild fish conservation bodies.
’9.7 The revised standards should include a requirement on all fish-farms to demonstrate complete openness in relation to weekly farm-specific sea-lice data, publication of Environmental Impact Plans (required under EVI 1.1) and other environmental data, prior to any certification by Freedom Food.’
The position here is that the RSPCA’s frontline concerns and its historic expertise centre on animal welfare and not on environmental issues.
The Salmon & Trout Association report therefore essentially recommends that it stick to what it knows and where the public is entitled to assume they can trust its judgment.
The question then actually becomes even more difficult for the RSPCA – because it is essentially indemnifying salmon members of its Freedom Food assurance scheme against any allegation of unsatisfactory animal welfare practices.
Even as things stand with the Freedom Food animal welfare and environmental protection assurance scheme, the RSPCA, which wholly owns Freedom Food, has to put its name to glossing animal welfare practices which, under any secure scrutiny criteria would appear to be beyond defence.
Sea lice and wrasse
An endemic problem in the dense populations of salmon farming is sea lice infestation. This is dealt with in what passes for regulation of the industry by imposing numbers of sea lice per salmon that should not be exceeded.
The industry’s has two methods of treating such infestations:
- chemical drenching – delicately expressed as ‘medicinal treatment’ – sometimes immersion in hydrogen peroxide baths, with the last drenching carried out at a specific period before harvesting;
- the use of wrasse, generally a small fish under 20cm long, to cohabit the salmon cages.
The Scottish Salmon Company (SSC) introduced wrasse to a salmon farm in the Western Isles in the Autumn of 2012. It had first worked with Viking Fish Farms at Ardtoe on Rannoch Moor in Argyll to develop the first commercial production of ballan wrasse.
The wrasse are kept hungry so that they eat the parsitic sea lice off the salmon they live with – and the salmon farming industry refers to them as ‘cleaner fish’.
However, kept hungry as they must be, as they progressively demolish the sea lice – or if a chemical treatment applied to the cage has actually worked and killed sea lice – the wrasse apparently turn to eating the eyes out of the salmon as an alternative source of the food they are left to crave.
This leaves numbers of the intense population in the cage swimming blind or half blind, regardless of the experience of having had their eyes eaten out.
This is an animal welfare issue which opens even that aspect of the validity of the RSPCA’s Freedom Food assurance to serious question.
Diseases in farmed salmon
The intensity of production of farmed salmon inevitably leads to the spread of contagious diseases. Most of these raise mortality levels, sometimes dramatically. They are largely treated, where possible, by vaccinations and antibiotics.
The impact of disease can be seen in the 2012 performance of the Scottish wing of the world’s biggest aquaculture combine – Marine Harvest.
In 2011, its Scottish operation was highlighted as its best performing division, with high production volumes of over 60,000 tonnes.
In the last quarter of 2012, however, its Scottish production fell to only 7,000 tonnes – said to be due to ‘biological issues’. This under production and a drop in the price of farmed salmon saw the group’s profits in the last quarter of 2012 fall from an anticipated £18 million to £6.6 million. In the last quarter of 2011, the last quarter profits had been £44 million.
The ‘biological problems’ cited by Marine Harvest are unspecified but may well have been the Amoebic Gill Diseae that swept the farmed salmon industry in the last part of 2012.
One of Scotland’s big five salmon producers, Greig Seafood, operating in Shetland, reported that it lost a third of its 2012 last quarter harvest to this disease, with 2,400 tonnes of salmon, carrying a market value of £8 million, dying between October and December.
Amoebic Gill Disease [AGD] is not normally seen in Scottish waters but in the unusually warm sea temperatures of the last quarter of 2012 and in the intense conditions in salmon cages, it appeared and mushroomed.
Greig Seafood took a write down of £5 million on this outbreak – taken up to £10 million on account of an outbreak of a different disease in its Canadian operation. Marine Harvest suffered a further knock back in its own figures as a result of an outbreak of listeria at its Delifish smoked salmon finishing plant in Chile.
We need to hear the RSPCA’s posiiton on the use of wrasse and on the diseases suffered by salmon farmed in these dense conditions and from which they cannot be protected.
We need too to hear its independently informed posiiton on the animal welfare aspect of farmed salmon’s impact on wild salmon – and particularly on the matter of the effect of sea lice in free swimming mode attaching themselves to passing and fragile juvenile salmonids on their first outward migration.
We also need much more detailed information on the way farmed salmon are harvested. Canada’s Mainstream company says that its fish are ‘crowded’ in seine nets, put aboard a harvest boat where ‘Stress is minimized and oxygen levels and behaviour are closely monitored.’ They are then ‘stunned and bled’.
This information does not extend to describing:
- just how stress levels are kept to a minimum;
- how it is practically possible at any effective level to momitor oxygen levels and behaviours in crowded numbers of fish;
- how the salmon are stunned – in a mass production, profts driven process, this will not be a time consuming procedure.
The Salmon and Trout Association report is espressly concerned that the RSPCA/Freedom Food operation will not disclose whether any of its members fail to gain accreditation nor will they publish farm-specific sea lice data.
Yet, with the recent revelations that people who thought they were buying beef burgers were in fact buying and eating a blend of beef and horsemeat, there is increasing demand from consumers to know exactly what they are eating and the circumstances in which it has been produced.
We can find no procedure nor any assurance that RSPCA/Freedom Food approved products are traceable to their source farm. We are asking the company to enlighten us on this and will report back.
In the meantime there is news of two experimental initiatives to improve what is a dirty industry’s environmental performance. The motives, however, are not essentially altruistic but relate, in one case, to halving the production cycle of farmed salmon and at lower costs; and in the other, to removing the necessity to feed farmed oysters and mussels by locating them near a source of waste nutrients.
A closed containment farming initiative in Tayinloan
Environmentally aware and expert campaign groups, like saveseilsound, have long advocated that salmon farmers move to closed containment production, as is seen, but not universally practised in Camada.
Earlier this month it was announced that a plan for the world’s biggest ‘salmon warehouse’, a £15 million onshore development at Tayinloan in Kintyre – which would be a closed containment operation – is to be submiited shortly to Argyll and Bute Counbcil for planning consent. The developer is Perthshire’s FishFrom company based in Dunkeld.
The 3.5 acre warehouse would house tanks annually producing 3,000 tonnes of farmed salmon with no connectiom to sea or river. This rules out the problem of farm escapees breeding with wild salmon and/or infecting them with sea lice.
It appears to be an accelerated production process in which smolt of 50g would be grown to salmon of 5kg in only nine months. This is half the time it takes to grow such fish in sea loch cages.
The process is said to cut costs as well as environmental impacts.
In this system the faecal and food debris does not drift down to the sea bed but is contained. However, we do not know how this sludge will be disposed of when it is cleaned from the containment tanks prior to restocking.
Am integrated multi-trophic aquaculture project in Loch Fyne
David Attwood, Aquaculture Director of Loch Fyne Oysters has been consulting with local communities – as is required prior to submitting a planning proposal – on 3 year pilot scheme for an integrated multi-trophic aquaculture project in Loch Fyne.
The scheme proposes to locate oyster and mussel farms closer to existing salmon farms – because mussel and oyster farms are benign and filter the water plankton, sea lice etc, helping to clean up pollution.
The system combines fed species in aquaculture – like salmon – with inorganic extractives like seaweed and organic extractives like shellfish to create an ecological balance that enables natural remediation, or biomitigation.
This process has the commercial advantage of improving the economic stability of operations through improved output, lower costs, product diversification and risk reduction.
It also has the advantage of being more socially acceptable – and therefore likely to produce fewer objections to planning applications – because it is based on better management practices.
So, in the Loch Fyne proposal, the oysters and the mussels will get drifting excess nutrients from the salmon farms and won’t need to be fed, although they will have to be looked after.
There would be two sites: one in Furnace Bay near to the current small fish farm and the other at Ardcastle, betwen Minard and Lochgair.
The sites would largely be serviced by boat from the Quarry Point Fish Farm near Minard with a traffic increase of around two HGVs a week are likely.
The water footprint would run to 2 hectares – a major development. The likely timescales are a planning decision within a year and, if successful, a further 2 years for species o reach a sustainable size.
Note: It is important to note that both the Salmon & Trout Association’s commissioned report and the RSPCA/Freedom Food response published above, refer to a supportive statement on the assurance scheme from environmental organisation, Greenpeace.
The Linley-Adams report for the S&TA quotes Greenpeace as saying: ‘Freedom Food standards developed by the RSPCA for farmed fish are also good although the standards are primarily welfare based, the better environment which they provide for the fish not only produces healthier fish, but also reduces the impact on the marine environment around the farm.’
The RSPCA/Freedom Food response above says: ‘We are extremely proud of the fact that Freedom Food has been awarded the Gold standard for fish welfare by the independent Marine Conservation Society (MCS) in their Principles and Criteria for Sustainable Fish Farming, and in Greenpeace’s report a Recipe for Disaster. The MCS also recognise that welfare can be of benefit for the environment’
The Greenpeace statement was contained in a report, A Recipe for Disaster – published back in 2005, eight years ago and in very different times. Greenpeace today cannot be held to a view formed so long ago in the context of an industry whose scale of operation has since undergone a compound increase and whose monitoring features the celebrated British ‘light touch’.