Mortality – the issue that just won’t die

In January 2025, nine MSPs on the Rural Affairs & Islands Committee (RAIC) finished their follow-up inquiry, focussing on four themes of fish health and welfare, environmental impact, interactions between wild and farmed salmon, and the location of fish farm sites.

The RAIC was checking progress from an earlier inquiry in 2018 during the previous session of the Scottish Parliament, conducted by its predecessor, the Rural Economy & Connectivity Committee (RECC), which set out 65 recommendations and required urgent action.

When, six years later, the RAIC’s follow-up inquiry revealed its findings, they could be summed up in one word: “disappointment”. Its overarching conclusion was that “the slow rate of progress in improving the regulation and enforcement of the Scottish salmon farming industry needs to be addressed as a matter of urgency, to future-proof the industry and enable it to grow sustainably”.

Its key recommendations on fish mortality, which became the focus of most debate, stated: “Powers to be given to the Fish Health Inspectorate (or another appropriate body) to limit or halt production at sites which record persistently high mortality rates. The Scottish Government should work with industry and regulators to agree appropriate criteria and mortality thresholds for the use of these powers.

“The publication of comprehensive, consistent and transparent mortality figures that include the number of fish at a farm, the freshwater and seawater mortality, per facility, with accurate numbers of dead salmon, wrasse and lumpsuckers per week and with cumulative mortality totals at the end of each production cycle.”

As a spur, the RAIC rejected calls for a moratorium on new and expanded fish farm sites – for now – unless the Scottish Government and industry could show sufficient progress within a year.

We heard the first 12-month progress report on February 25, from the Scottish Animal Welfare Commission, Animal and Plant Health Agency, Scottish Environment Protection Agency (SEPA), Fish Health Inspectorate, Fisheries Management Scotland, and the trade body Salmon Scotland, via a director Ben Hadfield, as covered in last month’s Fish Farmer.

Then, on 11 March, it was the turn of the Cabinet Secretary for Rural Affairs, Land Reform and Islands, Mairi Gougeon, to face MSPs, just before the Parliament dissolved for the May election, when Ms Gougeon will be standing down. 

Tough questions were asked by MSPs from all parties present, particularly by the Highlands & Islands’ Emma Roddick (SNP) and Ariane Burgess (Green), but some of the toughest that day came from those in the Conservative opposition. 

A fortnight later we got the RAIC’s verdict, and we heard that same refrain again, “disappointment” – but not so much that the MSPs called for a moratorium. 

Ms Gougeon, SNP MSP for Angus North and Mearns, began the day of Q&As by listing the Scottish Government’s progress. She said: “Given the concerns that some sites were experiencing persistent high mortality, Scottish Government scientists, fish health experts and policy officials have worked at pace to deliver a robust analytical framework to determine whether such sites exist, what actions are being taken by producers to tackle such mortality and, ultimately, to evidence whether further government intervention is required beyond our existing regulation.

“The preliminary conclusion is that persistent elevated mortality is not a systemic issue for Scottish marine salmon sites. Only a small fraction of sites were identified as having such mortality, and the work showed that all producers already take a considerable range of responsible and prompt actions to tackle and reduce persistent mortality where it occurs. As a result, I do not believe that further regulatory action is warranted at this time. It is still the Scottish Government’s position, which is shared by the industry, that mortality should be managed to the lowest possible levels.

“On fish welfare, I have already committed to progressing welfare standards for farmed fish under the Animal Health and Welfare (Scotland) Act 2006. Delivery will be progressed this year, [with] guidance that is both robust and operationally feasible. We are also strengthening enforcement of farmed fish welfare by working with the Animal and Plant Health Agency to increase the number of trained fish inspectors and the number of inspections that are carried out per year.

“To improve transparency across the sector, SEPA has updated the Scotland’s Aquaculture website to provide better access to important data and information. We have published a mortality data topic sheet to enhance the understanding and use of all the data that is published regarding fish health.

“On spatial planning and consenting, we have delivered on a programme for government commitment to confirm that local planning authorities are responsible for fish farm planning controls and to confirm SEPA as the lead regulator for fish farm discharges within the three to 12 nautical mile zone, thereby future-proofing regulation as fish farms look to move into more exposed locations.

“We have also adopted Scotland’s first regional marine plans: the plan for the Shetland islands region, which we adopted in December last year, and the plan for Orkney, which we adopted in February this year. The adoption of those plans, which marks a significant milestone for marine planning in Scotland, enables a community-led approach to be taken to marine spatial planning, to reflect local circumstances.

“We have also continued to work with SEPA to implement a monitoring programme to support the sea lice regulatory framework. The programme, which is examining sea trout on the west coast, the Western Isles and Orkney, was implemented last year, and, this year, it will be enhanced through the support of the Scottish Government. Although there are appeals relating to elements of SEPA’s framework, appeal mechanisms are part of a fair consenting system, and due process will be followed.”