Executive Summary – Salmon & Trout Conservation Scotland – 2018 revision – Permission Guy Linley-Adams
Fish Health Inspectorate (FHI) inspections 2015 to 2017
33. Information relating to the inspection and operational activities of Marine Scotland’s FHI is published on a regular basis at http://www.gov.scot/Topics/marine/Fish-Shellfish/FHI/CaseInformation.
34. A number of Loch Fyne farms have been inspected in 2015 and 2017 by FHI.
35. Inspection of the farms by the FHI shows considerable use of a range of anti-sea lice treatments during the peaks of sea lice numbers on farms which do not appear to have kept adult female sea lice numbers on the farmed fish below Code of Good Practice thresholds.
36. Rubha Stillaig was inspected on 15th February 2017, the FHI recording that the “site has been using hydrolicer as lice treatment. Has been effective at reducing lice numbers, although numbers still slightly above suggested criteria for treatment. Site suffered increased mortality between July and November, due to complex gill issues and PD”. At the time there were 61,433 salmon on site with average weight 3.66 kg, as well as 19,451 wrasse. Sea lice levels were recorded as not being below the suggested criteria for treatment in the CoGP during the period that records were inspected (CoGP Annex 6)
37. Glenan Bay was inspected on 15th February 2017, with the FHI recording that the “site experienced large numbers of mortalities between August and November due to PD/complex gill issues….Sea lice levels below CoGP suggested criteria for the majority of period checked, one or two elevated counts (1.06 – 1.12). Hydrolicer has been successfully used instead of chemical treatment”. At the time there were 165,599 salmon of average weight 2.87 kg and 16,000 wrasse on site.
38. Furnace Quarry was inspected on 28th February 2017. The FHI recorded that the “site harvested in December 2016 with remaining fish transferred to Quarry point to reduce number of cages in the Loch requiring treatment. Could not assess containment measures as site fallow. Treatments: Slice in April and June 2016, Alphamax June 2016, Salmosan 2 x August 2016 and end September/beginning October 2016, Hydrogen peroxide in October 2016, Hydrolicer x 2 beginning and end of November 2016. Levels coming down post treatment but resettlement was reported to have been quick.
39. Despite all the above treatment being deployed, the FHI recorded that the farm was “not below CoGP treatment thresholds from August 2016 through to harvest and at least one count of over 8 AF [adult female lice] was recorded every week from the implementation of the new sea lice policy in October 2016 until harvest” and that “bioassays conducted in Loch Fyne showed high resistance to AMX and lowered sensitivity to Salmosan Vet. Reported that Salmosan and Hydrolicer achieved good initial clearance but resettlement was rapid. AMX used initially, moved to Salmosan following gill issues. Enhanced sea lice control report for this cycle viewed – report contains review of sea lice treatments and assessment of efficacy”.
40. The FHI also recorded that “Lice numbers over 3 and 8 not reported to FHI. Lice peaked at 23.13 AF on 21/11/16”, acknowledging that “during the inspection the site was found to have had average adult female Lepeophtheirus salmonis (‘sea lice’) per fish counts of three or above. These counts had not been reported to the Fish Health Inspectorate as part of the required measures to demonstrate that satisfactory measures are in place for the control of sea lice. Where the average adult female sea lice per fish count reaches three or above this must be reported to the Fish Health Inspectorate within seven days of the date of the count”.
41. Despite the above, FHI was remarkably still able to conclude that “the site meets the requirement of current Scottish industry best practice at the date of inspection…”
42. A number of other mortality events at Loch Fyne farms were reported to the FHI during a visit to the business office in Lochgilphead in March 2017, covering the Ardcastle, Gob a Bharra, Meall Mhor, Tarbert South and Strondoir farms, being largely post-treatment and gill disease-related mortality events.
43. At the Thirty-Third Annual Meeting of NASCO in June 2016, the Scottish Government announced a new sea lice management policy for Scottish salmon farming, which required all salmon farmers to develop site specific escalation action plans to be implemented when sea lice levels rise above 3.0 average female lice per farmed fish. Furthermore, when levels exceeded 8.0 average female adult lice, the new policy was to result in enforcement action by Marine Scotland, including the potential to require reduction in biomass. Since the Scottish Government announcement, the following farms on Loch Fyne have breached the 3 or 8 triggers, but with no enforcement notices served on any of them.
Ardgadden >3 adult female lice per farmed fish
Furnace Quarry >8
Gob a Bharra >3
Meall Mhor >3
Quarry Point >8
Strondoir Bay >8
44. S&TCS has produced a critique9 of the Scottish Government’s new sea lice management policy for Scottish salmon farming and has written to NASCO over the failure of the new policy to meet the NASCO’s agreed 2009 Guidance on Best Management Practices to Address Impacts of Sea Lice and Escaped Farmed Salmon on Wild Salmon Stocks. The Head of Delegation for the EU (through which Scotland is a member of NASCO) has undertaken to contact the Scottish authorities to seek clarifications.
45. Nor were the problems recorded on Loch Fyne in 2017 new. The Furnace Quarry farm had earlier been inspected on 11th October 2016. Inspectors recorded a Salmosan treatment on 1st October 2016 and peroxide treatments throughout Loch Fyne with “lice levels coming down below 50% of untreated total, however resettlement is quick”. A number of lice damaged fish were reported in the cages with lice load being above the suggested criteria for treatment, Inspectors also recorded that “in addition to most sites in the area (whole loch) is treating with peroxide, however treatment has been difficult because of gill issues”(sic). At the time there were 100,000 fish on site of 2.9kg average weight with mortalities in the previous four weeks reported between 15 and 8.5% per cage. Tests also confirmed the presence of Amoebic Gill Disease (AGD). There was evidence of lesions suggestive of post-treatment effects and of chronic pancreas disease (PD). Tests also were positive for salmon gill poxvirus.
46. Ardgadden was inspected on 11th October 2016. A number of lice damaged fish were reported within the cages with lice load above suggested criteria for treatment. Similarly as with all other TSSC sites in Loch Fyne, the site was treated with peroxide, but inspectors noted that treatment “has been difficult because of gill issues”. At the time there were 322,000 fish of average weight 2.2kg on site with mortality ranging between 6.24% to 31.6% per cage over the previous four weeks, averaging 20.07% across the entire farm.
47. Glenan Bay was inspected on 12th October 2016 with the inspectors recording that wild caught mixed species of wrasse were being used as cleaner fish, the wild fish being from Mull, and the farmed, ballan wrasse from Otterferry. The site reported that wild caught wrasse were more effective at lice control than farmed wrasse. The farm reported severe and active AGD with evidence of PD and recorded that the lice load was above the suggested criteria for treatment and, as with all other TSSC sites on Loch Fyne, the fish were being treated with peroxide which was proving difficult because of gill issues. At the time there were 240,000 salmon of average weight 1.3kg on site together with 16,000 mixed species of wrasse. Recent mortalities averaged 12.24% over the previous four weeks. The lice load was recorded at about five adult females per fish.
48. Gob a Bharra was inspected on 15th June 2016 by the Fish Health Inspectorate. The inspection report confirmed sea lice treatments since November 2015 with Slice on numerous occasions, Salmosan and Alphamax. Lice numbers were recorded as having exceeded the CoGP recommended criteria for treatment over the last month to the inspection date. There were no cleaner fish on site. Two to three gravid female lice were observed on fish sampled for the Veterinary Medicines Directorate. At the time there were 355,593 fish on site of roughly 1.7kg each.
49. Inspections carried out in 2015 show that difficulties were being experienced with sea lice on the Loch Fyne farms in the previous production cycle.
50. Meall Mhor was inspected on 28th January 2015. The reports recorded that lice numbers increased in November 2014 and there had been treatments with Alphamax, Salmosan, Slice and Salmosan again in January 2015. On 11th March 2015 lice levels were recorded at 10 per fish of all stages and above the suggested criteria for treatment in the CoGP for adult female lice. At the time there were 123,500 fish on site of average weight 4.9kg. The FHI conducted an enhanced sea lice inspection.
51. Ardcastle Bay was inspected on 29th January 2015. The inspection recorded the use of Slice and Salmosan in the previous two months to control sea lice which had peaked at a level of 9.57 adult female gravids per fish. Treatments were noted to “have seen an overall reduction of greater than 50% of all stages, but not brought numbers below suggested criteria for treatment”. At the time there were 307,260 fish on site of average weight 3.9kg.
52. Quarry Point was inspected on 14th April 2015. The inspection recorded that lice levels were averaging 20 per fish of all stages with 1 to 4 adult female lice per fish. A peroxide treatment on 5th March had brought numbers down from 49.65 lice per fish of all stages to 8.64 lice per fish of all stages. At the time there were 130,907 fish of average 5.5kg on site and an escape was reported to Marine Scotland on 2nd November 2014. This was later confirmed as an escape of 2090 farmed salmon10.
53. Tarbert South was inspected on 14th April 2015. Lice levels were recorded at 6.1 lice per fish with 0.6 adult female lice per fish. Fish had been moved onto the site from Ardgadden as Ardgadden was going to exceed its permitted biomass. At the time there were 53,346 fish on site of mean weight 4.7kg.
54. On 16th April 2015, Rubha Stillaig was inspected. The inspection report records that the fish had been treated with Alphamax in November 2014, Slice in January 2015, Salmosan in January 2015 and Hydrogen peroxide in March 2015. Mortalities had reached 9,000 and 7,000 in cages 1 and 2 due to gill issues. There was an average of 9.2 lice of all stages with 1.2 adult female lice per fish recorded. At the time there were 29,972 fish on site of average 4.66kg.
55. On 15th April 2015, Strondoir Bay was inspected with the inspection recording that the site had been treated with Alphamax in November, Slice in December and Salmosan in January, which achieved only a 40 to 50% clearance. Hydrogen peroxide treatment on 13th March had achieved a 90% clearance, but lice levels of all stages were currently at 9.58 with adult females at 3.2 lice per fish. Total mortalities for the production cycle were recorded at 25,692, which is “considered low”. At the time there were 229,598 fish on site of average weight 4.9kg.
56. On 15th April 2015 Ardgadden was inspected. The inspection recorded Salmosan treatment in October and November 2014 and Alphamax in November 2014, Slice in December 2014, Salmosan in January and February 2015 and peroxide treatment in March. During the cycle there had been 39,937 mortalities amounting to 5.67%. At the time there had been 276,298 fish on site of an average weight of 4.7kg.
In-feed treatments for sea lice with emamectin benzoate, the impact on wild crustaceans and phasing out Slice
57. Recent research shows that the negative effects of the use of the in-feed treatment Slice (as widely used on Loch Fyne) have been underestimated.
58. The SAMS report from 201611 has raised serious concerns that residues of Slice, excreted by farmed fish and spread into the wider sea loch environment, have had a far greater impact on wild crustaceans than was predicted when Slice was first licenced. The SAMS authors concluded that: “the evidence indicates a wide scale cumulative impact and incomplete recovery between successive emamectin benzoate treatments…..”
“the ecosystem consequences of the observed reduction in crustacea are not known, but crustacea include important fishery species such as crabs and lobsters…”
“the evidence suggests that benthic crustacean may not be adequately protected by the current regulation of EMB use in Scottish salmon farms”.
“our results indicate that, even allowing for regional differences in the physical properties of the receiving environment, the use of EMB is associated with substantial, wide scale reductions in both the richness and abundance of nontarget crustacea. Given the findings in this report we believe there is an urgent requirement to… consider the likely ecosystem consequences of large scale reductions in crustacean richness and abundance at the scale of sea lochs”.
59. Small crustaceans are important prey species, forming part of the marine diet of sea trout.
60. In February 2016, SEPA’s high level Agency Management Team (AMT) was asked to approve appropriate regulatory action to effect a managed phase out of the use and discharge of Slice on Scotland’s fish farms, reducing use immediately and setting “a date for the complete suspension of the relevant CAR licence conditions to prevent use of Slice at all fish farms in Scotland (at present we recommend a target of 2 years to achieve this phase-out, (in any event it should not exceed 3 years)”.12
61. Subsequently, the SAMS report was subject to peer review commissioned by SARF, but, astonishingly this was conducted by 5 out of 6 reviewers appointed by the manufacturer of Slice, Merck. As the review states “to provide a wider context to the PAMP 2 (2016) Report (see below) and to address some of the concerns and recommendations from SARF Directors” which led to the key conclusion that “all those reviewers who commented on technical, statistical, benthic and inferential matters seemed therefore to regard this investigation as one whose nature and conclusions are insufficiently well founded to demonstrate cause, pathway or appropriately measured effect, one that is therefore unsuitable for direct use in evidence based regulation, but as one that is indicative of an issue that deserves more rigorous investigation”.
62. SARF’s director body, listed below, is dominated by bodies supportive of aquaculture, including the Crown Estate (which leases the seabed to fish farms), the Sea Fish Industry, Association of Scottish Shellfish Growers, Marine Scotland, Highlands and Islands Enterprise and the SSPO.
63. SEPA’s handling of the Slice issue led to accusations of cover-up and undue pressure being brought to bear on SEPA to continue to allow Slice to be used, despite the SAMS’s conclusions13.
64. Since then there have been five Decisions from the Scottish Information Commissioner concerning either Marine Scotland’s or SEPA’s failure to provide full information on Slice and the potential for a ban.
65. SEPA also commissioned WRc14 to propose new EQS values for emamectin benzoate, which proposed new levels which would effectively have precluded the use of Slice for sea lice control.
66. Under further pressure from the fish farmers, SEPA then issued a further call for information and UKTAG is expected to recommend a new EQS to Scottish Ministers at Easter 201815.
67. A written submission16 from the Scottish Creel Fishermen’s Association (SCFF) to the ECCLR Committee gives the current position, but, as SCFF notes, it is important that scientific advice is given free from the influence of the aquaculture industry, a concern the creelers have raised with the ECCLR Committee, given the way matters have been handled since the SAMS report first emerged.
68. This exercise may yet end the use of Slice on Loch Fyne completely, but, at the very least, any revised EQS for emamectin benzoate is expected markedly to reduce the quantity of Slice that can be used on the Loch Fyne fish farms, making effective control of sea lice at the current permitted biomass on the farms less likely, which should then lead SEPA to reduce that permitted biomass.