9 MARCH, 2016


The boil water notice issued last weekend to almost 5,000 consumers in County Galway by Irish Water has created an additional health risk, according to the environmental lobby group Friends of the Irish Environment.

The group has been campaigning to have consumers informed directly of exceedances of the WHO/EU permitted level of chemicals called trihalomethanes [THMs] in their water supplies.

THMs are a group of more than 60 chemicals, including the carcinogenic chloroform, created as a disinfectant by-product in drinking water as a result of reaction between organic materials, such as peaty soil, and chlorine. 412,000 Irish Water customers out of a customer base of 1.5 million – more than a million actual consumers –  in 79 water supply zones had levels of THMs above the limit, according to a December 11, 2015 letter from the Commission to FIE about a complaint the group has lodged.

While the Health Service Executive admits that ‘studies of THMs in drinking water show that there may be associations with human cancer’, they have refused to include the information on consumers bills or notify them directly, claiming studies are ‘weak’ and ‘inconsistent’.

Irish Water says that the boil water notice has been put in place for the Carraroe Water Supply due to the detection of cryptosporidium in the water supply which serves 4,700 people. Cryptosporidium is not affected by chlorination. FIE says records on Irish Water’s own site show that 4 out of the 5 tests undertaken on the Carraroe water scheme in 2014 and 2015 were over the WHO/EU limit for THMs, with two tests showing levels 1/3 above the permitted 100 micrograms per litre.

In a statement issued this morning, Friends of the Irish Environment highlight research published in the USA ‘Environmental Health perspectives’ in 2005 by government and academic researchers. The abstract says the study ‘adds to previous evidence that dermal absorption and inhalation of THMs associated with everyday tap water use can result in significantly higher blood THM concentrations than simply drinking the water [EHP 113:863–870]’. It recorded ‘THM blood concentrations rising 5- to 15-fold as a result of showering in subjects.’ The study states it ‘also provide[s] evidence that other THM exposure scenarios, such as washing dishes by hand and being exposed to a cohabitant’s shower steam, may also be important’.

The FIE statement continues: ‘It is universally accepted that THMs are volatile chemicals that present a specific and particular danger through inhalation. Yet this is exactly what Irish Water has instructed consumers to do by bringing the water to a ‘vigorous, rolling boil’.

‘We are not suggesting that Irish Water stop chlorinating the water before the infrastructure is rationalised, but it borders on the criminal to instruct consumers to boil the water without informing them of the necessary precautions, including ensuring adequate ventilation to protect themselves and their family from inhaling the dangerous chemicals released from boiling THM laden water.’

‘While Ireland informed the EU that all supplies exceeding the THM levels are placed on the Environmental Protection Agency Remedial Action List to inform the public, the Carraroe Public Water supply is not listed for THM exceedances on this list’.

‘An EPA Direction issued to Irish Water required completion of works including filtration and UV to address cryptosporidium in this supply by 30/11/15’, Tony Lowes of Friends of the Irish Environment added.



Boil Water Notice

Environmental Health perspectives study

EPA Remedial Action List


Back Story


Contact: Tony Lowes: 353 (0)87 2176316  /  353 (0)27 74771 /

Brockovitch warning on Irish campaign on THM chemicals- do not be fooled by this dodge of responsibility and factual sharing of information by your government!’

Risk to Pregnant women highlighted

 Erin Brockovitch has responded to Ireland’s refusal to notify consumers directly of chemical exceedences in their water by telling her ‘Irish Cousins’ ‘not to be fooled by this dodge of responsibility and factual sharing of information by your government!’

Brockovitch, an American legal clerk and environmental activist, became a household name after a 1990 film ‘Erin Brockovtich’, starring Julia Roberts in the title role, detailed Brockovitch’s work in exposing Chromium 6 in groundwater from a cooling tower system on a gas pipeline in California. The film was nominated for five Academy Awards.

The film is to be screened by TV3 tomorrow at 9PM.

Her warning comes after a report in the Irish media detailed the failure of the Irish environmental group, Friends of the Irish Environment, to have the European Commission require Ireland to inform consumer of these chemical exceedances on their water bills.

The Irish authorities admitted to the Commission that 412,000 consumers were receiving water over the level permitted by the EU and the World Health Organization but said that the Health Service Executive had ruled that as there was no ‘immediate danger’ to consumers they were not required to inform them directly.

Trihalomethanes are toxic compounds, including chloroform, which occur in drinking water as a result of reaction between organic materials, such as peaty soil, when chlorine is added as a disinfectant. Long-term exposure to THMs include an increased risk of certain cancers, such as bladder and colon; reproductive problems such as miscarriages, birth defects, and low birth rates; and damage to the heart, lungs, liver, kidney, and central nervous system.

On her recent Facebook Post, Brockovitch highlighted the dangers of THMs causing miscarriages as well as cancer. She highlighted specific danger to pregnant women, writing ‘Trihalomethanes are far more dangerous to pregnant women. Studies have demonstrated woman exposed to Drinking Water over 80 micrograms/Litre of trihalomethanes are exposed to a greater risk for miscarriage in the first trimester and low birth weight in the second and third trimester... beware of very real "short term" exposure!’

Brockovitch linked her comments to a study by the Harvard School of Public Health. This study examined the impact of THMs on pregnant women exposed to THM laden water based on a cross sectional analysis of 56,513 singleton infants born to residents of Massachusetts during 1990.

The Results showed that infants exposure to water containing over 80 microgramns/Litre compared to those exposed to water of less than 60 micro g/litre in the first trimester of pregnancy was associated with a 32 g reduction in birth weight. It also detailed ‘slight increases in gestational duration associated with TTHM concentrations’.

According to the study, for each further 20 micro g/l increase in THM, the estimated reduction in birth was 2.8 g for pregnancy average exposure. The EU permitted level are 100 micrograms/Litre, 20% higher than the level used in the Harvard study. Irish supplies quoted in the FIE complaint to the Commission included readings of up to 240 micrograms/litre.

FIE registered a complaint over the failure to inform Irish consumer of THM exceedances in 2012 but after a long series of meeting and correspondence, the Commission accepted accepted the Irish authorities claim that consumers could find out if their water supplies exceeded the permitted level through a new interactive website set up during the investigation and through a Remedial Action List on the EPA website.

Tony Lowes, a Director of FIE, said that this was ‘simply not true. The interactive website shows only very limited results for a water supply with many results ‘pending’ for over a year. In fact these readings may not coincide with readings which have established the previous vulnerability of a supply to THM exceedances’.

‘Further, the Remedial Action List only identifies THMs in the water supply for approximately 270,000 out of the 412,000 consumers the State says is affected, leaving 140,000 consumers unable to see if their supplies are affected -  even if they have internet access and skills.

‘Consumers have the right to know on their bill if their water contains THMs over the recommended limit,’ Mr. Lowes said. He pointed out that ‘THMs are not only absorbed through drinking THM laden water, but as they are volatile they can be absorbed through prolonged showering or steamy conditions in bathrooms or kitchens. They are easily removed with a relatively inexpensive charcoal filter – but consumers cannot do so unless they know their water is affected.’

An EPA sponsored conference on trihalomethanes has been announced for 16 June, 2016. The conference organisers point out that Ireland has the highest reported non-compliance for THM exceedances across the 27 EU Member States.

Comment and verification: Tony Lowes 027 74771 /  087 2176316


Brockovitch comments


Harvard Study: ‘Effect of trihalomethane exposure on fetal development.’


Natural Organic Matter & Trihalomethanes, National Technical Workshop 2016



FIE Press Release on Commission decision


Commission letter refusing to take action


EU Ombudsman letter










Friends of the Irish Environment have had no response to their letter to Minister Simon Coveney questioning his decision to ‘supplement and complement commercial insurance arrangements’ for salmon farms against ‘natural disasters’ and ‘adverse climatic events’ when the State will not do so for people.


Seafood Development Plan 2014 - 2020 plans to provide up to €2 million in state-backed insurance for salmon farms. The decision came after a salmon farm in Bantry lost 230,000 salmon in the February 2014 storm.


In response to a Parliamentary written reply to Deputy Clare Daly tabled for the organisation, the Minister said the funds were permitted to be used for this purpose by the EU for ‘safeguarding the income of producers’ in case of ‘abnormal production losses’ due to ‘adverse climatic events’.


In a separate question, he told the Deputy that ‘no insurance actuaries were currently employed by his Department.’


‘We don’t understand how the State can offer insurance to fish farmers against the worsening ravages of climate change disasters while no such comfort is offered to people.


Are farmed fish more important than people?



Comment and verification: Tony Lowes Director 087 2176316


Read the Letter


PQ on insuring fish farms


PQ on Department’s actuary experience



17 FEBRUARY 2016





A campaign in Europe to have Irish Water customers informed of toxic chemicals exceeding the World Health Organisation and European Union safety standards has failed, according to Friends of the Irish Environment.


The environmental lobby group, which specialises in the enforcement of European environmental legislation, has been told by the European Ombudsman that she cannot require the European Commission to force Irish Water to inform consumers on their bill that the water they receive contains levels of trihalomethanes above the EU and WHO permitted levels.


Trihalomethanes are toxic compounds, including chloroform, which occur in drinking water as a result of reaction between organic materials, such as peaty soil, when chlorine is added as a disinfectant. Long-term exposure to THMs include an increased risk of certain cancers, such as bladder and colon; reproductive problems such as miscarriages, birth defects, and low birth rates; and damage to the heart, lungs, liver, kidney, and central nervous system.


FIE says that ‘trihalomethanes are volatile chemicals that are easily removed by simple carbon filters if the consumer knows that his water contains them. Because they are volatile’, the statement continues, ‘there are particularly dangerous in enclosed areas with poor ventilation, through prolonged showering, bathing, ingestion, or in Jacuzzis, with pregnant women advised in particular to avoid exposure.’


During an investigation of the complaint by FIE the Irish authorities informed the Commission that on the basis of their last review, ‘around 412,000 persons are possibly affected by THM exceedances in 79 public water supply zones’.


While they agreed that ‘there is a need to substantially improve consumer communications in relation to THMs’, they have consistently refused to inform consumers on their bills when the level of trihalomethanes exceeds the WHO and EU recommended levels, instead arguing that all Irish Water customers can find out if their water supplies exceed the limit through their website, which ‘they are informed of through Irish Water billing which reaches over 1.5 million domestic premises’.


FIE Director Tony Lowes said that ‘the Irish Water website only gives consumers a snapshot of the most recent water quality results for their supply and does not include previous readings which may have shown high levels of the toxic chemicals requiring filtration upgrades. Thus, a resident of Enniskerry seeking water quality results will not see that his water is contaminated with these toxic chemicals through the Irish Water site, although the Enniskerry public supply is listed on the EPA Remedial Action List as needing an upgrade to filter trihalomethanes.

While Irish Water suggests that consumers can find further information on the EPA website’s ‘Remedial Action List’, in fact this list omits supplies covering almost 150,000 of the 412,000 consumers affected.


Emily O’Reilly, European Ombudsman, wrote to the organisation that ‘I appreciate that not all customers of the Irish water service (ʺIrish Waterʺ) will be satisfied with the approach to information provision proposed by the Irish authorities. Some customers may prefer to be informed directly rather than having to consult a website. And of course there will be customers for whom consulting a website proves either difficult or not possible.’


Ms O’Reilly said that case law prevented her from requiring the Commission to take legal proceedings against Ireland, suggested the organisation approach the Irish Energy Regulator, who is in charge of complaints against Irish water. The group is also taking legal advice about consumer rights.


Mr Lowes said ‘The core of this problem is land use policies that are allowing the draining of peat soils for forestry, farming, and peat extraction to contaminate drinking water supplies – a problem that is becoming worse as intense rainfall events increase.’




Commission letter refusing to take action


EU Ombudsman letter



Contact: Tony Lowes 027 74771 /  087 2176316

Sample Consumers affected (while we have not included all the supplies on the remedial action list, it omits almost 150,000 consumers. Ask Irish water why.)

Wicklow Wicklow Regional Public Supply 12,000, Enniskerry Public Supply 2,839, Wicklow Avoca / Ballinclash Public Supply1,506

Kerry Lisarboola  20,967, Ballymacadam  3,629

Meath East Meath 51,932

Mayo Lough Mask 36,939, Ballina 15,000, Kiltimagh  1,692

Cork Drimoleague 825; Kealkill 795; Schull  1,762

Donegal Cashilard  400, Fintown  352. Greencastle  1,000 Pettigo  510, Portnoo-Narin  941,

Rathmullen 270

Galway Ballinasloe 10,270, Portumna 2,719

Kilkenny City 17,083, Kilkenny Inistioge 1,452

Leitrim South Leitrim Regional  16,566

Longford GRANARD  1,915, LONGFORD CENTRAL 8,717

Monaghan Lough Egish 8,497

Sligo Lough Gill Regional Water Supply  13,668, South Sligo Regional Water Supply 1,403

Waterford Lismore 2,157, Ring/Helvick 1,104,  Tallow  1,197

Roscommon North Roscommon Regional Water Supply Scheme  6,762



See the worrying trends identified in Scotland in 2013 and questions for Ireland:

‘The lack of an improvement in THM compliance is extremely disappointing, especially in light of the additional efforts made by Scottish Water to achieve improvements in this respect. A number of treatment works with THM issues, such as Gairloch, Achmore and Shieldaig, were replaced during 2012 making the lack of progress all the more surprising.

Analysis of the data by DWQR shows that the pattern of THM failures in 2012 changed compared with previous years. Eighteen of the 29 supplies recording failures in 2012 did not fail in 2011 - a particularly concerning trend. Now, many failures are occurring where the treatment processes present at the site should, in theory at least, be able to treat the water to a standard needed to avoid THM formation.

Seven out of the 29 failing supplies had membrane treatment. None of these supplies should be producing water that fails the THM standard, and these failures suggest that the integrity of the nanofiltration membranes has been breached. To put this another way, Scottish Water has failed to monitor and replace membrane modules before they deteriorate to an extent that they allow organic material to pass through. Scottish Water acknowledges this and has implemented processes to ensure timely intervention takes place.

One contributory factor at some sites may be a change in the quality of raw water, meaning that a once adequate treatment process is now unable to cope. The extent of this issue has yet to be fully quantified, but Scottish Water must gain an intimate understanding of the quality of water it has to treat and design, build and optimise treatment processes accordingly.’

See for example the Nova Scotia warnings:







The Boycott Farmed Salmon campaign has issued a reply to an IFA statement on Friday alleging the campaign was engaging in a ‘smear campaign’. It has published two more pre-slaughter tests confirming the presence of antibiotic, anti-parasitic and anaesthetic chemicals. [1]


In a statement the campaign said it stood entirely behind the publication and accuracy of the pre-slaughter test results for farmed salmon they published on line last week showing the presence of 10 chemicals. The Information Commissioner reversed the Department of Agriculture Fisheries and Foods 2012 decision not to release these reports in July of this year. [2]


‘We are publishing today two more pre -slaughter reports that both confirm the presence of the anti-parasitic chemicals Emamectin benzoate and the antibiotic drug Oxytetracycline. One of these tests also confirms the presence of anaesthetic MS222 [tricaine mesilate].


‘The state holds no records of the chemicals used for treatment purposes on Irish fish farms. Consequently, the pre-slaughter reports are the only source of reliable data on the presence of chemicals.


‘The level of these chemicals as we stated in our Press Release [3], is below the ‘Minimum Permitted Residue Level, also called the ‘Level of Action’, but the fact remains they were present in pre slaughter samples. The symbol the IFA suggest can mean ‘not detected’ in laboratory reports indicates only that the level was less than that recorded but that the substance was detected as present. The ‘Level of Action’ for malachite has been halved since these 2011 and 2012 reports. [4]


‘These records, and the ones we publish today, show 10 chemicals present in farmed organic salmon at the time of slaughter – two of them - Malachite green and Leuco malachite green - called ‘illegal’ in the Marine Institute’s Chemical Residues in Irish Farmed Fish 2011. [5]


These chemicals include anti-parasitic chemicals designed to paralyse the nervous system of marine ectoparasites, antibiotics which are contributing to growing antibiotic resistance, and anaesthetics that are used for euthanasia in the aquarium trade. Anti-oxidants approved for use as the IFA states in animal feed to cut refrigeration costs while avoiding spontaneous combustions should never be allowed to enter the human food chain. [6] The cross-over of Ethoxyquin into Omega 3 products and Krill oil led to reported recalls in Australia. [7]


Those supporting the Boycott Farmed Salmon Campaign are responsible organisations and individuals and have neither misrepresented data not made false claims. They have come together to urge the public to support a boycott to protect our native salmon by removing open pen net salmon cages from our bays and estuaries.


Richie Flynn and the IFA have no business interfering in aquaculture and should put their own house in order before defending non-EU multi-nationals operating in our waters whose ‘organic’ product the States’s own records say contain an unprecedented chemical cocktail in food intended for human consumption.’



Galway Bay Against Salmon Cages 086 3511628

Save Bantry Bay 087 7949 227

Friends of the Irish Environment 087 2176316


Visit the website


NGOs supporting the campaign include: An Taisce, Aran Against Salmon Farms, Coastwatch, Federation of Irish Salmon and Sea Trout Anglers [FISSTA], Forest Friends, Friends of the Earth Friends of the Irish Environment, Galway Bay Against Salmon Cages, Irish Seal Sanctuary, No Salmon Farms at Sea, Salmon Watch Ireland, Save Bantry Bay




[1] Newly published test results


Original test results


[2] Appeal to the Commissioner for Environmental Information. Case CEI/13/0001




[4] Evin McGovern Ph.D. Senior Chemist - Marine Chemistry Section Manager, Marine Environment and Food Safety Services, 10 November 2015-12-20


[5] [9] Chemical Residues in Irish Farmed Fish 2011, Marine Environment & Health Series, No. 39, 2013, Marine Institute



Considerations on the Use of Malachite Green in Aquaculture an Analytical Aspects of Determining the Residues in Fish: A Review









Malachite green and Leuco malachite green are of particular concern as they have not been permitted for some years. Implementation of a new validated analytical method at the Marine Institute to expand testing lowered the Action Limit from 1 which applied at the time of the report we have published in 2011 to 0.5 ug/kg in October 2014, according to our recent correspondence with Marine Environment and Food Safety Services. [3]



Emamectin benzoate is the principle ingredient in ‘in food’ SLICE feed which these records show is commonly used as is deltamethrine, 2 of the listed 10 chemicals.



MS222 [anaesthetic tricaine mesilate] is used throughout the industries operations to sedate the fish before transferring for drug treatments. It is the euthanasia agent in the aquarium trade.



Oxyteracycline is an anti biotic used for disease and after jelly fish attacks. One Report notes that at one Marine Harvest Farm ‘Significant bacterial septicaemia affecting the salmon’ (‘furniculosis’) in 2011 required a course of antibiotics. Due to ‘an availability problem with Maracycline in Ireland at the time of writing so the dose will have to be part Maracycline and part Aquatet.’ Both of these antibiotics are approved by Marine Harvest on organic salmon



Unlike food for human consummation the economics of animal feed products do not allow for the same types of refrigeration that are used for human consumption products, so chemical antioxidants become ‘the only option’. The consequent dangers of spontaneous combustions are addressed as stated by the IFA by anti-oxidants


What is omitted from the IFA’s defence of the anti oxidants Butylated hydroxyanisole [BHA] and Ethoxyquin – 2 of the 4 anti-oxidants detected in the salmon’s food supply (Butylated hydroxytoluene [BHT] and Ethoxyquin D are the others) - fails to point out that these chemicals are only permitted in the animal feed chain.


There is great concern over the cross-over of these chemicals into the food chain through aquaculture, as exemplified in these tests. A recent recall in Australia was due to contamination of Omega 3 Oils and Krill products with anti-oxidant . The Australian Therapeutic Goods Administration (TGA) recenty reported (RC-2014-RN-00428-1) that it had detected the presence of ethoxyquin in multiple krill oil products sponsored by a large Australian-owned manufacturer and distributor which were subject to a recall.



We have received no explanation why of the 140 samples of farmed finfish reportedly tested for substances in 2011, only 10 records have been supplied to us and only 3 of those give the detailed pre slaughter analysis – one of them undated on the Report, undated in the remainder of the file, and undated on the Schedule of Records. We can only surmise that it fell within the time period of the request. The Information Comissioner also commented on great delays and low level of cooperation evidenced by the Department of Agriculture, Food, and Fisheries.


The Information Commissioner said he received ‘no explanations as to why ‘these reports were not identified as relevant in response to the original or internal review requests, or indeed when my Office queried the issue in 2014’. Our request for the remainder of the reports have been denied by the Department and have entered the appeals process.





IFA exec accuses environmental groups of smear campaign on farmed salmon

December 18, 2015, 9:01 am


Undercurrent News

The following is a statement from Richie Flynn, aquaculture executive at the Irish Farmers' Association (IFA), in relation to the story “Irish environmental groups launch boycott on farmed salmon”, published on Dec. 15.


A group of organizations who campaign to ruin hundreds of jobs on Irish farms, processing plants, smokeries and shops in Ireland in the run up to Christmas each year have been reduced to deliberately misreported data to give make an entirely false claim regarding chemical residues in Irish farmed organic salmon.

The test result released in conjunction with a press release by those organizations in fact shows the opposite is true. This handwritten note confirms that no unauthorized chemicals or medicines were present in the single fish concerned. Yet this single piece of “evidence” is the basis for the entire campaign to “boycott farmed salmon”.

The results in question actually show that of ten chemicals tested, six were not detected at all (It is normal laboratory protocol to use the “<” sign describes a result as either “not detected” or “below the limit of detection”). Therefore the fish did not contain any Deltamethrin, Oxytetracycline, Malachite Green, Leuco Malachite, MS222, or BHT.

Emamectin benzoate is an anti sea lice product which is authorized and has an permitted residue limit authorized by the EU and national authorities, In this particular case the level detected is well below the permitted level (1.2 ug/kg when the permitted level is 100ug/kg)

BHA and Ethoxyquin are permitted antioxidants found in fishmeal and fish oil (feed ingredients) necessary for the prevention of spontaneous combustion in fishmeal and oils transported by sea. These were permitted antioxidants in 2011 and again at barely detectable levels.

These facts have been ignored by the campaign and in fact distorted to an extent where headlines in the media have unfairly damaged the reputation of Irish organic salmon and the company involved. In fact the group’s press release accuses the company of actually using an “illegal chemical” when the proof they cite shows the complete opposite to be true.

The handwritten note published is an extract from the report of a Department of Agriculture Inspector which was compiled during an inspection visit of Marine Harvest Ireland in 2012 and is the Inspector’s note of a record kept by the company of internal testing carried out on a single fish in 2011.

This is an example of many voluntary internal tests (almost 3,000 in the past ten years) carried out by the company over and above that required by law for confirmatory purposes to give confidence to customers that their products are free of any illegal medicines or residues.

This voluntary testing is in addition to the 430 random regulatory tests carried out on MHI by the Marine Institute during 2011 out under the Animal Remedies Act which also confirmed that no illegal residue levels of authorized products nor unauthorized chemicals of any kind were present in the fish.