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:









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



Eamon O’Cuiv, TD, told the Committee on Agriculture Fisheries and Food, on 1 December 2015 that ‘No one can try to tell me that organic fish farmers do not use chemicals to control for various diseases or lice. Fish produced on such farms can be labelled as organic but I would take the hill lamb over such a fish any day, in terms of it being a natural product. I will not touch farmed salmon because it is a totally unnatural product.’


Today the Boycott Farmed Salmon campaign publishes the results of a pre-slaughter test recorded in 2012 (the last records released after an appeal to the Information Commissioner) that shows a single Marine Harvest fish slaughtered for human consumption reported in July 2012 showed a total of 10 chemical residues.


These included two chemicals designed to paralyse the nervous system of insects like lice (Deltamethrin and Emamectin) which require a withdrawal period in the United States but not in the European Union, the antibiotic Oxytetracycline, the anaesthetic tricaine mesilate, and four anti-oxidants used in the salmon’s food supply as well as two illegal dyes, Malachite green and Leuco malachite green.


6 of the 10 chemicals are not listed by Marine Harvest on their ‘Positive Medicine List’ of chemicals they say they use.


Read the Press Release    |   See the test results







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.




9 December 2015




The Department of Agriculture, Food, and Fisheries has again refused to release the accident records from storm damage leading to the loss of 230,000 adult salmon in February 2014 at Gerahies in Bantry Bay, Co. Cork.


It has informed Friends of the Irish Environment that the date for the completion of the report is 31 December, 2015.


FIE successfully appealed the Department’s refusal to release the preliminary reports and correspondence. The Department was ‘strongly of the view’ that the release of any parts of the deliberative process of advising the Minister what action to take ‘would be premature and would unduly constrain the Minister in respect of any action which he might deem appropriate.’


It also argued that the public interest would not be served by the release of the report.


However the Information Commission ruled against the Department on both grounds.


‘I do not accept’, the Information Commissioner wrote in the ruling on 13th July, 2015, ‘that the connection between the requested information and an ongoing, seemingly indefinite deliberative process provides an adequate basis for refusal.’


As to the public interest, the Commissioner concluded, ‘that there is a very strong public interest in maximising openness and accountability in relation to how the Department of Marine and the Marine Institute carry out their functions under the relevant legislation governing the aquaculture industry.’


FIE Director Tony Lowes said that the ruling only covered material requested in March 2014, shortly after the accident, and the new request was simply to bring the records up to date and should have been released on the basis of the earlier ruling.


‘The emails released to us show that the report of the accident was not made by the operator until 6 days after the accident – at 5.35 PM on Friday the 6th of February. Consequently, investigations did not begin until the Monday morning - 9 days after the accident. This was far too late to determine how many of the fish escaped and how many were trapped to die in the collapsed cages.’


‘There is currently no form of underwater inspection of these installations, in spite of requests supported at Assistant Secretary level in Simon Coveney’s Department for adequate systems in relation to certification, maintenance, inspection, repairs and records to be put in place’.


‘The key question that remains is if the damaged installations were subject to a full underwater assessment before restocking, as recommenced by the Engineering Division – and if regular inspections have been brought in to protect us from these disasters’, FIE said.






Director, Friends of the Irish Environment, Tony Lowes, 087 217 6316 (mobile), 027 74771 (office)


Secretary, Save Bantry Bay, Alec O’Donovan, 087 7949227 (mobile) or 027 50508


Chair, Save Bantry Bay, Kieran O’Shea, 086 1280303 (mobile) or 027 60121





Appeal decision granting access 13 July 2015:


Press Release:




29 May 2015