Last Sunday’s edition of The Herald, 10th February 2013, carried an article by Rob Edwards highlighting an environmental mystery we have been wondering about for some time in relation to the farmed salmon industry.
‘Aquaculture’ is a sanitising term – a deceptively clean and sterile moniker for what remains a dirty industry, where profit precludes best practice and regulation is markedly friendly. We prefer to talk about farmed salmon – which is what the greatest volume of ‘aquaculture’ is about.
Being an intense farming process, with dense populations in the salmon cages, not only are sea lice a problem, with easy feeding and multiple breeding – but other sorts of serious biological diseases are also prevalent.
Last year, in 2012, a leading salmon farmer, Marine Harvest, saw its Scottish output plummet to 7,000 tonnes in the last quarter – a figure we estimate conservatively as around 50% of what would have been anticipated. In 2011, Marine Harvest’s Scottish operation was a high performer, producing 60,000 tonnes, suggesting a quarterly output of 15,000 tonnes.
Its underproduction in the last quarter of 2012, given as due to ‘biological issues’, was most probably the amoebic gill disease [AGD] that is a constant problem for fish farmers and swept many Scottish salmon farms last year. For Marine Harvest, these ‘biological issues’ in the last quarter of 2012 will have left around the same tonnage of fish dead as those harvested.
Rob Edwards cites 1,897 tonnes as Marine Harvest’s fish mortalities for the whole of 2012 but that appears to be at odds with the company’s own end of year declaration of harvesting and financials, which would suggest a higher figure.
Our own estimate of Marine Harvest’s mortalities in Q4 2012, drawn from these declarations, may be much more conservative than is obvious. We have used an average quarterly production figure of 15,000 tonnes for 2012. Smaller salmon farmers operate this way, on a pretty even quarterly harvest.
But the major operators, like Marine Harvest – with the means to do so, have a traditional pattern of pushing production up in the last quarter to supply the greatly increased demand for salmon products over the Christmas period.
This pattern would suggest that Marine Harvest’s mortality rate from ‘biological issues’ in the last quarter of 2012 may have been very substantially more than 7,000 tonnes, itself a long way north of Edwards’ estimate.
So where are the bodies?
The key issue is, as Edwards asks, ‘where have all the dead fish gone?’.
The figure he gives for the Scottish total is 13,627 tonnes – or 8.5 million salmon dead in 2012. If the Marine Harvest numbers are indicative, the total may well be much more than that.
The Saveseilsound campaign – quoted by Edwards – discovered that the Ardmaddy salmon farm in Seil Sound in Argyll had lost 82,663 salmon [or 257 tonnes] in under a year – between August 2011 and June 2012.
They too wondered what happened to the bodies.
No one could – or would tell them.
The company owning and operating the controversial Ardmaddy farm, Meridian Salmon, declined to answer Rob edwards questions on this.
The Scottish Environmental Protection Agency [SEPA] told him that the disposal of dead fish is not an area in which they have ‘a leading regulatory role’. This is patently evasive. It cannot reliably be taken to mean that they don’t know where it all goes.
Argyll and Bute Council know nothing about where the waste goes? Should they not seek to know?
This is now a matter not only of animal welfare and sound environmental practice in production and harvesting – but of environmental responsibility in the not uncommon need to dispose of these unimaginably substantial volumes of dead fish.
And it may be much more serious than that – a matter we will come to at the end of this article.
Ewan Kennedy, secretary of the Saveseilsound campaign and a retired solicitor, has been pursuing the matter through Freedom of Information [FoI] requests to the Scottish Government.
Somebody has to know the answer to this material matter.
The carefully methodical questioning of the Scottish Government under Freedom of Information reveals the issue of concern that need to be teased out.
The disposal of salmon waste seems all but invisible in the regulatory procedures, although, as seen in the development of the exchanges below, Saveseilsound has now discovered – but was not told – that the Fish Health Inspectorate [FHI] have a statutory role under The Aquatic Animal Health (Scotland) Regulations 2009.
This matter is now being followed under another FOI request, investigating how the FHI has been carrying out its statutory responsibility.
Communication with Argyll and Bute Council
In a communication to Argyll and Bute Council on behalf of the Saveseilsound campaign, Mr Kennedy wrote:
‘When the EU Regs came in nearly ten years ago a derogation was allowed for the “remote areas” which was intended to apply only for a couple of years, until proper facilities were constructed. The derogation allows disposal “under official supervision” of fish dying of disease or accident by certain very restricted methods. Despite this our Council does not seem to know what happens, although plainly the operators do – but refused to tell Rob Edwards of the Herald when he asked them.
‘The Scottish Government say responsibility is shared between the local authority and the “State Veterinary Service”, which the lady at Argyll & Bute Council identified to me as the AHVLA down South, but when I asked them I drew a blank. It now seems that the “State Veterinary Service” means in this instance the Fish Health Inspectorate in Aberdeen, part of Scottish Government, hence the new FOI request. On the face of things it looks as if regulation is possibly going by default, but I will continue to work towards finding out what happens. What is absolutely clear is that there is a risk to public health in large quantities of dead fish being moved about the country without any “official supervision” in breach of the EU Reg, which was brought in as we all know in the wake of the BSE scare.
‘Even if you think that Argyll & Bute Council has no standing to regulate these matters, as planning authority dealing with the current application you are well placed to ask the applicants what arrangements they have made in the past and what they propose to do in future, given that both Ardmaddy and Port na Morachd are effectively inaccessible by road. The incident in December 2011 involved 257 tonnes of Category Two waste, approximately 30 skip loads I guess. By law this had to be incinerated or ensiled before landfilling. Where was this done?
‘These are not simple debating points.’
The Council’s view is, not unreasonably, that ‘This issue has to be addressed from the top down not from the bottom up. ‘
The first FoI request on this matter
On 28th January, Mr Kennedy received from the Scottish Government the following answers to his first FoI request on behalf of Saveseilsound.
Please supply a copy of the ministerial instrument designating these areas and confirm whether or not it remains in force.
Attached is a copy of the Animal By-Products (Enforcement) (Scotland) Regulations 2011. It can also be found on the following website:
Regulation 9 of the Animal By-Products (Enforcement) (Scotland) Regulations 2011 identifies the areas in Scotland that are categorised as remote areas where category 1, 2 and 3 animal by-products may be disposed of by burning or burial on site or by other means under official supervision which prevents the transmission of risks to public and animal health.
Please inform me about what happened to the FWMG. If it no longer exists please supply details of any successor body.
The Fish Waste Management Group (FWMG) produced a report on “Developing a Framework for a Sustainable Fish Waste Management Infrastructure” in February 2005. The FWMG was commissioned to produce this report and once it was complete the group was disbanded. No successor group has replaced the FWMG.
Please confirm whether or not there is such an instruction to operators of fish farms and if so supply a copy thereof.
There are conditions in the authorisations for fish farms to keep a record of fish farm mortalities in the Aquatic Health (Scotland) Regulations 2009. Regulation 6, (2)(a)(ii) states that it is a condition of an authorisation that the business must keep a record, in such form and manner as the competent authority may specify, of the number of any aquaculture animals that have died in each epidemiological unit within that area. Regulation 6, (2)(d) states that it is a condition of an authorisation that the business must have a system in place which enables the operator to demonstrate to the competent authority that the requirements of Regulation 6, 2(a) are being met.
Under the Animal By-Products (Enforcement) (Scotland) Regulations 2011, the waste originator, transporter and waste receiver must retain all animal by-product commercial documents for at least 2 years. This requirement can be found in Commission Regulation (EU) No 142/2011, Annex VIII, Chapter IV. For some of the information required by the Regulation, the commercial documents can be used as records.
Where the fish farm has its own approved disposal plant (i.e. on-farm incinerator) there will be no commercial documents but records must be kept of the animal by-products that have been incinerated.
Please explain the circumstances in which SEPA are required to seek an explanation for an event mortality. In what circumstances is there a duty on anyone to inform the local authority?
The conditions of authorisations issued under the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR) require that fish farmers furnish SEPA with certain information in the form of returns. These returns contain monthly data about the operation of fish farms and are made to SEPA on a quarterly basis. Amongst the data which farmers are required to supply to SEPA is information on the weight of mortalities at individual fish farm sites during each month of production.
SEPA does not require that farmers provide explanations for the mortalities at a fish farm where these mortalities are in the form of an “event” or the more routine day-to-day loss of fish. There are no circumstances where SEPA would routinely seek an explanation for a mortality event. SEPA considers that such information would be of limited value to the process of regulating farms under CAR although that they may be of interest to other regulators with a remit which includes fish health and welfare. These regulators may place requirements on farmers to provide such information.
There is an obligation to notify in case of suspicion of a listed disease or increased mortality in Regulation 23 of the Aquatic Health (Scotland) Regulations 2009. Regulation 23 states:
23. Obligation to notify in case of suspicion of a listed disease or increased mortality
A relevant person is guilty of an offence if that person–
- knows or suspects that a listed disease is present in aquatic animals; and
- fails immediately to notify the competent authority of that knowledge or suspicion.
A relevant person is guilty of an offence if that person–
- knows or suspects that increased mortality has occurred or is occurring in aquaculture animals; and
- fails immediately to notify the competent authority or a veterinarian of that knowledge or suspicion.
If the Scottish Government is notified of an increased mortality, we would investigate in relation to listed or emerging disease.
Please explain what steps are currently being taken to gather data on the basis of which policy can be formed for the disposal of Category 2 fish waste in a manner compliant with the Directive.
The Scottish Government are not gathering data to form policy on the disposal of category 2 fish waste. The Animal By-Products (Enforcement) (Scotland) Regulations 2011 states what disposal options are available for category 2 fish waste and we expect fish farms to use one of these disposal options.
Options for the disposal and use of category 2 material can be found in Article 13 of Regulation (EC) No 1069/2009.
Response and follow up FoI request
The responses above produced the follow up letter below, with some new requests for infomration.
‘Disposal of fish dying in “event mortalities” on industrial fish farms in Argyll & Bute.
‘I refer to my previous request for information, which you responded to on 28 January 2013.
‘Your reply made no mention of any responsibility on the Fish Health Inspectorate (FHI) for the matters canvassed in my request. You recall that I was concerned to discover information about event mortalities at the Lakeland Marine Farm installation at Ardmaddy at the end of 2011 (the Ardmaddy event).
‘I have now discovered that FHI [Ed: Fish Health Inspectorate] appears to have a statutory role under The Aquatic Animal Health (Scotland) Regulations 2009 (2009 Regulations), implementing the European Council Directive 2006/88/EC.
‘It seems that in terms thereof operators of APBs [Ed: Aquaculture Production Businesses] are required to maintain inter alia registers showing all movements and mortalities of fish and to make the information therein available to inspectors from the FHI on request. In view of this I require you to supply me with information as follows:-
- Was the FHI aware of the Ardmaddy event?
- If so, when and in what manner did the FHI become aware of it?
- Have inspectors from the FHI inspected the records kept by the operators of the site at Ardmaddy?
- If so please supply copies of all reports, records and data arising from such inspections in the period since the inception of the regulations referred to date.
‘I appreciate that you may treat this request as a new request, but would ask you to treat it as extremely urgent.
‘The group which I represent is currently engaging with the planning process in Argyll & Bute and we are under extreme pressure to finalise comments.
‘Separately, following publicity in the Press on the subject of fish mortalities , it has been suggested that some waste from fish mortalities may have been processed into fishmeal. An item appeared on Rob Edward’s blog including the following:-
“Two other councils with fish farms in their areas, Western Isles and Shetland, said that dead salmon went to local landfill sites. “It is the responsibility of the salmon farm to make arrangements for disposal of their waste, including salmon morts,” said a spokeswoman for Shetland Islands Council.
“Some 2,193 tonnes of salmon waste were disposed of at the council’s landfill site in 2012, she added. But most of the waste was turned into fishmeal at a factory at Heogan on Bressay.”
‘The full article can be accessed here:- http://www.robedwards.com/2013/02/where-have-all-the-dead-fish-gone.html
‘Is the FHI able to confirm that none of the waste processed into fishmeal on Shetland belonged to Category Two?
‘I look forward to hearing from you.
‘Ewan G Kennedy’
A new issue raised in the latest FoI
The new issue raised here clearly relates to food safety matters in terms of the possibility aired in the last sentence above – that salmon dying through disease may – even routinely – be processed as fishmeal.
It is against EU regulations to send disease mortalities for fishmeal. It is, however, perfectly legal to use the safe waste – such as the guts and what fishermen call ‘frames’ – skeletons etc.
Fishmeal is fed to growing fish in the salmon cages. The issue here is the risk of contamination of fishmeal made from a diseased source – and with what biological effect? Trace contaminants in the feed can cause diseases and fish mortality.
And it may be much more serious than that – in a matter we will come back to at another time and which is flagged in the above communication with Argyll and Bute Council. BSE in cattle, acquired through cattle feed containing beef derivatives, was shown to pass through the food chain to humans, appearing as what is known as Creutzfeldt Jakob Disease [CJD].
The incremental increases in farmed salmon production are of course giving rise to increased demand for fishmeal. This has serious consequences for fish stocks, with uncontrolled fishing for plankton and for unprotected fish species to fuel this satellite industry.
This is likely to make farmed salmon mortalities, from whatever cause, attractive and, tellingly, regular sources of fishmeal.
The current scandal over unnamed horsemeat and other ingredients in beef, lamb and other meat products sold in supermarkets and fed to school children, hospital patients and the elderly as a result of price-weighted local authority and NHS contracts, has been a wake up call.
It is obvious that the profit motive on one side and the cost saving motive on the other is driving a food industry at the cheap end which has been knowingly delivering anything plausibly like what is contracted in order to maximise economic performance.
Yet, as we are seeing, the one security here is that the source meat products can largely, if not exclusively, be traced.
Salmon products in supermarkets cannot currently be traced to their source farm – and regulatory bodies, with Scottish government backing, are not willing to make public details of which salmon farms fail to meet required animal welfare and/or environmental protection standards.
The public is entitled to know the source of what they are invited to buy to eat; and whether that food has complied in all points of its production with set food, animal welfare and environmental safety standards.
Yet the routine publication of such information to the public is the one sanction that has teeth to compel what is a dirty industry to clean up its act at the cost of a modest percentage of its considerable profits.
This is a very serious issue with an industry whose health, public acceptability and therefore its economic performance is important to Scotland.
With public concern about food security and safety running high at the moment, this is the time for responsible Government to bring the regulatory and protective regimes around fish farming to an acceptable level of assurance and public information.