- 12 Feb 2021
Date received: 25 Nov 2020
Date responded: 24 Dec 2020
Information regarding aquaculture practices within the Scottish aquaculture industry, specifically:
- In 2018 and 2019 respectively, what tonnage of finfish produced in Scotland was stunned prior to slaughter?
- In 2018 and 2019 respectively, what tonnage of finfish produced in Scotland was not stunned prior to slaughter?
- How many registered salmon farms existed as of 31 March 2020 that fall under Scottish jurisdiction? And how many of these farms practice stunning salmon before slaughter? (Please provide either the number or percentage).
- How many registered fish farms existed as of 31 March 2020 that fall under Scottish jurisdiction and how often is your register updated? 5) What information do you collect/record/monitor when it comes to the welfare of fish on fish farms that fall under Scottish jurisdiction? For example, the amount of fish stunned vs not stunned on farms, method of stunning used, average stocking density on farms, recorded disease outbreaks. Please provide a list of information headers.
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.
While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. Therefore, we are refusing part of your request under the exception at regulation 10(4)(a) of the EIRs. The reason why that exception applies is detailed below.
Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have information concerning the volume of finfish stunned prior to slaughter, because we do not hold or record this type of information. As a result we are unable to answer sections 1, 2 and part of section 3 of your request.
This exception 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about the volume of finfish stunned prior to slaughter within the Scottish aquaculture industry, clearly we cannot provide information which we do not hold.
With respect to your request I note the terminology you have used - ‘stunned prior to slaughter’ and I thought it may be beneficial to explain to you our understanding of the processes which are in place in Scotland. It is the understanding of the Scottish Government that farmed salmon are irrecoverably percussively stunned and killed in one single action, as part of the slaughter process. This is followed by a process of bleeding, normally exercised by cutting the gills. Together these processes of stunning and bleeding comprise the act of slaughter with respect to farmed salmon populations. Other acceptable methods of killing exist within Scottish Aquaculture but as explained above we do not hold definitive information regarding this. It is our understanding that percussive stunning and killing is the predominant method used with respect to the slaughter of farmed fish within Scotland.
With respect to your queries concerning site registration, specifically parts 3 and 4 of your request, I can advise you that in accordance with provisions within The Aquatic Animal Health (Scotland) Regulations 2009, aquaculture production businesses (APBs), including details of their sites in operation, are authorised by the Scottish Government. A record of these APBs is made publicly available in accordance with those Regulations. You can find out further information on the Scottish Government’s website:
The records established, maintained and made publicly available by the Scottish Government are updated on a weekly basis. Updates incorporate the registration and authorisation of new sites, inactivation and deregistration of existing sites and businesses, as well as other changes related to the recorded and published information. As a result, the number of APBs and operating sites is subject to constant change.
As of 17 December 2020, in accordance with Scottish Government’s database records there were 227 active seawater salmon farms within Scotland. The Scottish Annual Production Survey, and in particular Table 33 of the same, may be a useful resource for you to compare how the number of registered sites has changed over time. The published report for 2019 can be viewed on the Scottish Government website:
I note that you have also asked for information which is collected / recorded and monitored with respect to the welfare of fish on fish farms in Scotland – part 5 of your request. I can advise you that Scottish Government do not have an operational role in relation to the inspection of fish farms for fish welfare purposes. This responsibility and activity falls to the Animal and Plant Health Agency – APHA and you can find out more on their website:
Scottish Government do have a policy responsibility for the area covering animal welfare (including fish) and officials will liaise with APHA as appropriate in this regard.
Scottish Government undertake inspections of aquaculture sites with respect to aquatic animal health surveillance and on our website you can find out further details of the activities conducted as well as the results and findings of this surveillance which includes details of the type of information we inspected and record:
Operational activities: https://www.gov.scot/policies/fish-health-inspectorate/
Results of surveillance: https://www.gov.scot/collections/publication-of-fish-health-inspectorate-information/
Where we are made aware of potential or actual welfare problems or concerns, through either third party notification or our own inspection activity we will liaise directly with APHA and assist with any site inspection where necessary.
As explained above we do not hold recorded information relating the stunning of fish with respect to fish farm sites. Disease information is contained within the published information relating to aquatic animal disease surveillance, the link to which is provided above.
You have requested information relating to the average stocking density on fish farms, whilst this type of information is not routinely collected by the Scottish Government, with respect to aquatic animal health surveillance, information on potential maximum stocking densities are calculated as part of our consideration of planning applications for new and modified sites. Scottish Government is a statutory consultee within the Aquaculture planning process. The information relating to stocking densities, which we consider, is already in the public domain on planning portals for individual local authorities where the sites are located. Please do get back to me if you require any additional information on accessing the same.
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
Phone: 0300 244 4000
The Scottish Government
St Andrews House