The Global Alliance Against Industrial Aquaculture, 9 January 2017

Policing Lice-Ridden Scottish Salmon
- New "Enforcement Regime" following £300 million losses
A new 'Enforcement Regime' policing lice-ridden Scottish salmon farms is to be introduced
from 1 April 2017 - despite "grumbles" from the salmon farming industry.
Read more via The Herald: "Imminent action on £300m sea lice problem" (9 January 2017)
Documents obtained via FOI from the Scottish Government reveal that sea lice damage is
costing Scottish salmon farming an estimated £300 million per year [1]. Whilst other
countries publish site specific sea lice data, Scotland is "out of kilter" concedes a briefing to
the Cabinet Secretary. "The aquaculture industry have strong concerns relating to
commercial confidentiality and operational sensitivities," stated another briefing. The salmon
farming industry "remain resistant to increased legislative controls citing lack of evidence of
impacts and significant commercial risks associated with offences or Enforcement Notices,"
admitted another briefing.
Download a summary of the FOI reply online here (and the 74-page PDF in full online here)
"The fact that even the salmon farming's biggest cheerleader, the Scottish Government, is
reading the riot act is symptomatic of the industry's escalating problems," said Don Staniford
of the Global Alliance Against Industrial Aquaculture (GAAIA). "The Scottish Government
admit that for the last decade the industry has been riddled with reduced efficacy of sea lice
treatments, amoebic gill disease and increased sea lice infestation. Instead of allowing the
industry to hide from public scrutiny, the Scottish Government should publish site specific
sea lice data as is already the case in Norway, Ireland and Canada. Salmon farms breaching
lice limits should be named and shamed and then closed down if non-compliance continues."
Documents obtained by GAAIA from the Scottish Government include:
"Industry are engaged in improving sea lice management but remain resistant to increased
legislative controls citing lack of evidence of impacts and significant commercial risks
associated with offences or Enforcement Notices," admitted a Scottish Government private
briefing paper to the Cabinet Secretary in August 2016 obtained by GAAIA via FOI.
A letter dated October 2016 from the Scottish Government's Marine Laboratory in Aberdeen
concedes that since 2007 the sector has been hit hard by "reduced efficacy of sea lice
treatments, the emergence of amoebic gill disease and increased challenges associated with
sea lice control, all contributing to increased sea lice numbers across the Scottish salmon
farming industry."
"Reaching the intervention limit requires the implementation of an explicit action plan,
agreed with the Fish Health Inspectorate, which will reduce and maintain the average number
of adult female sea lice per fish at the site below the reporting level of 3," stated the letter. "If
satisfactory measures cannot be demonstrated then enforcement action will be taken (a more
detailed explanation of this policy is attached)."

"In order for industry to implement the required procedures, the enforcement regime will take
effect from 1st April 2017," concluded the letter.
"The aquaculture industry have strong concerns relating to commercial confidentiality and
operational sensitivities," stated another Scottish Government briefing document in 2016. "If
site-level reporting of sea lice levels is made public, there would be increased focus on the
performance of individual sites and potential targeting of anti-fish farming lobby activities.
The information could be used in order to call for the removal of sites which report high sea
lice levels, putting pressure on local authorities and other regulators, and possible loss of
production in the short term."
Another briefing paper prepared for the Cabinet Secretary in July 2016 included the
admission that:
"Scotland is arguably out of kilter with the other major salmon producing countries in terms
of sea lice publication and the industry’s inability to manage sea lice infestation better makes
it challenging to hold this line."
For example, Norway (via Lusedata), Ireland (via the Marine Institute) and Canada (via
DFO) all publish site specific sea lice data online.

The briefing paper for the Cabinet Secretary also conceded that: "Full closed containment
salmon farming (on-land)....is not currently economically viable and even if it were the risk is
that production would be carried out closer to markets, rather than in the Highlands and
islands as now."
In other words, the Scottish Government is protective of the lice-ridden open net cage salmon
farming industry as currently practised since a move to closed containment nearer markets
would jeopardise what the Scottish Salmon Producers' Organisation describes as "Scotland’s
number one food export with a total value of £494m in 2014".
Last week (1 January 2017), GAAIA published damning data on chemical use on Scottish
salmon farms including the revelation that the use of the toxic chemicals Azamethiphos,
Cypermethrin, Deltamethrin, Emamectin benzoate and Teflubenzuron increased ten-fold over
the last decade.
Read more via:
Letter: "Sea lice 'nature fighting back'"
Press & Journal: "Scottish salmon farming ‘fighting a losing battle’ against sea lice"
The Times: "Toxic war on salmon lice soars 1,000%"
Press Release: Scottish Salmon's Lethal Legacy
The Sunday Times: "Salmon industry toxins soar by 1000 per cent"
A briefing paper to Paul Wheelhouse in July 2016 admitted that:
"Resistance to available sea lice treatments is increasing in all salmon producing nations."
"Management of sea lice on farms is the key challenge for the industry both in Scotland and
in other aquaculture producing nations such as Norway and Canada," stated the briefing
paper. "If not managed satisfactorily then sea lice will limit the future expansion of the
industry."
'Press lines' provided to the Scottish Government's communications team in August 2016
included:
"Scottish Government acknowledges that sea lice management presents the key challenge for
the aquaculture industry. Over the last year The Scottish Government has worked
cooperatively with the aquaculture industry to agree a new sea lice management policy,
including a redefining of “satisfactory measures” for the prevention, reduction and control of
sea lice on farms as required by the Aquaculture and Fisheries (Scotland) Act 2007. This
includes agreed reporting levels and increased monitoring and intervention. It also includes a
backstop limit at which point enforcement action will be taken. We believe that this new
policy will result in improvements to the management of sea lice by the aquaculture industry
in Scotland."
A briefing to the Cabinet Secretary in November 2017 included:
"We are aware of a large number of mortality events resulting from a combination of both sea
lice and on-going gill health issues across parts of Scotland. These have been widely

reported by the media recently. Loss of production, in combination with accelerated harvest,
has unexpectedly and significantly decreased the stocked biomass in some reporting areas."
"Media interest has been quiet following recent publications of the fish health management
reports, however there have been several media articles relating to aquaculture mortality
including in relation to the use of a Thermolicer sea lice treatment. We stand ready to respond
and Comms have been made aware and provided with appropriate press lines."
Read more via:
Daily Telegraph: "Poached alive - fish die as farm overheats water"
‘Unprecedented’ mortality rates impact salmon farmer
Thermoliced dead salmon make waves in the media!
Fish farm firm kills 175000 salmon by accident
Press Release: 'Thermolicer' Back-Fires Killing 95,400 Farmed Salmon
Alert over salmon deaths crisis on Scots fish farms caused by infectious disease
The briefing to the Cabinet Secretary also conceded:
"The new policy....includes a requirement to report sea lice levels above 3.0 average female
adult lice per fish to Marine Scotland’s Fish Health Inspectorate. This will initiate a site
specific action plan and will require satisfactory control measures to be implemented. As an
indication, at a minimum, sites in at least 8 of the reporting areas were over this level
at some point in this reported quarter."
Note that Salmon & Trout Conservation Scotland reported in December 2016:
"Over the year to September 2016, regions representing 66.4% have been over three adult
female lice per fish for at least one month, the level at which the Scottish Government
now requires individual farms to produce a “site specific escalation action plan”.
Over the year to September 2016, regions representing 18.2% have been over 8 adult
female lice per fish for at least one month, the level at which the Scottish Government
announced in May 2016 would result in enforcement action, including the potential to
require reduction in biomass.
To date, S&TCS understands that there has been no such enforcement action."
Salmon & Trout Conservation Scotland reported in June 2016:
“When it comes to the most serious threat to wild salmonids, sea lice produced by the billion
on salmon farms, Scotland essentially relies on what are little more than gentleman’s
agreements and unenforceable codes of good practice with the industry which have no status
in law. In contrast, the Faroese have almost zero tolerance of any build-up of sea lice and the
Norwegians accept no more than 0.5 lice per farmed fish. Yet the Scottish regime now allows
up to an astonishing eight lice per farmed fish before any serious remedial action must be
considered.”

A briefing paper - "Sea Lice Management and Impacts on Wild Salmonids" - authored by
Marine Scotland for the Cabinet Secretary included the questionable claim that:
"No evidence yet exists on the scale of any impacts of lice on wild populations of salmon or
sea trout for Scotland."
The Scottish Government's denial of salmon farming's impacts is despite over two decades of
scientific research linking sea lice infestation on salmon farms with declines of wild fish [2].
Contact:
Don Staniford: 07771 541826 (dstaniford@gaaia.org)
Notes to Editors:
[1] A submission to the Cabinet Secretary by Marine Scotland in August 2016 included:
"Recent analysis suggests that parasites account for an annual loss of up to 16.5% of the
value of UK aquaculture production. The vast majority of this relates to the treatment of sea
lice."
Since Scottish aquaculture production is valued at £1.8 billion (read Scotland Food & Drink's
2016 publication "Aquaculture Growth to 2030" online here) then annual losses due to sea
lice could be nearly £300 million.
Read a summary of the FOI reply by GAAIA (January 2017) online here
Read the FOI reply from the Scottish Government (23 December 2016) in full online here
(74-page PDF)
[2] Over the last few decades there has been an increasing weight of scientific evidence
pointing to significant impacts of sea lice infestations from salmon farms on wild fish -

including (see scientific papers listed below). A Scottish Government paper - "Summary of
Science: summary of information relating to impacts of salmon lice from fish farms on wild
Scottish sea trout and salmon" - includes:

Read more via the Scottish Government's: "The interactions and effects of sea lice on wild
salmon".
The Weight of Scientific Evidence: Sea Lice & Salmon Farms
Finstad, B. (2016). Advances in understanding the impacts of sea lice on wild Atlantic
salmon. NASCO, CNL (16) 46.
Shepherd, S. et al (2016). Aquaculture and environmental drivers of salmon lice infestation
and body condition in sea trout. Aquaculture & Environment Interactions 8, 597-610.
Murray, A. (2016). Increased frequency and changed methods in the treatment of sea lice
(Lepeophtheirus salmonis) in Scottish salmon farms 2005–2011. Pest Management Science
72 (2), 322-326.
Vollset, K. W. et al (2015). Impacts of parasites on marine survival of Atlantic salmon: a
meta-analysis. Fish and Fisheries 17(3), 714-730.
Murray, A. & Hall, M. (2014). Treatment rates for sea lice of Scottish inshore marine salmon
farms depend on local (sea loch) farmed salmon biomass and oceanography. Aquaculture
Environment Interactions 5 (2), 117-125.

Middlemas, S.J. et al (2013). Relationship between sea lice levels on sea trout and fish farm
activity in western Scotland. Fisheries Management and Ecology Volume 20, Issue 1, 68–74.
Torrissen, O. et al (2013). Salmon lice – impact on wild salmonids and salmon aquaculture.
Journal of Fish Diseases 36 (3), 171-194.
Peacock, S. et al (2013). Cessation of a salmon decline with control of parasites. Ecological
Applications 23 (3), 606-620.
Skilbrei, O.T. et al (2013). Impact of early salmon louse, Lepeophtheirus salmonis,
infestation and differences in survival and marine growth of sea-ranched Atlantic salmon,
Salmo salar L., smolts 1997–2009. Journal of Fish Diseases 36 (3), 249-260.
Krkosek, M et al (2012). Impact of parasites on salmon recruitment in the Northeast Atlantic
Ocean. Proceedings of the Royal Society B.
Gargan, P. et al (2012). Evidence for sea lice-induced marine mortality of Atlantic salmon
(Salmo salar) in western Ireland from experimental releases of ranched smolts treated with
emamectin benzoate. Can. J. Fish. Aquat. Sci. 69, 343–353.
Middlemas, S.J. et al (2010). Temporal and spatial patterns of sea lice levels on sea trout in
western Scotland in relation to fish farm production cycles. Biology Letters 6.
Penston, M.J. & Davies, I.M. (2009). An assessment of salmon farms and wild salmonids as
sources of Lepeophtheirus salmonis (Krøyer) copepodids in the water column in Loch
Torridon, Scotland. Journal of Fish Diseases 32 (1), 75-88.
Penston, M.J. et el (2008). Spatial and temporal distribution of Lepeophtheirus salmonis
(Krøyer) larvae in a sea loch containing Atlantic salmon, Salmo salar L., farms on the northwest coast of Scotland. Journal of Fish Diseases 31 (5), 361-371.
Ford, J.S. & Myers, R.A. (2008). A Global Assessment of Salmon Aquaculture Impacts on
Wild Salmonids. PLOS Biology.
Frazer, L.N. (2008). Sea-cage aquaculture, sea lice and declines of wild fish. Conservation
Biology 23: 559-607.
Holst, J.C. (2007). Mortality of Seaward-Migrating Post-smolts of Atlantic Salmon Due to
Salmon Lice Infection in Western Norwegian Salmon Stocks. In book: Salmon at the Edge by
D. Mills. Blackwell Scientific Publications, Oxford, UK. pp.136 - 137.
Krkošek M, Ford JS, Morton A, Lele S, Myers RA, et al. (2007). Declining wild salmon
populations in relation to parasites from farm salmon. Science 318: 1772–1775.
Gillibrand, P.A. & Willis, J.W. (2007). Dispersal of sea lice larvae from salmon farms: a
model study of the influence of environmental conditions and larval behaviour. Aquatic
Biology. 1, 63–75.

Cunningham, C. (2006). A review of research and field data on relative louse infection levels
of wild salmon smolts and sea trout and the proximity of fish farms to river estuaries.
Fisheries Research Services Internal Report No 12/06.
Butler, J.R.A. & Walker, A.F. (2006). Characteristics of the sea trout Salmo trutta (L.) stock
collapse in the River Ewe (Wester Ross, Scotland), in 1988-2001. In: Sea Trout Biology
Conservation & Management. (Graeme Harris & Nigel Milner, Eds). Proceedings of the 1st
International Sea Trout Symposium, July 2005, Cardiff, Wales, 45-59.
McVicar, A. H. (2004). Management actions in relation to the controversy about salmon lice
infestations in fish farms as a hazard to wild salmonid populations. Aquaculture Research
35(8): 751-758.
McKibben, M. & Hay, D. (2004). Distributions of planktonic sea lice larvae Lepeophtheirus
salmonis in the inter-tidal zone in Loch Torridon, Western Scotland in relation to salmon farm
production cycles. Aquaculture Research 35 (8), 742-750.
Penston, M.J. et al (2004). Observations on open-water densities of sea lice larvae in Loch
Shieldaig, Western Scotland. Aquaculture 35 (8), 793-805.
Butler JRA, Watt J (2003). Assessing and managing the impacts of marine salmon farms on
wild Atlantic salmon in western Scotland: identifying priority rivers for conservation. In:
Mills D, editor. Salmon at the edge. Oxford: Blackwell Science. pp. 93–118.
Gargan, P.G. et al (2003). The relationship between sea lice infestation, sea lice production
and sea trout survival in Ireland, 1992–2001. In Salmon at the Edge. Edited by D. Mills.
Blackwell Scientific Publications, Oxford, UK. pp. 119–135.
Holst, J.C. et al (2003). Mortality of seaward-migrating post-smolts of Atlantic salmon due to
salmon lice infection in Norwegian salmon stocks. In Salmon at the Edge. Edited by D. Mills.
Blackwell Scientific Publications, Oxford, UK. pp. 136–137.
Butler, J.R.A. (2002). Wild salmonids and sea louse infestations on the west coast of
Scotland: sources of infection and implications for the management of marine salmon farms.
Pest Management Science, 595-608.
Edwards, R. (1998). Infested waters. New Scientist 2141, 4 July.
Birkeland, K. & Jacobsen, P.J. (1997). Salmon lice, Lepeophtheirus salmonis, infestation as a
causal agent of premature return to rivers and estuaries by sea trout, Salmo trutta, juveniles.
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