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