Submission 0166-RAY

Submitter: Janet Ray

Community: Victoria

Date Submitted: September 1, 2023

The refusal of the aquaculture industry to disclose salmon feedlot disease information is preventing the public, through the provincial government, from determining whether sea lice, IHN virus outbreaks or other factors are causing the decline of wild salmon. The new proposed federal Pacific Aquaculture Regulations do not go far enough in guaranteeing the protection of wild salmon. Thorough monitoring and enforceable measures, such as transitioning to land based closed containment feedlots, must be implemented to ensure that salmon feedlots are not adversely affecting wild salmon stocks.

In 2009 the Department of Fisheries and Oceans (DFO) was expecting over 10 million sockeye salmon to return to the Fraser River. Instead, less than 15 per cent (1.5 million) showed up.

As a physician, if I were to imagine this problem presenting as an office visit, the salmon would be a desperately sick child and the DFO the full time babysitter who’s been entrusted with their welfare. I say the babysitter, because it is the public, you and I, who elect the government which in turn authorizes the DFO to monitor and enforce regulations to protect wild salmon. You and I are the parents. This is happening on our watch.

Presenting Problems:
1. Potentially life threatening illness of salmon
2. DFO’s (babysitter’s) inability to understand, anticipate or remedy the problem
3. Absentee parents

History of the Presenting Illness (HPI):
A major determinant of health for all living things is lifestyle, which includes everything from nutrition, exposure to toxins and infectious agents. Like children, salmon cannot choose their lifestyle or exposures to environmental threats. They are completely dependent on us to protect them from man-made harm.

It was known that this year’s generation of salmon had been the least affected by recent declines. The record return this year suggests that the oceans are still capable of supporting healthy salmon stock, but it does not mean that all is well. It’s important to remember that each year of salmon is very independent from each other. Each salmon run is like a strand of an ecological tight rope that we balance on. We know from the decimated return of last year that one of the strands is breaking. We cannot afford another break and neither can any of the other species who depend upon them- the eagles, bears, etc. Because of their pivotal role in our ecosystem, we in the Pacific North-West are called by ethnobotanists ‘The Salmon Nation’.

Two of the top man-made potential threats to the health of wild salmon are exposure to viruses especially the Infectious Hematopoietic Necrosis virus (IHN) and parasites, especially sea lice which exist in high levels in fish feedlots. When we have an epidemic outbreak of human influenza virus, we know that living in close quarters provides a perfect breeding ground for transmission and mutation. Any family can tell you that respiratory illnesses increase in everyone at home when children start school. In a similar fashion, the unnatural concentration of fish in the feedlots amplifies disease outbreak. It’s estimated that there is over one ton of waste being produced and discharged every day from every feedlot. (2) Because this is an open system, the vulnerable young wild salmon fry can become infected with viruses or become contaminated with sea lice as they swim past the feedlots.

Physical Exam:
The DFO has found IHN in Fraser sockeye in the years of the IHN epidemic and have also gone on record stating that IHN is lethal to sockeye. Dr. Morton has determined that “the decline in productivity of Fraser Sockeye is alarmingly correlated with massive IHN outbreaks in salmon feedlots on the Fraser sockeye migration route going back to 1992”. (1) “The Fraser Sockeye decline began at the same time government failed to cull millions of IHN virus infected feedlot salmon on the Fraser River migration routes.” (2)

Sea lice epidemics are known to occur, despite questionable reporting by the industry. “In 1995, a salmon farm requested permission to use hydrogen peroxide to treat an extremely heavy outbreak of sea lice on their fish. When the Ministry of Environment, Parks and Lands (MELP) informed the company that their drug application would have to be released to the public, the fish farmer withdrew the request. When environmental groups found out about the sea lice outbreak, the BC Salmon Farmers Association called for an investigation of MELP and a guarantee that fish farmers had a right to secrecy in the future.”….. “Sept 6, 1995 Don Peterson of MELP writes, ‘The company has withdrawn their application (for hydrogen peroxide) because they heard there was a requirement to advertise if a pesticide was going to be applied. I guess they were either afraid of the shareholders…or the public finding out… the company has asked that this request be kept strictly confidential and that all correspondence on the subject be destroyed’.” (3)

Differential Diagnosis:
We know our salmon ‘child’ is sick. Differential diagnoses include sea lice parasites, IHN virus outbreaks, as well as a host of other factors related to feedlots and the marine environment.
To know what other factors are significant, it’s an obvious question to look back and examine if there were in fact disease outbreaks in feedlots that may have affected last year’s run. “On March 1st 2010, the Office of the Information and Privacy Commissioner (BC Order F10-06) decided that salmon feedlot disease records had to be released to an FOI applicant. In the decision, the adjudicator, Michael McEvoy, quotes the four biggest companies in BC, stating that if their disease records are released to the public they would never give government (us) access again.” …. They have since followed through with their threat, and according to Dr. Morton, “Fish health and lice monitoring audits by BCMAL (BC Ministry of Agriculture and Lands) ceased as of April 1 2010 when live fish and carcasses were no longer volunteered or made available to BCMAL fish health program staff.” (1)
How can we ever possibly know what is going on if we can’t complete the history or physical exam?
How would you feel if your newborn was kept in their hospital crib beside someone dying of a deadly infectious disease? Would you want to know how contagious it was? Would you have a responsibility to demand separate wards? What if the hospital wouldn’t tell you if there was a deadly disease and how pervasive it was? Withholding this information would be morally reprehensible and consistent with criminal negligence.
This is what’s happening now to our salmon, on our watch. This has been going on for too long. “In an Letter of Understanding (Jan 23, 2024) British Columbians paid $70,000.00 for a data base containing feedlot disease information that was so secret BCMAL promised not to give it even to their enforcement officers. The information they do release is so incomplete it failed to report the IHN epidemic in Broughton in 2003.” (1)
1. Potentially life threatening illness, unable to determine cause secondary to inability to conduct thorough history or physical exam. Prognosis is poor unless we are allowed open access to the patient and ‘relatives’- (feedlot salmon disease information) and have laws to enforce protection. An assessment from the Canadian Food Inspection Agency reports that Canada is failing international fish disease reporting standards. (4)

2. Baby sitter (DFO) needs clear guidelines and needs to be empowered to act.

3. Parents (we the people/government) need to set the rules with clearly defined consequences if they are not adhered to. We need to do everything in our power to protect the safety and health of wild salmon stocks. Parents have the right and responsibility to know what’s happening to their children. We (and the government) have the right and responsibility to know what’s happening with feedlot salmon and how it may be affecting our wild salmon.

Status of Patient: Critical
The new proposed Federal Pacific Aquaculture Regulations offer lesser disease reporting for some salmon feedlot sites. They will give Norwegian companies the right to leave infected salmon in the water and protect them from liability, as well as offering them authorization for “harmful alteration disruption or destruction’ of fish habitat (Section 35(1) Fisheries act). They also propose that feedlot licenses be granted or changed without environmental assessment.
I care about wild salmon and the proposed regulations do not go far enough to guarantee their protection. I want thorough monitoring and enforceable measures to ensure that salmon feedlots are not adversely affecting wild salmon stocks.

I support Independent Members Bill C-518, which proposes the transition to land based closed containment fish feedlots, so that there is no risk to our wild salmon stocks from feedlot contamination.

(1) Dr. Morton, Open letter to BC MLA’s Aug 3 2010
(2) Dr. Morton, in letter to Ed Porter, Fisheries and Oceans Canada July 28th, 2010
(3) Sea Lice Secrets, 26 May 2023

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