Farmed fish health: Scotland's Farmed Fish Health Framework group minutes - January 2022

Minutes from the meeting of the group on 31 January 2022.

Attendees and apologies

  • Sheila Voas, Chair, Scottish Government (SG)

  • Iain Berrill, Salmon Scotland
  • Oliver Robinson, Brittish Trout Assocaition (BTA)
  • John Webster, Brittish Trout Assocaition (BTA)
  • Jim Gallagher, Scottish Sea Farms (SSF)
  • Ronnie Soutar, Fish Vets
  • Heather Jones, Sustainable Aquaculture Innovation Centre (SAIC)
  • Michael Montague, Scottish Environment Protection Agency (SEPA)
  • Fraser Broadfoot, Veterinary Medicines Directorate (VMD)
  • Ken Stapleton, VMD
  • Lorna King, SG
  • Bill Turrell, SG
  • Rob Raynard, SG
  • Charles Allan, SG,  Fish Health Inspectorate (FHI)
  • Tasha Geddie, SG
  • Vickie Curtis, Secretariat, SG
  • Julien Lake, SG
  • Diarmuid O’Neil, SG


  • Alison Hutchins, Dawnfresh
  • Ben Hadfield, MOWI
  • Donald Carmichael, SG

Items and actions

Progress review

Progress since the refresh in December 2020 was reviewed to ensure delivery and impact going forward. While it was agreed that good progress had been made in some areas, other issues such as gill health were identified as requiring more focus. The structure of the group was discussed in terms of additional expertise participating at an operational level to facilitate delivery, and also to ensure that Marine Scotland (MS) and regulatory strategic direction takes account of fish health and welfare and provides oversight to the Farmed Fish Health Framework (FFHF). It was also suggested that the group focus on a smaller number of issues, in order to consolidate a strong evidence base and further progress.


  • the Chair to discuss strategic overview with chief executives of regulatory bodies before the next meeting on February 24
  • the Chair/MS to invite the Cabinet Secretary to meet with the steering group
  • the Chair/MS to respond to comments provided by the next meeting on the 24 Feb explore funding available for addressing gill health

Marine Scotland policy updates

Marine Scotland (MS) is providing support for the delivery of a number of Ministerial commitments and initiatives, including delivery of an independent review of aquaculture regulation which is due to be published imminently.  

Two additional strategic initiatives were presented to the group: the development of a SG Vision for Aquaculture; and the development of a Marine Scotland Science (MSS) Strategy. Both of these initiatives will involve engagement with external stakeholders, and members of the group were invited to feed back any views or suggestions. Formal work on the MSS vision would begin in April and members of the group would be contacted.


  • group members who are interested can contribute to the MSS strategy discussions


Salmon Scotland updated the group on its mortality by cause analysis. As of January 2022, they will provide a monthly mortality figure for the entire sector (as a %) and this will be further broken down according to the 10 causes of mortality previously agreed within FFHF. Data will be reported one month in arrears to allow for data collation and verification, therefore the first report will be published at the end February.

MS outlined the many uses of the SG’s finfish statistics across policy, marine planning, fulfilment of international commitments, ministerial briefing, external scientific research, and informing knowledge relating to food security.

SEPA is currently looking at its policies relating to water abstraction and have approached colleagues in Northern Ireland in order to share best practice.

There was a brief discussion on dissolved oxygen (DO), and it was reported that low DO has been detected in December which is unusual for this time of the year.


  • SEPA to continue dialogue with counterparts in Northern Ireland regarding water abstraction consents in response to specific weather / environmental parameters


An update was given on the UKTAG review of the use of emamectin. The report is now due sometime in Q1 of this year.

The VMD gave an update on EU Veterinary Medicinal Products Regulation (VMPR). A consultation will be held in 2022, but the date has not been confirmed. The VMD would like to hear about specific concerns / examples from the sector relating to what approaches have worked, and what hasn’t. Concern was raised about the impact of new regulation on the withdrawal period and the stipulation for 500 degree days. The possibility of considering an interim measure since the consultation may not take place for a while was raised.

The potential for using bacteriophages in treatments and how they fit into regulatory frameworks was discussed. VMD confirmed it was considering bacteriophage use and SEPA stated that their use could be accommodated by the regulation.


  •  VMD to emphasise need for progress on VMPR consultation within VMD and report to chair. VMD also to consider a meeting with fish vets and sector to fully explore the issue
  • Fish Vets, SEPA, VMD to discuss the use of bacteriophages in medicines sub group
  • SEPA to be provided with information sourced from Slice manufacturers that will allow it to conclude its consideration of the flexibility of Slice use

Climate change

Practical climate change projects which can be completed this financial year have been funded by MS and will be delivered by SAIC. These relate to monitoring of dissolved oxygen and monitoring/measurement of harmful algal blooms.


  • MS to circulate details of the newly funded projects to the group

Any other business 

Progress relating to the updating of the FFHF pages on the Marine Scotland website was raised, as was the possibility of a visit to a fish farm site for group members.

It was agreed that it would be beneficial to further discussions on medicines if Julie Fitzpatrick (Moredun Research Institute, Chief Scientific Adviser for Scotland) was to attend the next meeting of the steering group.


  • MS Aquaculture to update FFHF website page to reflect refreshed FFHF, once the forward look for the group is agreed
  • MS Aquaculture to arrange a visit to a fish farm site for FFHF steering group members
  • MS to invite Julie Fitzpatrick to the next meeting
  • MS to circulate brief SMRU analysis of data relating to seal avoidance of underwater turbines

Date of next meeting

24 February 2022

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