Farmed fish health: Scotland’s Farmed Fish Health Framework group minutes - October 2021

Minutes from the meeting of the group on 6 October 2021.

Attendees and apologies

  • Sheila Voas (SG, Chair)
  • Iain Berrill SSPO)
  • Oliver Robinson (BTA)
  • Ben Hadfield (MOWI)
  • Jim Gallagher (SSF)
  • Alison Hutchins (Dawnfresh)
  • Ronnie Soutar (Fish Vets)
  • Heather Jones (SAIC)
  • Michael Montague (SEPA)
  • Ken Stapleton (VMD)
  • Lorna King (MS)
  • Bill Turrell (MS)
  • Rob Raynard (MS)
  • Sonia Duguid (MS)
  • Vickie Curtis (MS)
  • Tasha Geddie (MS, secretariat)


  • representative from MS Conservation Team
  • John Webster (BTA)
  • Charles Allan (MS FHI)

Items and actions


Mortality analysis by cause. Work is ongoing on the presentation of the causes of mortality analysis work being undertaken by the SSPO. Data will be presented as monthly aggregated figures for seawater salmon expressed as a percentage of the number of fish under the 10 categories previously agreed by the FFHF steering group. Final presentation will include a narrative explaining methodology and presentation.


  • SSPO to provide an update on progress made towards publication of analysis by cause data following its December Board meeting (action 1)

Dissolved oxygen. Lower dissolved oxygen as a result of increased water temperature contributed to summer mortality in some areas. Impacts were greater when lower levels of dissolved oxygen coincided with algal blooms or other events which further reduce oxygen saturation, or when gill disease which hampers oxygen uptake. There is a need to better understand lower levels of dissolved oxygen outwith farms in the wider environment and better understand the movement of oxygen depleted water. 

Possible mitigation to take in response to decreased dissolved oxygen could include reducing biomass within pens when required; improved ability to net clean; abstraction of fresh water (at the point where it joins sea water) for storage and use in net pens. Flexibility to trigger implementation of mitigation measures when specific environmental conditions were met (e.g. high water temperatures for a given period/high sunlight for a given period/when certain dissolved oxygen levels are reached) could significantly improve fish health and welfare.

It was noted that availability of oxygen supplies to the farmed fish sector had decreased due to requirements for COVID-19 treatment, and that limited available stocks had not been prioritised for farmed fish welfare as opposed to other non-animal purposes in some areas.


  • all steering group members to determine what dissolved oxygen data is being collected and report at next meeting (action 2)
  • MOWI to provide information/give presentation on fresh water abstraction and storage as mitigation by farms in Ireland at next meeting (action 3)
  • SEPA with MOWI and Fish Vets to consider flexibility in water abstraction consents in response to specific weather/environmental parameters (action 4)
  • Chair to raise problem with supply of oxygen to aquaculture sites with SGoR, seeking prioritisation of supplies to aquaculture for fish welfare purposes (action 5)

Post meeting note from S Voas: CVO (Scotland) has had discussions with suppliers of oxygen who have agreed to prioritise supplies for animal welfare purposes ahead of other areas except human health. A further meeting is arranged to confirm that this mitigation is working. 

Mortality reporting within official statistics. There was discussion on different presentations of mortality related data by different organisations including SSPO, SEPA and Marine Scotland. Although different data is published for different purposes and using different methodologies, readers could be confused as to why mortality figures apparently vary between organisations and the use of different metrics was questioned.


  • Marine Scotland to consider the presentation of ‘survival to harvest’ data in the Marine Scotland production survey and the opportunity for alignment with information presented elsewhere (action 5a)


The treatments ‘subgroup’ was seeking to provide data to inform SEPA’s consideration of increasing dose limits of SLICE within its regulatory framework provided it can be achieved within environmental standards. 

Supporting innovation which can negate environmental impacts of new treatments and thereby promote their availability will be important going forward, especially with regards to regulation of discharge. Accessing treatments used elsewhere in the world but not marketed here would be useful in future.

Discussion on development of vaccines and problems associated with patents concluded that source development was needed. Opportunities to work with academic institutes to promote vaccine development and cross working with SEPA/VMD/MS regarding regulations was thought to be a possible way forward (to be further explored at the next steering group meeting)


  • BH and MM to consider medicine discharge levels/medicine residue treatments in relation to changes to slice/SPCs and discharge, to inform future well boat requirement planning (action 6)
  • Aquaculture Policy (LK) to seek update from UKTAG on emamectin (action 7)
  • SSPO (IB) to discuss funding for consultancy work to identify anti-inflammatory medicines available with Marine Scotland (LK) (action 8)
  • VMD and Fish Vets to discuss use of medicines under cascade and access to global products (action 9)
  • LK to contact Julie Fitzpatrick (Chief Scientific Adviser for Scotland Scientific and Director of Moredun) and invite to the steering group (action 10)

Post meeting note from UKTAG vis SSPO: The Emamectin Review final draft is ready for peer review however there have been some delays setting up the peer review. We are hoping this process can complete before the end of November. 

Climate change

SAIC reported on the first workshop (22 July) agreed by the steering group workshop. It had been well attended by producers, had been cooperative and had identified data availability, sampling techniques, training, data sharing, and a range of actions which could contribute to standardised standard operating procedures had been collected. 

The second workshop was intended to focus on standardising protocols across Scotland and provide training to promote enhanced data collection and analysis of climate change related environmental data in future. This would also help with farm to farm dialogue. Funding would be required from MS. The group considered alternatives for funding.

Discussion on next steps included consideration of whether a complied environmental data set could be analysed in such as a way as to complement the SAIC HAB project; whether analysis of environmental factors alongside the biological data generated by the SAIC gill health project could provide insight as to triggers/thresholds and impacts; more practical projects such as identifying anti-inflammatory treatments to help manage the impacts of climate change events; changes in feed to include natural anti-inflammatories. 


  • all members to consider practical climate change projects which can be delivered this financial year to be considered/agreed at the next meeting (action 11)
  • MOWI (BH) and Scottish Sea Farms (JG) with input from RS and MM to engage with VMD (KS) on treatment solutions for current endemic issue with AGD (action 12)


MS had commissioned SAIC to facilitate a cross interest workshop to identify projects to develop non-lethal control options for seal management. The workshop had been successful and 21 projects had been identified but further work was needed to distil them. Next steps would be for MS/ the SPPO, BTA and SAIC to identify priorities and consider how best to take forward. Members of the steering group considered that the priority focus should be on excluding seals from pens.


  • all steering group members to provide comments to Marine Scotland on the projects recommended by SAIC workshop on non-lethal control of seals (action 13)
  • MS to consider the specific request from the sector to implement a grace period in line with the requirement for implementation being delayed until January 2023 and allow the sector some ability to intervene at farms where seals continue to be a contributing factor to mortality (action 14)

Post meeting note from Marine Conservation - The aim of the amendment to the Marine (Scotland) Act 2010 was to increase the protection for seals from being killed, injured or taken. It also ensures continued access to the important US market for farmed Scottish Salmon. When the US authorities provided additional time to demonstrate comparability (from 01 March to 30 November 2021) Scottish Ministers were given advice on the potential to delay the coming into force of the amendment. After carefully considering this advice Ministers chose to proceed with the planned coming into force date of 01 February 2021.


  • MS to comment on seal population dynamics and population control for conservation purposes (action 15)

Post meeting note from Marine Conservation - under the Conservation of Seals Act 1970 and the Marine (Scotland) Act 2010, the Natural Environment Research Council (NERC) has a duty to provide scientific advice to government on matters related to the management of UK seal populations. NERC has appointed a Special Committee on Seals (SCOS) to formulate this advice. 

Any other business

MS gave a short update on work which had commenced in relation to commitments on the further reduction in sea lice levels, unless there is evidence to the contrary. It was agreed sea lice should be the first item at the next meeting to allow for a more in depth discussion.

MS was asked to update the FFHF website page to reflect the refreshed FFHF and to arrange a site visit to a fish farm.


  • Aquaculture Policy (TG) to update FFHF website page to reflect refreshed FFHF (action 16)
  • TG to arrange a visit to a fish farm site for FFHF steering group members (action 17)
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