SEPA's Sea Lice Regulatory Framework

4. Conclusions

28. Regulation is a fixture of an industrial landscape, which is undisputed. The physical principles and underlying methodology of the SLRF are scientifically well-founded (assessing encounter rates in a moving fluid). Clarity on the precise application of the approach and certainty of outcomes is where most contention has arisen. Science moves on, the underlying principles are the SLRF used the best science available at the time of development – a timetabled and rules-based method for adaptation to new scientific evidence must be clearly articulated.

29. Relationship between industry and regulator is at a low ebb (notwithstanding continuing day-to-day operational dialogue). This report tries to summarise and categorise industry concerns which centre around the scientific basis, scientific presentation, and scientific application of the SLRF. Where it finds merit in those concerns, recommendations are made which Ministers are invited to consider. Where recommendations are not made, explanations are given as to why a particular concern does not merit further action in the view of CSA Marine.

30. This report is based on unilateral meetings between CSA Marine and industry (listening to their concerns), and CSA Marine and SEPA (seeking points of clarification). Bilateral meetings should now happen to facilitate any Ministerial recommendations. Respecting SEPA’s role as the independent regulator, these meetings should have a third-party expert chair agreed in advance by both parties and be time limited. This may improve the relationship between industry and regulator and lead to improved relations and regulation.