Mass mortality data published earlier this month by the Scottish Government's Fish Health Inspectorate makes for grim reading for the salmon farming sector - with 233 'Mortality Event Reports' already during the first six months of 2020 reporting 2.52 million dead farmed salmon due to Cardiomyopathy Syndrome, Pancreas Disease, Heart & Skeletal Muscle Inflammation, Fungus, Infectious Pancreatic Necrosis, viraemia, Moritella, Vibrio, Yersinia, Amoebic Gill Disease, physical damage and mechanical losses.
2.52 million dead farmed salmon in 233 'Mortality Events' during the first six months of 2020. This has been a catastrophic summer for Scotland's fish farms. Our seas are getting warmer. Expect more of this to come. Tens of thousands of these fish are killed by disease treatments https://t.co/NwCaDvhKG9
God forbid any tourists going down to the Dunvegan Harbour 🤢It’s grim. The smell is regularly overpowering. I am surprised that the Macleod’s Dunvegan offices up the road haven’t complained. Who knew they are adjacent to such morbid death.
Grieg Seafood reported Heart & Skeletal Muscle Inflammation (linked to Piscine Reovirus) to @marinescotland back in July. Jellyfish are being made scapegoats for virus-laden farmed salmon @GriegShetlandhttps://t.co/6koo3UKCKZ
When I filmed earlier this month (8 September 2020) at Landcatch's salmon hatchery at Ormsary, I was assaulted by the boss of Hendrix Genetics Scotland (Jarl van den Berg) who pushed me and attempted to grab my camera to stop filming.
The boss of Hendrix Genetics Scotland (owners of Landcatch) strongly objected to Scottish Salmon Watch filming in a public area and taking samples of salmon hatchery effluents being discharged onto a public beach on Loch Caolisport in Argyll.
Here's video footage shared with Police Scotland and Hendrix Genetics.
Scottish Salmon Watch asked Police Scotland to give the 29-year old a warning rather than file a formal complaint that may have led to an assault charge.
However Scottish Salmon Watch's polite request in 2018 for a formal site visit was refused leading to a night time visit in March 2019.
Perhaps Hendrix Genetics have unwanted pathogens, viruses and infectious diseases hiding in the waste effluents they are discharging into Loch Caolisport?
A front page exclusive by The National reported (31 May 2018):
Earlier this week (1 September 2020), the Scottish Government published a FOI reply which denied any knowledge of any trials of Imidacloprid since 2017.
Benchmark's FAI Aquaculture web-site refers to "the need to maximise the sustainability and minimise the environmental impact of the technologies, and practices we develop" but there is no mention of the use of the neonicotinoid insecticide Imidacloprid or the 'CleanTreat' system which was developed over a 10-year period at Ardtoe.
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Tue, Aug 25, 2020 at 3:07 PM Subject: Additional Information re. SEPA 202000275 To: Karin Killington <kkillington@itspublicknowledge.info>, <wsneddon@itspublicknowledge.info>
Scottish Salmon Watch strongly believes that there is a public interest in the disclosure of information on 'CleanTreat' including BMK08 (Ectosan).
In fact, it was only in March 2020 that Scottish Salmon Watch discovered that BMK08/Ectosan was the toxic neonicotinoid insecticide Imidacloprid (banned by the EU in 2018 for use in terrestrial agriculture).
This was reported via The Ferret, ENDS and other publications in March 2020:
Suffice to say that this controversial disclosure adds considerable weight to Scottish Salmon Watch's appeal.
Moreover, Scottish Salmon Watch further revealed in May 2020 (via a FOI disclosure by SEPA) that salmon farming giant Mowi in March 2020 had asked SEPA to support a field trial of Ectosan (re-named BMK08 in November 2019) in Loch Ailort:
In June 2020, Scottish Salmon Watch published scientific opposition to the use of Imidacloprid (which Benchmark proposes to use via the CleanTreat system):
Scottish Salmon Watch also published further details on the patents secured by Benchmark (information which we are not even sure that SEPA was in possession of):
The Sunday Times and BBC Radio featured the controversial issue in June 2020 and British Wildlife viewed the issue as such a public concern that they featured it in their Editorial in August 2020:
SEPA's refusal to disclose information on CleanTreat, BMK08, Ectosan and Imidacloprid is an affront to transparency and runs counter to their role as a publicly-funded watchdog for the environment. Scottish Salmon Watch believes that protecting the commercial interests of a Norwegian-funded industry at the expense of the Scottish environment is unacceptable and unreasonable.
It beggars belief that SEPA are placing the profits of Norway's 5th richest man (Johan Andresen - owner of Ferd Capital which controls Benchmark) before the Scottish environment and public accountability.
Scottish Salmon Watch asks the Scottish Information Commissioner to force the disclosure of information in the public interest. The considerable media coverage of the issue since March 2020 when it was publicly revealed that CleanTreat was a Trojan Horse designed to use a banned neonicotinoid insecticide is evidence enough.
Please force SEPA to protect the Scottish environment rather than protect the commercial interests of a Norwegian company wanting to keep secret documents detailing the use of a toxic neonicotinoid insecticide.
If you require further information please do not hesitate to contact me on 07771 541826.
Here's the latest lice infestation and mortality data published by Mowi Scotland (for all Mowi's faults they stand head and shoulders above other companies in terms of transparency of reporting lice and mortalities):
Last month, Mowi's Q2 2020 financial report was a dog's dinner for Scotland with infectious diseases and mortalities downgrading volume guidance by 8,000 tonnes.
Here's the worst mortality rates at most of Scotland's salmon farms during July 2020 (not all salmon farming companies - e.g. Kames - are members of the SSPO):
If you're bored this weekend you could spend some time number-crunching data published by the Scottish Government via 'Scotland's Aquaculture' where 3.5 million escapees in 350 incidents have been reported since 1995 (since the numbers of escapees is listed as 'unknown' in many cases the true figure could be over 4 million).
Click on 'CSV Export' and an Excel spreadsheet can be downloaded detailing 350 reported escape incidents from fish farms in Scotland (the data set only dates back to 1995) here's the top 50 largest escapes:
If you focus the data search on 'Mowi' (via 'Show/Hide Advanced Filters') you can see that out of 344,778 escapees reported in 51 incidents the number of escaped farmed fish recovered is listed as 3,061 (even those with a basic grasp of Maths will know that is less than 1%):
Number-crunching the whole data set published by the Scottish Government gives a recapture rate of less than 3% for escapes from fish farms since 1995. However, the recapture rate for sea cage salmon farms is much worse with only 3,998 escapees recaptured out of 2.87 million (that's 0.1%!!!). Here's the only cases since 1995 where escapes from salmon in sea cages have been recovered:
According to the data published by the Scottish Government from returns submitted by the salmon farming companies themselves here's the Top 20 largest escapes (not yet including last week's escape in Kilbrannan Sound) from Mowi.
Last week's escape of 48,834 is Mowi's second largest reported escape in Scotland.
The escapees have been reported washed up on beaches with warnings to anglers across the area.
"Anglers across Ayrshire have been warned to report any obviously farmed salmon they find to @marinescotland. The farmed fish are identifiable because of deformed or shortened features such as their fins, gill covers & snouts" https://t.co/7QDaZpZSHC@arranbanner@ArranCoast
According to the Scottish Government's web-page 'Fish Farm Escapes', "authorisation for the emergency use of nets to affect recapture must be applied for":
It does not seem as if Mowi or Ayrshire Fisheries Trust have mounted a recapture effort - with the latter issuing a reporting form on 26 August 2020 "that should be completed and returned along with scale samples, photos, location etc for anyone catching an escaped farmed salmon in any Forth of Clyde connected river".
Scottish Salmon Watch believes that financial incentives are urgently required to reduce escapes but fines as in Chile and rewards for recapturing escapees as in Norway do not appear to be on the agenda in Scotland. It is not even clear if Mowi, Marine Scotland or wild fish agencies have mounted a recapture effort.
Following the recent escape of farmed fish from the Salmon farm at Carradale, we are asking all anglers who capture a farmed fish to report it here: https://t.co/GTaVvgzy71. We would also like any fish caught in the area, incl. wild, to have scale samples taken. Details in form.
— Fisheries Management Scotland (@fms_scotland) August 26, 2020
Whilst Mowi leaks salmon (not to mention untreated effluent, pathogens, lice, viruses and infectious diseases) like sieves, executives are laughing all the way to the bank.
Scottish Salmon Watch today (28 August 2020) wrote to Scottish Ministers repeating calls for hefty fines, rescinded licences for repeat offenders like Mowi and fines for highly paid executives.
The Scottish Parliament's Rural Economy & Connectivity Committee recommended in November 2018 that "appropriate sanctions should be developed and introduced in Scotland" in relation to escapes from salmon farms:
The Scottish Parliament's Rural Economy & Connectivity Committee recommended in November 2018 that "appropriate sanctions should be developed and introduced in Scotland" in relation to escapes from salmon farms:
Back in 2014, the Global Alliance Against Industrial Aquaculture called for hefty fines, rescinded licences for repeat offenders and prison sentences for escapes in a press release: "Scottish Salmon's Great Escape"
"Mowi's disease-ridden salmon farms are dead in the water in Scotland with 8,000 tonnes less production forecast in 2020," commented Don Staniford, Director of Scottish Salmon Watch. "Lice infestations, Cardiomyopathy Syndrome, Pancreas Disease and Pasteurella Skyensis are plaguing Mowi's Scottish operations. The horror story that is Mowi features mass escapes, mass mortalities and ongoing welfare abuse."
Quoted in today's @ScotNational: "Whilst Norway continues to ban imports of Scottish salmon eggs due to disease and genetic risks, @GreenerScotland is recklessly resuming imports from Norway where salmon farms are being plagued by ISA" https://t.co/vJYDUF4lh1@InfoMattilsynet
Download press release with Notes to Editors in full online here
Download press release with Notes to Editors in full online here
Scottish Salmon Watch wrote to Scottish Ministers (26 August 2020) calling for a ban on imported ova and testing of hatcheries and farms for infectious diseases, viruses and pathogens - download letter as a PDF online here
Scottish Salmon Watch filed this FOI request with the Scottish Government (8 July 2020):
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Wed, Jul 8, 2020 at 9:40 AM Subject: FOI re. ova imports & ISA since 16 December 2019 To: <ceu@scotland.gsi.gov.uk>
Ova import data since the last imports detailed in the information disclosed via FOI-19-02663 (i.e. data since 16 December 2019).
Information in relation to discussions re. ova imports since 16 December 2019, to include discussions with the Norwegian Government, egg companies, salmon farming companies and other parties. This would also include any emails, letters, Cabinet Briefings, press updates and other information on ova imports in relation to salmon farming. It would also include any correspondence with EFTA/ESA, Mattilsynet (Norwegian Food Safety Authority), European Commission, AquaGen, Benchmark (Stofnfiskur), Landcatch (Hendrix Genetics), Mowi, Scottish Sea Farms and any other parties in relation to ova imports since 16 December 2019.
Information on any disease risks and biosecurity concerns of ova imports. This would include any discussions, emails, letters and other information relating to Infectious Salmon Anaemia (ISA) which would certainly include reference to Norwegian salmon farming.
Please consider this a formal request for information under the relevant FOI and Environmental Information regulations.
Please provide the information electronically.
Please provide a receipt for this FOI request.
Thanks,
Don Staniford
Director, Scottish Salmon Watch
From: <casehandling.service@gov.scot> Date: Fri, Aug 7, 2020 at 10:08 PM Subject: Your recent correspondence with Scottish Government and partner agencies - 202000058422 To: <salmonfarmingkills@gmail.com>
Please find attached a response to your correspondence.
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Tue, Aug 18, 2020 at 1:45 PM Subject: Review re FOI 202000058422 To: <directormarinescotland@gov.scot> Cc: <Neil.Purvis@gov.scot>
Please consider this a formal request for a review of FOI/202000058422.
Firstly, I do not see the FOI reply posted online?
Could you please double-check that the FOI reply is complete and all documents have been included?
Scottish Salmon Watch's FOI request dated 8 July 2020 included:
However, the Scottish Government's FOI reply failed to include any information relating to discussions with the Norwegian Government, EFTA/ESA or Mattilsynet (Norwegian Food Safety Authority).
Moreover, the Excel document disclosing data on ova imports included two shipments from AquaGen in Norway dated 8 April 2020:
"The company’s [AquaGen's] hatchery in Rimstad, Norway, was given the all-clear for export in April, and eggs stripped from broodstock held at a Nofima-operated land based unit can once again be transported there for incubation.... The [Scottish Government] spokesperson added that the Norwegian Food Safety Authority lifted its self-imposed suspension of health certification of live fish, ova and gametes from a number of ISA-free zones and compartments in March 2020."
An email from DEFRA dated 12 March 2020 did include some specifics on the Norwegian ban being lifted from 6 March 2020:
Surely there is more information than the information disclosed on 7 August by the Scottish Government?
For example, AquaGen's press statement - cited as a PDF in the FOI disclosure (Word) surely generated some internal discussion?
Scottish Salmon Watch asks you to review the FOI reply and double-check the completeness of the information disclosed.
On p13 of the FOI disclosure in Word it cites:
However, I cannot open this file. Could you please send by separate copy?
Finally, Scottish Salmon Watch takes issue with the exemption re. internal communications; namely:
Surely there is no "private space" via emails for publicly-elected Ministers and officials (paid for out of the public purse) to exchange free and frank advice? Surely the private space of dark corridors and smoky pubs is enough?
Scottish Salmon Watch is of the view that any discussions of drafts to media and other responses and exchanges via email should be disclosed via FOI as part of an open and transparent government. We therefore ask you to reconsider this exemption as part of this FOI review request.
Please provide a receipt for this FOI review request.
Scottish Salmon Watch filed the following FOI request to DEFRA (20 August 2020):
From: Don Staniford <salmonfarmingkills@gmail.com> Date: Thu, Aug 20, 2020 at 10:10 AM Subject: FOI re. imported salmon ova and testing for diseases, viruses and pathogens in hatcheries and farms To: Defra Information Rights Team <informationrequests@defra.gov.uk>, defra.helpline@defra.gov.uk
Please provide information on the import of salmon eggs (ova) since 1 May 2019.
Please include data on salmon ova imports.
Please include emails, letters and any other information relating to salmon ova imports.
Please also provide information on disease risks and the testing of imported salmon eggs (ova) for infectious diseases, pathogens and viruses such as Infectious Salmon Anaemia and Piscine Reovirus since 1 May 2019.
Please include correspondence with the Norwegian authorities (e.g. Mattilsynet), EFTA/ESA, EU, EC, the Scottish Government, AquaGen, Benchmark, salmon farming companies and other parties.
Please consider this a FOI request under the relevant FOI and Environmental Information regulations.
Please note a FOI reply from the Scottish Government disclosed on 7 August 2020 (FOI/202000058422) which included:
From: <REDACTED> <<REDACTED>@gov.scot> Sent: 07 February 2020 15:03 To: <REDACTED> <<REDACTED>@defra.gov.uk> Cc: <REDACTED> (MARLAB) <<REDACTED>@gov.scot> Subject: Temporary ova suspension update from Norwegian authorities.
Hi <REDACTED>
It was nice talking to you earlier – thank you for the update.
As we discussed, some industry members expressed concerns, over uncertainty with the subject in matter, as a result I thought it would best to ask DEFRA to seek an update from Norwegian authorities if possible. We would be grateful if you can seek clarity and provide further information on the ISA free compartment list and when the competent authority will resume issuing certificates for exports.
I guess the main question to ask is if they expect to put forward the ISA free list for consideration and open up trade in the meeting next week or in any of the following meetings e.g April meeting? Are they seeking approval from SCoPAFF that they have fully implemented corrective measures or is this just an update on their progress?
Also is the EFTA audit completed (still scheduled until April?).
Also grateful if you can let me know if there is any forward visibility regarding which compartments will be put forward.
Any help/assistance you can provide would be greatly appreciate.
Kind regards
<REDACTED>
<REDACTED> <REDACTED>
Marine Scotland – Aquaculture, Crown Estate, Recreational Fisheries, EMFF and Europe Tel: <REDACTED> E-mail:<REDACTED>@gov.scot Web: http://www.scotland.gov.uk/marinescotland Mail: Scottish Government, 1B North, Victoria Quay, Edinburgh EH6 6QQ
From: <REDACTED> <REDACTED>@defra.gov.uk> Sent: 25 February 2020 16:43 To: <REDACTED> <REDACTED>@gov.scot> Cc: <REDACTED> <REDACTED>@defra.gov.uk> Subject: Feedback from Norway - ova suspension
Hi <REDACTED>,
Sorry for the delay with this but we’ve now heard back from Norway regarding an update on the ova suspension.
They have informed us that they’ve been in a process of carrying out a comprehensive evaluation of all of their previously Declared ISA-free zones and compartments in order to rule out all possible misunderstandings and lack of fulfilment of the requirements set out in Commission Decision 1554/2015. This process is now in its final stage, and a conclusion will be reached within a few days.
Therefore, they’ve said that at the moment they’re not able to give more details on which compartments will be reintroduced on their list, but will provide more information as soon as the final decision is made.
I will let you know as and when we receive more information.
Best wishes,
<REDACTED>
<REDACTED>
<REDACTED>
Aquatic Animal Health | Animal & Plant Health
Department for Environment Food & Rural Affairs
Area 2B Nobel House | 17 Smith Square | London SW1P 3JR
Please find information below regarding the Norwegian self-imposed suspension of health certification of live aquaculture animals from certain ISA-free zones and compartments.
They have now confirmed that the Norwegian Food Safety Authority has decided to lift the suspension for the following compartments as from 6th March 2020:
Compartment 18000 - Rimstad, Company AquaGen
Compartment 12917 – Sjølseng – Hall 6, Veksthall 1 og 2, Company AquaGen
Compartment 12917 – Sjølseng - Hall 2, Company AquaGen
Consequently, live ova produced at those compartments will from now on be certified for export to UK.
Best wishes,
<REDACTED>
<REDACTED>
<REDACTED>
Aquatic Animal Health | Animal & Plant Health
Department for Environment Food & Rural Affairs
Area 2B Nobel House | 17 Smith Square | London SW1P 3JR
If you have any queries please do not hesitate to contact me on 07771 541826.
Thanks,
Don Staniford
Director, Scottish Salmon Watch
From: SM-Defra-Helpline, Defra (MCU)<defra.helpline@defra.gov.uk> Date: Thu, Aug 20, 2020 at 10:18 AM Subject: Automatic reply: FOI re. imported salmon ova and testing for diseases, viruses and pathogens in hatcheries and farms To: Don Staniford <salmonfarmingkills@gmail.com>
Thank you for your email to the Department for Environment, Food & Rural Affairs. We have a target of replying to emails within 20 working days where a response is required, and 20 working days where a case is handled under the Freedom of Information Act 2000 or the Environmental Information Regulations 2004.
Please be aware that we are receiving a high number of correspondence during the COVID-19 outbreak which may mean a delay in response times.
If you or someone you are contacting us on behalf of are currently at risk of serious harm or in a life threatening situation, please contact the emergency services:
999 for emergencies
101 non-emergency police line
111- NHS
If you suspect a notifiable animal disease or have animal welfare concerns, please report these to the Animal and Plant Health Agency (APHA) immediately. Failure to report a notifiable animal disease is an offence. APHA can be contacted using the following details:
We receive thousands of identical emails each month from organised campaigns. Ministers and officials are made aware of these campaigns, but unfortunately we cannot reply to each email individually.
Best wishes,
Ministerial Contact Unit
From: SM-Defra-Information Requests (DEFRA) <InformationRequests@defra.gov.uk> Date: Sat, Aug 22, 2020 at 12:23 PM Subject: Request acknowledgement: Imported Salmon Ova and Testing for Diseases in Hatcheries and Farms (FOI2020/21710) To: salmonfarmingkills@gmail.com <salmonfarmingkills@gmail.com> Cc: SM-Defra-Information Requests (DEFRA) <InformationRequests@defra.gov.uk>
Dear Don Staniford,
Following on from our acknowledgment below, your request has been forwarded to our executive agency the Animal and Plant Health Agency (APHA) to respond to you directly. Should you wish to contact them please email enquiries@apha.gov.uk
Kind regards
Information Rights Team
Department for Environment, Food and Rural Affairs
Address: Area 1E, Nobel House, 17 Smith Square, London SW1P 3JR
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Fri, Aug 28, 2020 at 7:50 PM Subject: FOI/Letter to Scottish Ministers To: <scottish.ministers@gov.scot>, <ceu@scotland.gsi.gov.uk>
Please find attached a letter to Scottish Ministers which includes a FOI request.
Unconfirmed rumours are that the salmon farming industry is looking to bring in Harry Maguire to work for them after he is sacked by Manchester United for repeated bodily harm & violence https://t.co/LuaE8wkTD7
This is my phone after I was assaulted and thrown to the ground. It was my Christmas present from my lovely wife, very sad, loved my phone, I was even using my old phone so as not to scratch my new one but ironically took my new one yesterday.. pic.twitter.com/ck3g5yiJuR
I want to thank everyone that has offered support and shown compassion for what we are going through and thanks to every single one of you we have hope. Hope in resolving this and hope that the world stops these greedy corporate polluters Thank you all from the bottom of my heart pic.twitter.com/b7PbvvcVt3
These are the Oxygen tanks going out today. This is used when treating with Formaldehyde. This means yet again the daily barrage is in full force. The fumes start at 8 am and linger on till at least 8pm. This is appalling. Anyone wants to come and witness this drop me a line pic.twitter.com/i83ceDFpng
This was todays barrage of Formaldehyde 6 drums in total. I cant put videos of what happened today as advised by the Police but i was attacked and assaulted by one of the employees I now fear for my life as I was told by the police that I was lucky because they all carry knives. pic.twitter.com/2dN13IR8F7
This is the face of Salmon farming in freshwater lochs in Argyll. Note that these fish were only brought to this loch on the 10th July 2020... 6 weeks and they are covered in fungus. Treatment.. FORMALDEHYDE. carcinogenic, poisonous, corrosive, toxic, disgracefull !!! pic.twitter.com/KjIerYiq28
Well today at Loch Tralaig Argyll, Kames Fish Farm resumed there treatment of there salmon with Formaldehyde, this chemical is a proven carcinogen as well as highly corrosive and toxic to the environment. Again I ask Sepa to stop granting licences to these farms !!! pic.twitter.com/HvdeoCoO6t
Fish Farming Expert reported (21 June 2020) that salmon farmers who cannot sell their unwanted fish can "apply to a new £1.25 million fund to cover the costs of maintaining unsold stock" in freezers.
The Scottish Government scheme, funded by the European Maritime and Fisheries Fund (EMFF), compensates businesses for the cost of transporting, freezing and storing salmon, trout and shellfish until the end of 2020. Storage is relatively cheap, at between £5-£10 per tonne for 10 weeks, but the initial blast freezing can cost up to £300 per tonne. "It is understood that cold storage capacity is available at facilities in the north east that primarily store whitefish, and at distribution depots at Larkhall and Bellshill in the Central Belt," reported Fish Farming Expert.
More details on the Scottish Government's 'Storage Aid' for salmon (announced on 18 June 2020) is available online here
Campaigners fear that a nicotine pesticide that the fish farming industry and the Scottish Government want to trial in Scotland could threaten marine wildlife.https://t.co/bw5IBgTwqi
If Mowi's salmon at their storm-battered farm in the Kilbrannan Sound were not gruesomely deformed before last week then it looks like tens of thousands of fish were battered to death when at least three cages were damaged by Storm Ellen! https://t.co/cA0WBP84Om#Mowi#Salmonpic.twitter.com/cdAqZNcF1d
Throughout the last few months Scotland's salmon farmers have worked incredibly hard to ensure people across the UK and beyond have access to fresh, healthy food. They deserve to be able to work free from harassment, fear and intimidation. pic.twitter.com/ZyfxQqP2KV
— Scottish Salmon Producers Organisation (@SSPOsays) August 19, 2020
Scottish Salmon Watch have asked for a review of the Scottish Government's refusal to disclose information on the West Coast Salmon Smolt Tracking project and other interactions between wild salmon and salmon farming.
A scientific review of the impacts of salmon farming on wild fish is available online here
The Atlantic Salmon Trust's toxic relationship with the 'Scottish' salmon farming industry (99% of which is controlled/owned by foreign money) will only cloud the issue. If we know anything from the history of salmon farming in Scotland, we know that the salmon farming lobby have a long history of trust and secrecy issues.
Cabinet Secretary for Environment, Climate Change and Land Reform
CabSecECCLR@gov.scot
Gillian Martin
Convenor, Environment, Climate Change and Land Reform Committee
ecclr.committee@parliament.scot
12 August 2020
Ref: Formaldehyde use in freshwater fish farms
Dear Roseanna & Gillian,
Alerted by local community groups as well as Freedom of Information investigations it was reported in the media that salmon farming companies have been discharging large quantities of Formaldehyde into freshwater lochs in the North and West of Scotland, in a largely uncontrolled and unrestricted manner. Given the chemical is classified as “cancer causing” as well as being toxic to ecosystems there is considerable, and understandable, concern about this activity on both public and environmental health grounds. As a leading campaigning organisation, critical of the environmental impacts of open cage salmon farming, we were approached by locals and community groups to seek support from the wider public in Scotland to call for a ban on the use of Formaldehyde in freshwater lochs by all fish farming companies until a public consultation on its safety and use can be held.
In a very short space of time 9,500 people have signed the following petition:
Signatures were limited to UK residents only, who had to supply a valid post code and email address. The petition circulated organically on social media. Understandably there is scepticism about the veracity of signatures and the true level of support concerning online petitions. For our part we considered this a local issue and sought support on that basis, as a small community led campaign. For reference, more information on who signed the petition and how they interacted with it is contained in Appendix 1 below.
Minister, we now respectfully call on you to ban the use of Formaldehyde in freshwater lochs by all fish farming companies until a public consultation on its safety and use can be held.
We do of course recognise that Formaldehyde has been used in terrestrial farming for many years and also that the chemical does breakdown relatively rapidly in water. However, the effects of its use in a freshwater ecosystem in the quantities reported are not well researched or understood and many people would expect a more precautionary approach to have been taken and far greater consultation, given the potential for widespread use in a number of lochs and river catchments throughout North and West Scotland.
Having reviewed existing literature it is not clear or well understood to what extent Formaldehyde on freshwater fish farms will directly impact wild fish, of any species, at the alevin, fry or parr stages or indeed aquatic invertebrates and other foundation organisms that are in proximity to freshwater fish farms. The extent to which its effects may cascade through an entire ecosystem, diminishing biodiversity, is therefore not well understood and the risks are unquantified.
In terms of the regulation of the use of Formaldehyde on freshwater fish farms it is not clear who the relevant authority is or if the substance is considered a medicine or a biocide for the purposes of regulation. There is no public register of use, nor a process for independently auditing the self-reported figures of fish farm operators contained in FOI disclosures. It is not clear under what circumstance operators are required to report use and whether this would capture all usage.
Clearly local communities are not routinely consulted on the introduction and usage of such chemicals. In locations where the public has a right to roam and no physical barrier exists between the use of a cancer causing chemical and the public, the lack of consultation seems inadequate. Wild swimmers for example, unaware of the issue, will no doubt freely interact with the chemical, potentially at high concentrations.
From a lack of proper regulation flows public uncertainty and mistrust. Without proper regulation of toxic chemicals, which should include independent and transparent monitoring and reporting, fish farming will never be able to allay the fears of the public about the use of this chemical in very large quantities in freshwater bodies, sometimes forming part of public water supplies.
This raises a wider question, the extent to which the Scottish Government has made any proactive efforts to better understand the environmental impact of fish farming on the freshwater environment since it was raised as a significant issue by the ECCLR committee in its detailed report on the Environmental Impacts of Salmon Farming (2018).
351. Scotland needs an ecosystems-based approach to planning the industry’s growth and development in both the marine and freshwater environment, identifying where salmon farming can take place and what the carrying capacity of that environment is. A cohesive framework is needed.
347. The Committee is deeply concerned that the development and growth of the
sector is taking place without a full understanding of the environmental impacts. The Committee considers an independent assessment of the environmental sustainability
of the predicted growth of the sector is necessary
In respect of Research, the committee held the view that,
328. There are knowledge gaps in:
• the environmental impacts on freshwater lochs
In respect of Additional Environmental Issues, the committee noted that,
331. The Atlantic Salmon Trust (AST) considers the report largely neglects impacts in freshwater ecosystems through salmon smolt production intended for coastal aquaculture. In particular they suggest cage farming of fin-fish, particularly in freshwater lochs, has the potential to generate significant amounts of organic waste which can result in alterations to the fish population structure.
Convenor, it is for this reason that we are also formally calling for a firm commitment that there will be ample opportunity for scrutiny by the ECCLR Committee, in both this and the next parliamentary session, of the Scottish Government’s progress in assessing and regulating salmon farming’s impacts on the freshwater environment.
We trust you will give these requests the consideration they deserve given the concern of local communities, and I look forward to conveying your response in due course.
Meanwhile, it seems that the use of Formaldehyde on Scottish salmon farms continues unabated:
Well today Kames Fish Farm "Treated" there fish at Loch Tralaig with Formaldehyde. The fish in these cages have now been "treated " with anti biotics, anesthetics and now as they did last year they have resumed there barrage of Formaldehyde... https://t.co/cTbZqU7BQJpic.twitter.com/f0mLAnPTfj
This is the face of Salmon farming in freshwater lochs in Argyll. Note that these fish were only brought to this loch on the 10th July 2020... 6 weeks and they are covered in fungus. Treatment.. FORMALDEHYDE. carcinogenic, poisonous, corrosive, toxic, disgracefull !!! pic.twitter.com/KjIerYiq28
Scottish Salmon Watch today (20 August 2020) filed Freedom of Information requests with the UK and Scottish Government on testing of imported salmon ova (eggs) for Infectious Salmon Anaemia as well as testing in hatcheries and farms.
In February 2020, Scottish Salmon Watch and The Ferret revealed that imports of salmon eggs (ova) from Norway were banned in May 2019 following fears of the spread of Infectious Salmon Anaemia.
Scottish Salmon Watch filed this FOI request with the Scottish Government (8 July 2020):
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Wed, Jul 8, 2020 at 9:40 AM Subject: FOI re. ova imports & ISA since 16 December 2019 To: <ceu@scotland.gsi.gov.uk>
Ova import data since the last imports detailed in the information disclosed via FOI-19-02663 (i.e. data since 16 December 2019).
Information in relation to discussions re. ova imports since 16 December 2019, to include discussions with the Norwegian Government, egg companies, salmon farming companies and other parties. This would also include any emails, letters, Cabinet Briefings, press updates and other information on ova imports in relation to salmon farming. It would also include any correspondence with EFTA/ESA, Mattilsynet (Norwegian Food Safety Authority), European Commission, AquaGen, Benchmark (Stofnfiskur), Landcatch (Hendrix Genetics), Mowi, Scottish Sea Farms and any other parties in relation to ova imports since 16 December 2019.
Information on any disease risks and biosecurity concerns of ova imports. This would include any discussions, emails, letters and other information relating to Infectious Salmon Anaemia (ISA) which would certainly include reference to Norwegian salmon farming.
Please consider this a formal request for information under the relevant FOI and Environmental Information regulations.
Please provide the information electronically.
Please provide a receipt for this FOI request.
Thanks,
Don Staniford
Director, Scottish Salmon Watch
From: <casehandling.service@gov.scot> Date: Fri, Aug 7, 2020 at 10:08 PM Subject: Your recent correspondence with Scottish Government and partner agencies - 202000058422 To: <salmonfarmingkills@gmail.com>
Please find attached a response to your correspondence.
From: Don Staniford<salmonfarmingkills@gmail.com> Date: Tue, Aug 18, 2020 at 1:45 PM Subject: Review re FOI 202000058422 To: <directormarinescotland@gov.scot> Cc: <Neil.Purvis@gov.scot>
Please consider this a formal request for a review of FOI/202000058422.
Firstly, I do not see the FOI reply posted online?
Could you please double-check that the FOI reply is complete and all documents have been included?
Scottish Salmon Watch's FOI request dated 8 July 2020 included:
However, the Scottish Government's FOI reply failed to include any information relating to discussions with the Norwegian Government, EFTA/ESA or Mattilsynet (Norwegian Food Safety Authority).
Moreover, the Excel document disclosing data on ova imports included two shipments from AquaGen in Norway dated 8 April 2020:
"The company’s [AquaGen's] hatchery in Rimstad, Norway, was given the all-clear for export in April, and eggs stripped from broodstock held at a Nofima-operated land based unit can once again be transported there for incubation.... The [Scottish Government] spokesperson added that the Norwegian Food Safety Authority lifted its self-imposed suspension of health certification of live fish, ova and gametes from a number of ISA-free zones and compartments in March 2020."
An email from DEFRA dated 12 March 2020 did include some specifics on the Norwegian ban being lifted from 6 March 2020:
Surely there is more information than the information disclosed on 7 August by the Scottish Government?
For example, AquaGen's press statement - cited as a PDF in the FOI disclosure (Word) surely generated some internal discussion?
Scottish Salmon Watch asks you to review the FOI reply and double-check the completeness of the information disclosed.
On p13 of the FOI disclosure in Word it cites:
However, I cannot open this file. Could you please send by separate copy?
Finally, Scottish Salmon Watch takes issue with the exemption re. internal communications; namely:
Surely there is no "private space" via emails for publicly-elected Ministers and officials (paid for out of the public purse) to exchange free and frank advice? Surely the private space of dark corridors and smoky pubs is enough?
Scottish Salmon Watch is of the view that any discussions of drafts to media and other responses and exchanges via email should be disclosed via FOI as part of an open and transparent government. We therefore ask you to reconsider this exemption as part of this FOI review request.
Please provide a receipt for this FOI review request.
Scottish Salmon Watch filed the following FOI request to DEFRA (20 August 2020):
From: Don Staniford <salmonfarmingkills@gmail.com> Date: Thu, Aug 20, 2020 at 10:10 AM Subject: FOI re. imported salmon ova and testing for diseases, viruses and pathogens in hatcheries and farms To: Defra Information Rights Team <informationrequests@defra.gov.uk>, defra.helpline@defra.gov.uk
Please provide information on the import of salmon eggs (ova) since 1 May 2019.
Please include data on salmon ova imports.
Please include emails, letters and any other information relating to salmon ova imports.
Please also provide information on disease risks and the testing of imported salmon eggs (ova) for infectious diseases, pathogens and viruses such as Infectious Salmon Anaemia and Piscine Reovirus since 1 May 2019.
Please include correspondence with the Norwegian authorities (e.g. Mattilsynet), EFTA/ESA, EU, EC, the Scottish Government, AquaGen, Benchmark, salmon farming companies and other parties.
Please consider this a FOI request under the relevant FOI and Environmental Information regulations.
Please note a FOI reply from the Scottish Government disclosed on 7 August 2020 (FOI/202000058422) which included:
From: <REDACTED> <<REDACTED>@gov.scot> Sent: 07 February 2020 15:03 To: <REDACTED> <<REDACTED>@defra.gov.uk> Cc: <REDACTED> (MARLAB) <<REDACTED>@gov.scot> Subject: Temporary ova suspension update from Norwegian authorities.
Hi <REDACTED>
It was nice talking to you earlier – thank you for the update.
As we discussed, some industry members expressed concerns, over uncertainty with the subject in matter, as a result I thought it would best to ask DEFRA to seek an update from Norwegian authorities if possible. We would be grateful if you can seek clarity and provide further information on the ISA free compartment list and when the competent authority will resume issuing certificates for exports.
I guess the main question to ask is if they expect to put forward the ISA free list for consideration and open up trade in the meeting next week or in any of the following meetings e.g April meeting? Are they seeking approval from SCoPAFF that they have fully implemented corrective measures or is this just an update on their progress?
Also is the EFTA audit completed (still scheduled until April?).
Also grateful if you can let me know if there is any forward visibility regarding which compartments will be put forward.
Any help/assistance you can provide would be greatly appreciate.
Kind regards
<REDACTED>
<REDACTED> <REDACTED>
Marine Scotland – Aquaculture, Crown Estate, Recreational Fisheries, EMFF and Europe Tel: <REDACTED> E-mail:<REDACTED>@gov.scot Web: http://www.scotland.gov.uk/marinescotland Mail: Scottish Government, 1B North, Victoria Quay, Edinburgh EH6 6QQ
From: <REDACTED> <REDACTED>@defra.gov.uk> Sent: 25 February 2020 16:43 To: <REDACTED> <REDACTED>@gov.scot> Cc: <REDACTED> <REDACTED>@defra.gov.uk> Subject: Feedback from Norway - ova suspension
Hi <REDACTED>,
Sorry for the delay with this but we’ve now heard back from Norway regarding an update on the ova suspension.
They have informed us that they’ve been in a process of carrying out a comprehensive evaluation of all of their previously Declared ISA-free zones and compartments in order to rule out all possible misunderstandings and lack of fulfilment of the requirements set out in Commission Decision 1554/2015. This process is now in its final stage, and a conclusion will be reached within a few days.
Therefore, they’ve said that at the moment they’re not able to give more details on which compartments will be reintroduced on their list, but will provide more information as soon as the final decision is made.
I will let you know as and when we receive more information.
Best wishes,
<REDACTED>
<REDACTED>
<REDACTED>
Aquatic Animal Health | Animal & Plant Health
Department for Environment Food & Rural Affairs
Area 2B Nobel House | 17 Smith Square | London SW1P 3JR
Please find information below regarding the Norwegian self-imposed suspension of health certification of live aquaculture animals from certain ISA-free zones and compartments.
They have now confirmed that the Norwegian Food Safety Authority has decided to lift the suspension for the following compartments as from 6th March 2020:
Compartment 18000 - Rimstad, Company AquaGen
Compartment 12917 – Sjølseng – Hall 6, Veksthall 1 og 2, Company AquaGen
Compartment 12917 – Sjølseng - Hall 2, Company AquaGen
Consequently, live ova produced at those compartments will from now on be certified for export to UK.
Best wishes,
<REDACTED>
<REDACTED>
<REDACTED>
Aquatic Animal Health | Animal & Plant Health
Department for Environment Food & Rural Affairs
Area 2B Nobel House | 17 Smith Square | London SW1P 3JR
If you have any queries please do not hesitate to contact me on 07771 541826.
Thanks,
Don Staniford
Director, Scottish Salmon Watch
From: SM-Defra-Helpline, Defra (MCU)<defra.helpline@defra.gov.uk> Date: Thu, Aug 20, 2020 at 10:18 AM Subject: Automatic reply: FOI re. imported salmon ova and testing for diseases, viruses and pathogens in hatcheries and farms To: Don Staniford <salmonfarmingkills@gmail.com>
Thank you for your email to the Department for Environment, Food & Rural Affairs. We have a target of replying to emails within 20 working days where a response is required, and 20 working days where a case is handled under the Freedom of Information Act 2000 or the Environmental Information Regulations 2004.
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We receive thousands of identical emails each month from organised campaigns. Ministers and officials are made aware of these campaigns, but unfortunately we cannot reply to each email individually.
When shopping on holiday with my family in Scotland last week (14 August 2020) I got more than I bargained for at a Coop supermarket near Fort William.
"Fuck off - go back home," said an abusive man as I stood at the checkout. "You're not welcome here," he continued as he lifted off his face mask just a few feet away at the coffee machine. The nasty man (believed to work for Norwegian-owned Mowi although he claimed on camera to work for the sawmill) proceeded to spit verbal venom and launched into abusive tirade laden with expletives for several minutes which shocked both myself and the Coop check-out worker. Sadly, I did not have my phone with me but I just had time to retrieve it from my car to capture him on camera leaving the Coop and getting into his car (making a note of the registration number).
Trucks with Mowi (formerly Marine Harvest) written on the side were parked outside the Coop as the abusive man drove off.
The next day I visited the Police station in Fort William to file a complaint for verbal abuse and intimidating behaviour. The PC on duty explained that it was a clear cut case of abuse and that charges could be pressed or a warning could be given to the abuser. The PC phoned this morning (18 August 2020) to say that Police Scotland had visited the abuser and warned him against committing a similar crime.
It would be ironic if the abusive man turned out to work for Norwegian-owned Mowi - a company which many people around the world want to go back home to Norway.
Scottish Salmon Watch recently spent a week on the trail of 'Scottish Scamon' - here's some videos from our travels on the West coast of Scotland.
Prisoner Cell Block Salmon - exclusive report from inside Scottish Sea Farms in the Sound of Mull (includes footage of skeletons left in the nets) https://t.co/hW80vMwGqC@scotseafarms@LeroySeafood
Safety is of paramount importance and it is therefore important to be safe on the water and venture out only if the weather conditions are suitable (on the West coast of Scotland it is often too windy to kayak out and you may need boat support!).
Salmon farms operate in public waters and the public have a right to navigate in a kayak as well as swim and dive.
But beware - Scottish salmon is a disease-ridden nightmare!
Due diligence and in-depth research is required before taking the plunge on Scottish salmon!
Night-filming is sometimes necessary to shine a light on the dark side of Scottish salmon farming:
Early mornings are a must when it comes to catching the scoop on Scottish salmon.
But you can also catch a whiff of Scottish salmon in the city.
And follow your nose to find damning evidence dumped in skips.
As salmon farmers pollute with impunity, the Scottish Environment Protection Agency (SEPA) is closed to the public.
And public beaches are closed to the public as salmon farmers continue to work without any regard for community access and resource use.
Watch this space for further filming over the Summer and Autumn at 'Scottish Scamon'.
Here's video footage of events in Loch Creran on 16 July 2020 captured by Scottish Salmon Watch (who today filed a formal complaint against Police Scotland for harassment and against Scottish Sea Farms for reckless behaviour and breach of safety):
Download Scottish Salmon Watch's complaint to Police Scotland in full online here
As a former cop, I would like to know what Act is 'criminal'? Watching the videos I see NO H&S issues, except the fish farm boat approaching the swimmer. What is this 'exclusion-zone' referred to? New one on me! Police failure to address two complaints or give advice interesting. https://t.co/Lxd8kLL3wo
I had thought @policescotland job was to uphold the law? Not make new laws on the hoof. The Chief Constable of @policescotland needs to investigate, why it appears to be acting as private security, when the sea is a public common. https://t.co/kQtFW3p1iF
Disgusting behavour from our police, they are perfectly happy to allow fish farm vehicles to drive around with toxic chemicals, diseased rotten fish and overloaded trailers and dump shit everywhere but threaten to prosecute for swimming !! https://t.co/eB2kAvbfyQ
A lot of nasty and toxic things are concealed under fish farms, not least that this industry is trying to steal our land. The seabed is held in trust for all and the public have the constitutional right to be on it for purposes including navigation and recreation./1 https://t.co/lm9p6V5Fqa
If Police Scotland is seriously interested in upholding the law then why are police officers not investigating the theft of a public beach and plastic pollution at Teithil Beach - just yards from where Scottish Salmon Watch was harassed?
Read a follow up letter to Police Scotland dated 6 August 2019 - online here
Scottish Sea Farms claimed in a letter dated 22 August 2019 that "a water-based protest poses a serious risk to our salmon stocks, potentially breaching biosecurity protocol and causing stress to the fish, both of which can have devastating consequences on animal welfare". Scottish Sea Farms invited Scottish Salmon Watch to "find less dangerous means of expressing your opinion" and referred to "several instances of people getting into unexpected difficulty, sometimes with fatal results".
I guess the truth about Scottish salmon hurts https://t.co/ZgrFAS7W1i If you did have time to show us around on 31 August we'd love to sample your "healthy" farmed salmon - what diseases, pathogens & viruses do you have currently? pic.twitter.com/lfviWoLjFW
If Police Scotland investigated Scottish Sea Farms instead of the public for daring to safely venture close to their salmon farms (which operate in public waters - and in the case of Loch Creran, a Special Area of Conservation supposedly protected by law) then they would uncover a disease-ridden welfare nightmare - as the BBC 'One Show' discovered when they filmed at Scottish Sea Farms in 2017.
When Scottish Salmon Watch visited the salmon farm operated by Scottish Sea Farms in Loch Spelve in August 2018 we were shocked at the levels of lice infestation - of both farmed salmon and cleaner fish. Watch video footage online here
"Drone footage clearly shows that Mowi endangered the health and safety of the general public during an inspection of a salmon farm in Loch Alsh 'Special Area of Conservation'," wrote Don Staniford, Director of Scottish Salmon Watch. "Mowi staff deliberately rammed a kayak, drove at high speed past a small dingy, unclipped a kayak tied safely to the farm, kicked a paddle into the water and scraped a work boot down my Achilles tendon. Mowi's behaviour on 2 November was both reckless and dangerous. Since Scottish Salmon Watch plans further unannounced site inspections and sampling near salmon farms it is a hoped that a protocol can be put in place urgently to properly police surveillance of this unhealthy and unsafe industry."
Here's photo stills grabbed from drone video footage taken ca. 8am on 2 November 2019 at Mowi's Ardintoul salmon farm in Loch Alsh (drone footage has been shared with the Health & Safety Executive and the Maritime & Coastguard Agency):
Here's the Mowi work boat recklessly speeding past a tiny dinghy safely navigating and filming in public waters:
Here's Mowi deliberately ramming into my safely tied kayak (luckily it was not badly battered and I was able to kayak back to shore):
When the Mowi work boat leaves the cage the engines cause unnecessary stress to the farmed salmon (unlike a kayak which operates quietly and without a motor):
Here's a Mowi worker scraping his work boot down my Achilles heel (not once but twice) as they surround and intimidate me (audio recordings of the interactions will hopefully be made available):
The same Mowi worker (he also called me a "cunt", "beady eyed" and mouthed "fuck you") is seen here untying my kayak which was safely clipped onto the cage and then throwing the safety rope into the water:
The Mowi worker is then filmed kicking my paddle into the water with the unclipped kayak now dangerous drifting away from the farm (at the same time another Mowi worker is ironically asking me to leave the site - even though my paddle and kayak are in danger of floating off into Loch Alsh):
When the Mowi worker fails to kick the paddle into the loch he moves to try for a second attempt (as a Mowi work boat emblazoned with the words "Safety First" docks alongside the cage). He appears to stop and looks up at the drone filming his every move:
The kayak floats along the cage as the Mowi worker seems to be beckoning the work boat to smash it against the farm:
