Salmon Farming in Scotland

OneKind Parliamentary Briefing

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Wednesday 6 February 2019

Motion S5M-15677

That the Parliament notes the conclusions in the Rural Economy and Connectivity Committee’s 9th Report, 2018 (Session 5), Report on Salmon Farming in Scotland (SP Paper 432).

Introduction

OneKind animal protection charity welcomes the report Salmon Farming in Scotland by the Rural Economy and Connectivity Committee (REC) and also the earlier report by the Environment, Climate Change and Land Reform Committee (ECCLR). While fish welfare was not integral to the remit of either inquiry, we are grateful to both Committees for considering our representations, and those of others, on this important issue.

It is widely acknowledged that fish are sentient animals, capable of feeling pain. However, given the scale of the industry, it is easy to forget that each salmon farmed in Scotland is a unique individual, capable of suffering.

Consumers of Scottish salmon are led to believe that they are buying products from healthy, happy and sustainable fish, and as consumer awareness grows, poor welfare can lead to direct economic losses. Protecting the welfare of fish and preventing suffering is not only a moral imperative, it is also critical to the viability of the industry itself which currently seems intent on expanding and intensifying production.

OneKind recommends a moratorium on industry growth that applies to the development of new farms and the expansion of current ones. This moratorium should be kept under review, to be lifted once the industry demonstrably passes three tests:

1. The farmed salmon and any cleaner fish have good lives that are worth living.

2. The industry does not cause suffering to wild animals native to Scottish waters, including seals, cetaceans and wild salmon and trout.

3. The environmental impact of salmon farms is reduced and can be shown to do no harm.

OneKind animal welfare reports

The animal welfare issues connected with salmon farming are discussed in detail in three OneKind reports:

· Fish welfare on Scottish salmon farms describes animal welfare issues including mass mortalities, sea lice infestations, disease and escapes.

· The welfare status of salmon farms and companies in Scotland highlights the worst and best salmon farms for animal welfare in Scotland in 2017. This includes the welfare of other animals such as seals, who can be shot when around salmon cages.

· Cleaner fish welfare on Scotland’s salmon farms evidences numerous animal welfare problems which can affect cleaner fish that are used to clean salmon of sea lice infestations. These include high mortality rates, escapes, the need to provide supplementary food and shelter, health problems and issues relating to cleaner fish being farmed.

Mortalities during the production cycle

Fish welfare on Scottish salmon farms details the high mortality rates in the industry, with 10 million salmon dying on seawater sites in 2016. This is estimated to have increased to 11 million in 2017.  Escapes are also common with 300,000 fish escaping from salmon farms in 2017: farmed fish are not adapted to living in the wild and are likely to suffer as a consequence.

The fish welfare report also reveals the extent of disease on salmon farms. For example, over 100,000 salmon died of Amoebic Gill Disease over a period of 10 weeks in 2016; 68,265 died from Cardiomyopathy

syndrome (which affects the heart muscle of fish) in 2016; and an estimated 27,000 salmon died from Infectious Salmon Anaemia on one site alone in 2018.

According to the most recent Scottish Government Scottish Fish Farm Production Survey 2017, 45.5 million young salmon (smolts) were put into seawater farms in 2015, and of these, 20.9% (9.5 million) died during the two-year production cycle. Mortality rates of smolts put to sea in 2015 were lowest in Orkney and highest in the Western Isles where, of the 13 million salmon put to sea, 4 million (30.3%) died during the production cycle. Overall there was a small reduction in mortalities over the previous year, but more recent figures published by the Scottish Salmon Producers Organisation (SSPO) indicated a slight increase in the early part of 2018.

Either way, these are enormous mortality rates, indicative of animal suffering, and should not be tolerated. With recorded mortality levels of over 20% during the production cycle, the Committee report recognises the severity of this problem: “the current level of mortalities to be too high in general across the sector and it is very concerned to note the extremely high mortality rates at particular sites”.

The Committee also noted that the mortality data now published by the Scottish Salmon Producers Organisation (SSPO), three months in arrears “is very limited and does not provide detailed information on the causes of mortality on each farm”.

The Committee took the view that no expansion should be permitted at sites which report high or significantly increased levels of mortalities, until these are addressed to the satisfaction of the appropriate regulatory bodies.

In its recent response the Scottish Government defends the efforts of the sector to reduce mortalities over the last 12 months but acknowledges that progress is variable. The response states that mortality occurs in all forms of animal farming and goes on to suggest that emerging disease and environmental factors are difficult to control and therefore “[i]t is not clear how the committee’s recommendations would assist in such circumstances.”

OneKind is disappointed that premature animal mortality appears to be accepted as a normal part of fish farming, despite its obvious negative impacts on fish health and welfare. We would still recommend the Committee supports a moratorium on fish farm expansion until fish health and welfare and environmental challenges are resolved (see below). However, we believe that for now, at least, the recommendation to halt expansion at poorly-performing sites should be supported.

Sea lice

Sea lice infestations continue to be a major animal welfare problem. For example, in 2017 over 70 farms breached Scottish Government trigger levels of an average 3 adult female lice per salmon. Treatments for sea lice and diseases have been known to do further damage exposing salmon to harsh chemicals or mechanical treatments that can cause stress, physical injury and death.

The RECC report notes that sea lice cause a “significant challenge”, but despite this “the industry has not yet identified a means to fully and effectively deal with this parasite”.

The SSPO has recently started publishing sea lice data, again, three months in arrears (unlike Norway, where information is published weekly on an interactive website). The Committee has called for the provision of sea lice data to become mandatory, and for the development of a robust compliance policy, to include appropriate penalties for non-compliance.

Case history – sea lice

Shocking evidence of the suffering caused by sea lice was made public in August 2018, in video footage filmed at a salmon farm at Vacasay in Loch Roag on the Isle of Lewis. The footage showed hundreds of sea lice feeding on salmon with open wounds and damaged tails and fins. The farm is owned and operated by the Scottish Salmon Company. Following investigations by the Fish Health Inspectorate, the Animal Plant and Health Agency and the Scottish SPCA, the company was issued with an advisory letter from Marine Scotland, requiring it to undertake a review of measures in place to prevent, control and reduce parasites. Given the animal suffering and environmental impact caused by such high sea lice levels, many observers considered this response wholly inadequate.

Use of cleaner fish

Salmon farms also use cleaner fish – wrasse and lumpsucker – as an alternative “treatment” to pick off and eat the sea lice, however these fish suffer the same welfare issues as farmed fish. The OneKind report Cleaner fish welfare on Scotland’s salmon farms evidences numerous animal welfare problems which can affect cleaner fish including high mortality rates, escapes, the need to provide supplementary food and shelter, and health problems. OneKind acknowledges the environmental concerns surrounding cleaner fish (especially wild-caught wrasse) but the welfare issues must not be overlooked.

Whilst the RECC report does not include recommendations relating to the welfare of cleaner fish, it does state: “There is an urgent need for an assessment of future demand as well as all associated environmental implications of the farming, fishing and use of cleaner fish”

The Scottish Government response to the Committee’s recommendations on sea lice states that overall sea lice numbers for 2018 were the lowest since reporting began, reflecting major efforts to tackle sea lice through preventative husbandry and “sustainable use of ‘cleaner fish’ “. The response refers to successful captive breeding of Ballan wrasse at Machrihanish and continues: “It is now expected that Scottish Sea Farms and Mowi will be able to produce all their requirements for wrasse cleaner fish in the next few years.”

Regrettably, there is no reference to resolving the welfare problems of cleaner fish, and without this we would question whether such developments can be genuinely described as sustainable.

Impact of salmon farming on marine mammals

OneKind has long called for the use of physical barriers such as anti-predator nets to prevent seals being killed at fish farms. While seal shooting has reportedly decreased following the introduction of licensing under the Marine (Scotland) Act 2010, the latest seal licensing returns to Marine Scotland show that a total of 73 seals (54 grey and 19 common) were shot by salmon farmers between February 2017 and January 2018. There remain serious animal welfare concerns about the shooting of pregnant and lactating females, wounding and illegal unreported killing.

There is also overwhelming evidence that the use of Acoustic Deterrent Devices (ADDs), which emit loud noises in an attempt to deter seals from salmon farms, has harmful impacts on cetaceans – notably harbour porpoise – while at the same time there is a lack of evidence of their long-term effectiveness in deterring seals from salmon farms.

OneKind therefore welcomes the Committee’s recommendation:

“The Committee shares the view of the ECCLR Committee that […] physical barriers should be used ahead of deterrents such as Acoustic Deterrent Devices which potentially have a harmful impact on cetacean species such as whales and dolphins”.

Given the evidence that ADDs can also cause distress and potentially physical injury and hearing damage to protected whales, dolphins and porpoises – which are dependent on sound for navigation and are much more sensitive than seals to underwater noise – OneKind believes that these currently unregulated devices should be subject to strict legal controls, and ultimately banned.

Closed containment systems

While sometimes recommended as a solution to environmental problems with sea cages, OneKind is opposed to the movement of salmon rearing into closed containment systems on land. Being more expensive, it is likely that stocking densities would be higher leading to problems with water quality and increased aggression between fish. The animal welfare implications of closed containment systems need to be considered in detail.

Suggested moratorium on industry expansion

Given that the aquaculture industry plans to expand to produce 210,000 tonnes of finfish by 2020, and 350,000 tonnes (over 65 million individual salmon) by 2030, OneKind believes that industry expansion should be restricted until key serious animal welfare issues are addressed. Doubling production will exacerbate the current welfare problems on salmon farms and result in many more fish suffering. In addition, we note the compelling evidence that salmon farms place a large and unsustainable burden on the natural environment (Environment, Climate Change and Land Reform Committee, 2018).

OneKind regrets that (with the exception of John Finnie and Colin Smyth) the Committee was not persuaded by the evidence from environmental and welfare interests about the need for a moratorium on expansion, although it recommended that expansion should not be permitted at farms with high mortality rates. The Scottish Government’s response appears to resist this recommendation. The RECC also said it was “of the view that urgent and meaningful action needs to be taken to address regulatory deficiencies as well as fish health and environmental issues before the industry can expand” and OneKind hopes Members will support this view while continuing to consider the need for a wider moratorium on expansion.

OneKind, 50 Montrose Terrace, Edinburgh www.onekind.scot policy@onekind.org