Information on mortalities, welfare and diseases of cleaner fish: EIR release

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

FOI reference: FOI/18/02812  
Date received: 4 October 2018 
Date responded: 1 November 2018
Information requested
You asked for information on mortalities, welfare and diseases of cleaner fish (wrasse & lumpsucker/lumpfish) since 1 January 2017. Specifically, you asked that this should include:

1) Any emails, correspondence and any discussions in relation to mortalities and diseases of cleaner fish.

2) Any photos of dead & diseased cleaner fish.

3) Details of tonnages and quantities of dead cleaner fish.

4) Information on the disposal of dead cleaner fish.

5) What quantities of cleaner fish are disposed of via 'Category 3' waste (i.e. at the end of the harvesting cycle) and via 'Category 2' waste (i.e. diseased and disposed of before the end of the production cycle).

6) Any information on welfare concerns relating to cleaner fish.
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.
You have previously requested information on cleaner fish relating to diseases and mortalities since 1 January 2017 (FoI/17/03056) which we received on 19 December 2017 and responded to on 22 January 2018. You have also previously requested photographs of lumpsuckers, wrasse and other so-called ‘cleaner fish’ since 1 January 2017 (FoI/18/02310) which was received on 28 August 2018 and replied to on 21 September 2018. Therefore, this request is a partial repeat of two previous requests.

We try hard to respond to EIR requests on time and by providing all relevant information (unless exceptions apply). Repeat requests for information can make our job in doing this more difficult, and while this request also covers information for 2018, in large part it is a repeat of your requests FoI/17/03056 and FoI/18/02310. It would be helpful if you could bear in mind information that you have already requested from us when submitting new requests and not submit repeat requests. Responses to both requests FoI/17/03056 and FoI/18/02310 are publicly available on the Scottish Government website:

With respect to the specific areas of this request, as relevant from 19 December 2017 onwards, and for photographs from 28 August 2018 onwards, I can confirm that, in relation to mortalities, welfare and diseases of cleaner fish:
  • We hold no information relating to emails, correspondence and any discussions concerning mortalities and diseases of cleaner fish.
  • We have no photographs of dead and diseased cleaner fish relating to Fish Health Inspectorate (FHI) case inspections (this part of the request has been restricted to FHI case inspections, for the reasons given to you detailed within communications relating to previous requests for photographs – including FoI/18/01141 and FoI/18/02310).
  • We hold no information on the tonnages and quantities of dead cleaner fish or the disposal of dead cleaner fish and no information on the quantity disposed of by waste category.
  • We hold no information on welfare concerns relating to cleaner fish.
Please be aware that Marine Scotland does not routinely collect or maintain comprehensive records of information relating to the quantity, disposal and waste category of ‘dead cleaner fish’. However, we may hold some information relevant to your request in relation to the FHI aquatic animal health surveillance activity. As you are aware, our active publication plan makes this information available through publication on a quarterly basis, three months in arrears. Any information held on incidences of disease or mortality on Scottish fish farms, which have resulted in further investigation and follow up site inspection by the FHI, will be published through this route:

In addition, the Scottish Government publishes a lot of information on the activities and responsibilities of the FHI on its website. The FHI Service Charter,, will inform you about the areas within which the FHI have responsibility. Hopefully this is a useful resource for you to consider when formulating requests and considering the likelihood that the information you require will actually be held by us.

Of course there will always be information that you need that we do not publish, and information which you are unsure if we will hold or not. We are always happy to answer information requests, and I am trying here to help you to ask us questions that get you what you need, quickly.
About FOI

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Please quote the FOI reference
Central Enquiry Unit 
Phone: 0300 244 4000

The Scottish Government 
St Andrew's House 
Regent Road 

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