Disposal of farmed salmon via landfill, incineration, and bio-gas:EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004.

FOI reference: FOI/18/01887  
Date received: 8 July 2018 
Date responded: 7 August 2018
Information requested

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.


Any relevant information which we do hold in relation to this request will have been obtained and recorded through our aquatic animal health surveillance programme. This information will be contained within the case information which as you are aware is published through our active publication plan:
We hold no other relevant information relating to this request.
I note the comments you have made in your request regarding the legality of landfill operations in relation to the disposal of aquaculture mortalities. I can advise you that in January 2016, the Scottish Government applied to the European Commission for a derogation to allow the continued burial of salmon farm mortalities at Whiteshore Cockles. The derogation was permitted on the grounds that the site operator undertook to install a disposal system that meets the requirements of the animal by-product regulations; burial would continue only until installation was complete. The installation has taken longer than originally planned, Scottish Government understand that the disposal site will be operational later this year.

I would also like to inform you that Marine Scotland’s Fish Health Inspectorate do not have a regulatory responsibility under the animal-by-product regulations, which cover the disposal of fish farm mortalities. Our regulations, specifically The Aquatic Animal Health (Scotland) Regulations 2009, take effect in relation to this area where the presence of a listed disease has been detected. In such circumstances statutory control measures can be placed to ensure that the removal and disposal of mortalities is undertaken in a bio-secure manner to reduce the risk of disease spread. Again, this information and the results of any activities undertaken would be captured through our aquatic animal health surveillance programme.

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at  http://www.gov.scot/foi-responses



Please quote the FOI reference:
Central Enquiry Unit 
Email:  ceu@gov.scot
Phone: 0300 244 4000 
The Scottish Government 
St Andrews House 
Regent Road 
Back to top