Prospect
CAB Publication date
GTC
Certificate holder Date of submission
2016-03-02
Unit of certification Species
Monday Rock Farm · Atlantic salmon (Salmo salar)
Country Reference to other VRs
Canada
Document
Document reference Version
Salmon 1.0
Indicator Other relevant indicator/clause
3.1.7
Background
Background info
Many differences exist between Pacific British Columbia and other salmon farming regions globally, with respect to sea lice. These differences, both environmental and regulatory, make meeting the ASC threshold of 0.1 mature female lice not only difficult but potentially causing long term negative consequences of treatment resistance build up in lice populations due to the narrow range of available active therapeutants in British Columbia.

ASC has recognized the need to adjust the threshold for British Columbia in the Operational Review, stating that “requiring Canada to comply with the Norwegian trigger…would simply inflate PTI scores unnecessarily” (p. 12). The Operational Review also notes that the limit of 0.1 mature females was set “in the absence of understanding the differences between regional epidemiology” of lice in what are very different ecosystems when compared to North East Atlantic (p. 17).
The current ASC standard is based upon NE Atlantic and not Pacific British Columbia. Along with submissions via the BC Salmon Farmers Association to the operational review, this variance supplies information relevant to British Columbia vital to determining the appropriate level of lice acceptable for health of the environment.

The British Columbia salmon farming industry has been under intense pressure from environmental groups for many years to prove that lice are being managed effectively to protect the health of wild Pacific salmonid stocks.
Many years of research has been undertaken by government, NGOs, industry and academics. Some of the leading sea lice researchers have summarized the data gathered throughout these research projects in Appendix 1 (to this VR and submitted as evidence along with a previous and accepted VR for MHC Doyle Fish Farm).

The many years of research show that lice are being managed, and additional treatments could have irreversible harm on the environment. Rather than attempt to enforce a threshold developed in another country with very different circumstances, the ASC should review the regulatory levels for lice management (Appendix 2) in British Columbia specific to this VR. Associated and Accepted VR’s In December, 2015, a similar variance request (VR-88) was accepted by the ASC for Doyle Island farm site.
This variance is being submitted to recognize that some operating areas (including Quatsino Sound, where Monday Rock is located) have been approved for use of hydrogen peroxide to treat sea lice. While this changes the detail of the variance, the local conditions (including lice and salmon species, proportion of wild to farmed fish, and other details explained in Appendix 1) remain the same.

Marine Harvest states that managing lice in accordance with the Pacific Aquaculture Regulation is the most effective way to ensure the health of farmed and wild salmonid populations. There are many reasons to consider Pacific British Columbia separately from other operating areas in regards to sea lice management. While details and scientific evidence of each argument are laid out in Appendix 1, the key points are listed below.

Key Arguments:
  • Environmental Differences
    - L. salmonis in BC are a different species from L. salmonis in Europe; BC is a sub-species and is less virulent.
    - Wild salmon in Pacific BC belong to the genus Oncorhynchus, while European salmonids belong to the genus Salmo; Pacific BC species are more tolerant to sea lice.
    - Sensitive period for wild salmonid outmigration is much longer in BC (March 1 – June 30) than other areas, requiring a greater number of treatments to keep the lice level   low for this period
    - Ratio of wild to farmed salmon in BC (approx. 1000:1) vastly different than that in Norway (approx. 1:1000)
  • Basis for lice threshold in BC
    - Established in 2003 as a precautionary level
    - Level acknowledged the lack of serious disease resulting from lice in BC, compared to other regions
    - Set to reflect the large populations of wild salmon in BC, which carry large loads of lice and are known to greatly influence on-farm lice levels in the summer and fall months
  • Risks of over-treating
    - In most BC production areas, SLICE is the only regulated treatment option
    - Increasing the number of SLICE treatments is irresponsible, as it increases the chances that lice will become resistant, leaving the BC industry without effective treatment options
    - Hydrogen peroxide has been approved for use in some production areas (including Quatsino, where Monday Rock is located). While this gives farmers an additional option and reduces reliance on SLICE, prudent use is still necessary to ensure resistance does not develop and standards should be developed to support the avoidance of resistance.
    - Unnecessary treatments increases the amount of chemicals in the environment which may have further negative impact and conflicts other clauses.
  • Contradiction within the ASC standard
    - Additional treatments required to meet 0.1 threshold increase farm PTI, jeopardizing the farm’s ability to meet Indicator 5.2.5. A commitment to meet 3.1.7 will mean failure to meet 5.2.5?
    - This compounded by a far longer period of smolt outmigration for 5 Pacific salmon species, of at least 3 times the length of time compared to Norwegian Atlantic salmon smolt outmigration. This makes the PTI immensely challenging and arguably unworkable and compounds earlier statements of unnecessary treatments.
Conclusion

Sea lice have been effectively managed in BC for over 10 years. Current management, including frequent on farm sampling for lice, timely treatment, and prudent use of the treatment options available have allowed BC salmon farmers to keep their fish healthy while preserving the health of wild populations. Enforcing a European threshold in BC does not take into account the vast environmental differences between the regions. Adhering to these thresholds in BC would, at best, create concern, and at worst result in damage to the environment and resistant lice populations. For these reasons, we ask for a variance to Indicator 3.1.7.


Supporting evidence
Appendices

Refer to Appendix 1 attachment.

Appendix 2:
Pacific Aquaculture Regulation Sea Lice Management Requirements
  • 7.4 During the period from July 1 to February 28 inclusive, the licence holder cultivating Atlantic salmon and trout shall carry out a sea lice abundance assessment once every month, at a minimum, for fish held in containment structures for more than 30 days, and where the abundance threshold of three motile Lepeophtheirus spp. has been exceeded, the licence holder shall:
    (a) increase monitoring to at least once every two weeks;
    (b) initiate action within 30 calendar days to manage motile Lepeophtheirus spp. on Atlantic salmon and trout; and
    (c) notify the Department as per section 8.1
  • 8.3 From March 1 to June 30 inclusively, should the average sea lice abundance reach or exceed three motile Lepeophtheirus spp. per cultivated salmonid, the licence holder shall report to the Department within five calendar days of the discovery:
    (a) the abundance results of the sea lice monitoring; and
    (b) the actions and management response to be initiated within 15 calendar days of the discovery.

Request/Recommendation
It is recommended to accept the variation request on the basis that:
  • the requirements of the local Pacific Aquaculture Regulation Sea Lice Management Requirements prescribe a sea lice management regime in synch with the local sea lice infestation characteristics and evidence demonstrates their effectiveness at not causing long-term detrimental effects on farmed and wild salmonid populations. Track record demonstrates suitability of the current thresholds used.
  • that Marine Harvest Canada’s intent was to meet the ASC standard but as in other sites, were not successful due to the same environmental and regulatory circumstances and which were recognised and accepted by variation request.
  • Negative consequences may occur from overuse of a narrow range of active therapeutants to combat sea lice infestation. Other regions of the world have access to a broader range of active ingredients allowing for Integrated Pest Management principles to be readily adopted. MHC follows best practice in this regard which means judicial use of the available treatments and not overuse of the same products, where there are no proven benefits on either farmed or wild salmon populations.
  • A variation request of near identical circumstances has been accepted based on the same evidence.
As such it is recommended that the ASC recognizes that regional interpretation of the objective/intent of protecting salmon outmigration from sea lice infestation from farmed salmon can be provided in other ways than a direct requirement to achieve the metric of 0.1 mature females per fish. Factors that are considered important in BC Canada include; an extended outmigration period for the range of Pacific salmon encountered; limited access to alternative treatment types causing greater farm and regulator interest in ensuring over-use of a single product is avoided to avoid resistance; that IPM is limited due to reliance on one treatment type; that legally ensuring safe trigger levels are established with a legal basis.

Therefore, we recommend that Monday Rocks farm to be certified with a higher sea lice trigger based on the legal definition of 3 motile lice per fish within the context of clause PI 3.1.7.
Determination
Decision of the request Effective date
Variation approved March 28, 2016
Rationale
The Variance Request seeks to vary from the maximum on-farm lice levels during the sensitive period of wild fish as is defined in the Standard (i.e. 0.1 mature female lice  per farmed fish) and proposes to adhere to the Pacific Aquaculture Regulation instead. In this regulation, no maximum lice level is set, but instead a metric threshold trigger (3 motile lice ) is defined that, if exceeded, requires prompt management action to reduce lice levels accordingly.

Although, conceptually, this approach varies in a certain degree from the ASC approach (i.e. a maximum lice level), there is the realisation that the overall appropriateness of Indicator 3.1.7. demands review and revision given the vast differences between North East Atlantic conditions and North East Pacific conditions. This review and revision process has started and can be followed via https://www.asc-aqua.org/what-we-do/our-standards/new-standards-and-reviews/op-reviews/3-1-7/.

Adhering to (the current) Indicator 3.1.7 in the context of British Columbia will result in the need for more treatments, thus leading to an increased chance of resistance built-up and environmental discharge of chemicals.

In light of the above, ASC approves this VR on the following conditions:
  • i.    Since no maximum sea lice limit is set as part of the Pacific Aquaculture Regulations, a conflict arises with the intent of the ASC Salmon Standard (in which a maximum limit is set). Therefore, a maximum limit of 3 motile sea lice (L. salmonis) per farmed fish, shall be applied.

    As such, for farms seeking to apply VR 88 and/or VR 141, Indicator 3.1.7 must be read as follows:
Indicator:
Requirement:
3.1.7 In areas of wild salmonids, maximum on-farm lice levels during sensitive periods for wild fish47. See detailed requirements in Appendix II, subsection 2.     3 motile  lice per farmed fish
  • ii.    If the maximum limit as per i) is exceeded, the UoC shall inform (see also CAR 4.9.4.12) the CAB by the next working day after the last day of a “Counting Event”. Details regarding what entails a Counting Event are outlined in Appendix VI of the “Marine Finfish Aquaculture License under the Fisheries Act”.

  • iii.    If the maximum limit as per i) is exceeded, the UoC shall bring the on-farm lice levels below the maximum limit within 42 days upon exceedance.

  • iv.    If the UoC fails to bring on-farm lice levels below the maximum limit within 42 days, the UoC shall not sell the fish as ASC certified.

  • v.    Farms shall adhere to Appendix VI (item 14) of the ASC Salmon Standard for required data reporting.

  • vi.    The CAB shall report performance levels as required in the audit report template.
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