FRIENDS OF THE IRISH ENVIRONMENT
MONDAY 21 DECEMBER 2015
‘SMEAR CAMPAIGN’ - IFA WRONG IN FACT AND WRONG IN LAW
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. 
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. 
‘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 , 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. 
‘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. 
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.  The cross-over of Ethoxyquin into Omega 3 products and Krill oil led to reported recalls in Australia. 
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
 Newly published test results
Original test results
 Appeal to the Commissioner for Environmental Information. Case CEI/13/0001
 Evin McGovern Ph.D. Senior Chemist - Marine Chemistry Section Manager, Marine Environment and Food Safety Services, 10 November 2015-12-20
  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. 
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.
December 18, 2015, 9:01 am
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.
LAUNCH OF FARMED SALMON BOYCOTT 2015 REVEALS ILLEGAL CHEMICALS
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.
23 November, 2015
Friends of the Irish Environment
Peat extraction to be exempted from planning permission
The industrial extraction of peat is to be removed from planning controls, according to statements by horticultural peat extraction companies Bulrush and Westland in the High Court on Friday.
Bulrush Horticulture is based in Northern Ireland and is a wholly owned subsidiary of the Danish growing media manufacturer, Pindstrup Mosebrug A/S. Westlands Horticulture is registered in Northern Ireland.
The industrial peat extractors are challenging rulings by An Bord Pleanala, made in 2013 in response to applications by Friends of the Irish Environment (FIE), that their operations require planning permission.
The President of the High Court, The Hon. Mr. Justice Nicholas Kearns, accepted that changes in the legislation were ‘imminent’ and granted an adjournment.
According to solicitors for the two companies in the Court on Friday, the changes in the legislation are expected in ‘late December or early January’.
A statement issued by FIE said that ‘These companies are engaged in extensive peat extraction in County Westmeath for horticultural use. Since FIE brought these illegal activities to the attention of the planning authorities and the EPA in 2009, no enforcement action has been taken and the unauthorised extraction has actually increased.’
FIE Director Tony Lowes said that ‘more than five years of work to enforce the planning laws is being met with an attempt to change the law retrospectively to allow ongoing environmental destruction - including the ongoing destruction of a Bronze Age bog road by Westlands at Mayne in County Westmeath.
FIE estimates there are ‘8 to 10 mini Bord na Mona’s’ operating entirely outside the law. They provided the Department with the results of a 2010 Satellite Survey, in part funded by the Department, that led to an investigation of 126 sites of over 30 hectares in 19 counties, many of which the Local Authorities reported as required planning permission. None of the operations were known to the Local Authorities or were listed on the required Extractive Industries Register, according to FIE.
From its discussions with the Department of the Environment, FIE understands the changes are planned in response to its petition to the EU Petitions Committee which presented a satellite survey of exposed peatlands in Ireland and the failure of Irish authorities to enforce laws regulating peat extraction.
‘Is this what the Minister for the Environment is taking to the Climate Change conference in Paris next week – the news that Ireland is removing peat extraction from planning controls just as Mary Robinson has called for major fossil fuel reserves to be left in the ground?’
Tony Lowes 087 2176316 / 027 74771
Petition: (includes photographs)
The Satellite survey information and documentation
Background survey article
FRIENDS OF THE IRISH ENVIRONMENT
9 December 2015
ACCIDENT REPORT FOR NEW YEAR’S EVE
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:
REPORT ON MARINE FISH FARMS INSPECTIONS 2012 – 2014
29 May 2015
DEPARTMENT INVER BAY 2010 ACCIDENT REPORT
FRIENDS OF THE IRISH ENVIRONMENT
MONDAY 19 OCTOBER 2015
Salmon Farming Norwegian Multinational not ‘fit person’
An appeal has been lodged against the Norwegian multinational Marine Harvest's application for a salmon farming expansion in Bantry Bay that claims the applicant is not a ‘fit person’ to hold a licence.
The appeal cites records showing the company refused to cooperate with audits by the Department of Agriculture and by the Marine Institute in 2013 and 2014.
The claims are based on records released to Friends of the Irish Environment recently by the Commissioner for Environmental Information after the Department of Agriculture had cited ‘public interest’ for refusing them.
A recent FIE Study of Fin Fish Inspections Reports from the Department of Marine’s records 2012 – 2014 show that the applicant, Marine Harvest, failed to co-operates in the 2014 audit after overstocking was identified and ordered to be corrected in two of their Castletownbere-based sites in 2011, 2012, and 2013.
Citing a further Marine Institute’s Veterinary Audit Report in which Marine Harvest refused to provide the Institute's Auditor with any sea lice treatment details in 2014, FIE has argued to the Aquaculture Appeals Board that Marine Harvest is not a ‘fit person’ to be issued with further licences.
‘It is part of the licence conditions that operators must cooperate fully with audits. Marine Harvest’s failures to do so mean that they are not a ‘fit person’ to be granted a further licence.’
The group has also provided a detailed scientific examination of the Environmental Impact Statement that demonstrates that fundamental errors in Marine Harvest’s original application which the group identified in 2012 have remained uncorrected.
‘The EIS continues to significantly misrepresent the length of coastline and nominal sea area as well as the prevailing wind conditions on the Western Irish Coast’, according to the appeal.
The appeal argues that the applicant’s claim that the waste from the site – given by FIE as equivalent to the nitrogen content of treated sewage from a population of 58,000 – will pass to the south of Bere Island and ‘out into the Atlantic circulation’ is clearly contradicted by the Marine Institute’s own published weekly models.
These show the flow from Shot Head is both in and out of the inner bay.
The appeal cites scientific studies that demonstrate that the already frequent closures of mussel farms in inner Bantry bay due to the presence of significant levels of toxicity will be made worse by this project.
FIE’s appeal is one of many highlighting the failure of the EIS authors to review the literature of sea lice and the potential impact of farmed salmon on migratory Irish salmon in the five nearby rivers.
The organisation gives its overall position as ‘against any farming of piscivores – fish which eat fish - high up the food web - like farmed salmon and farmed tuna. One-third of the global fish harvest is now used to make fish food.
‘If Ireland is serious about feeding people, farmed salmon are not a sustainable food source as the fish required to feed them could and should go directly to feeding human beings’, FIE Director Caroline Lewis concluded their appeal.
CONTACTS: 353 (0)87 2176316 / 353 (0)27 74771
Shot Head Appeal URL
FIE Inspection Report URL
Commissioner for Environmental Information recent decisions:
Gerahies Accident - full release 13 July 2015
Chemical Use Inspection Reports limited release 21 Aug 2015