The curious case of the great salmon escape that wasn’t…

Scottish Ministers again failing to comply with FOI law over mysterious 2016 salmon farm escape of 300,000 fish that company now says never happened….

The reporting of the disappearance of 300,000 farmed salmon in 2016, understood at the time to be the industry’s biggest escape in many years, raises serious questions about the oversight and regulation of salmon farming and Scottish Government’s dubious record on transparency.

In June 2016, The Scottish Salmon Company reported that it believed about 300,000 salmon, with an average weight of 623g, had escaped from its Scadabay farm on Harris.

Over the next 18 months the company’s financial reports, SEPA’s biomass records, Marine Scotland’s Annual Production Survey, Scotland’s Aquaculture website and various industry websites consistently maintained that this major escape had indeed occurred (2).


Salmon Escapes Removed From Database

However, in early 2018, just as the Scottish Parliament’s Environment Climate Change and Land Reform (ECCLR) Committee was beginning to investigate the Environmental Impact of Salmon Farming, the escapes database on the official Scotland’s Aquaculture website was amended to record an escape of zero fish at Scadabay in June 2016.

Guy Linley-Adams, for Salmon and Trout Conservation Scotland (S&TCS), said:

“Whatever the true facts as to what went on here, the removal of a 300,000 escape in 2016 from the datasets did have the effect of improving dramatically the industry’s official record on escapes.”

 Mr Linley-Adams continued:

“There have also been unexplained delays, over many months, by the Fish Health Inspectorate (FHI) and Scottish Government in providing paperwork under Freedom of Information law to help clarify what has occurred.”

S&TCS asked the FHI for copies of relevant inspections conducted in 2016 at the Scadabay farm, which unusually still remained unpublished on the FHI’s Case Information website, but these were not supplied by FHI until after a referral was made to the Scottish Information Commissioner.

Those reports have now been disclosed, in redacted form, to S&TCS. Other requested information – such as a letter from the company concerned to Scottish Government, sent in late 2017 – remains unpublished.

One of the FHI reports from June 2016 notes that the suspected loss of fish “is thought to have occurred during the storms at the beginning of 2016” and that “a new fish counter was used which could reported account for slight discrepancy in fish numbers, but not the 332,372 that are unaccounted for”.

However, an update to the FHI inspection reports records that a letter from The Scottish Salmon Company, sent to Marine Scotland in Edinburgh on 16th November 2017, a year and a half after the “escape”, states that the company had concluded that it had lost no fish and that the most likely reduction in biomass was caused by early mortality that was undetected due to adverse weather conditions.

Andrew Graham-Stewart, Director of S&TCS, said:

“To say, 18 months after the event, that there was a mass mortality rather than an escape is stretching credulity to breaking point. There must be serious questions about the standards of husbandry when the deaths of 300,000 fish go unnoticed.”

Guy Linley-Adams, for S&TCS, added:

“Irrespective of whether 300,000 fish escaped in June 2016 or just died in the cages – and   whatever the reason for the apparent discrepancy in reported fish numbers and biomass at the Scadabay farm – taking almost two years to assess whether or not such a massive escape or mortality had actually occurred raises serious questions.

If these fish had either escaped or just died in June 2016, presumably 300,000 fewer fish eat a lot less feed as they grow?  Was this not noticed before the site started harvesting or the letter apparently reporting a ‘zero’ loss was finally sent in November 2017?

Whatever the facts or what has occurred here, what we can say is that this demonstrates that current regulation of fish farms is not fit for purpose.”


Salmon Escapes a 'Cause For Concern'

The Scottish Government has acknowledged for some time that “escapes from fish farms are a cause for concern….for conservation and wild fish interests, escaped fish may represent a disease hazard, occupy valuable habitat to the exclusion of wild fish and have the potential to interbreed with wild fish, leading to dilution of genetic integrity”.

The Convention for the Conservation of Salmon in the North Atlantic Ocean (NASCO) aims to minimise impacts from aquaculture on wild salmon stocks.

The NASCO Williamsburg Resolution (4) lays down measures to minimise the impact of aquaculture with respect to escapes. Each party, including the UK, is required to take measures to minimise escapes of farmed salmon to a level that is as close as practicable to zero.

The number of escapes of farmed Atlantic salmon in Scotland remains stubbornly high.

S&TCS’ information requests over the Scadabay “escape” had to be referred to the Scottish Information Commissioner who has just issued yet another Decision against Scottish Ministers in favour of S&TCS in relation to the failure by FHI to comply with the Environmental Information (Scotland) Regulations 2004.

This decision adds to another seven decisions from the Scottish Information Commissioner that S&TCS has obtained in just 15 months concerning requests about salmon farms that have not been answered by Scottish public authorities in compliance with the law (3).

 Guy Linley-Adams commented:

“While we welcome this latest decision, the Scottish Information Commissioner has required Scottish Ministers to consider whether it would be appropriate to apologise to S&TCS for their failure to comply with the statutory timescales for response. 

I would just note that this is not the first time.

In lay terms, Scottish Ministers simply being told to say sorry, and do what they should have done many weeks or months ago, does not yet appear to be having the desired effect of ensuring they comply with the law on freedom of information.” 


Issued by Andrew Graham-Stewart (telephone 01863 766767 or 07812 981531) on behalf of Salmon and Trout Conservation Scotland. For further information, call Guy Linley-Adams on 07837 881219.


Notes for editors


1) Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in both England and Scotland (where it operates as S&TC Scotland) and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

2) The Scadabay “escape”

In June 2016, it was initially reported by The Scottish Salmon Company that about 300,000 fish, with an average weight of 623 g, had escaped from its Scadabay farm on Harris.

On 28th November 2016, The Scottish Salmon Company ‘Final Notification’ to the FHI indicated the numbers lost were still “unknown”, and noted “the inconclusive results from  investigation”, but biomass data for the Scadabay farm held by the Scottish Environment Protection Agency shows a drop in reported biomass at the farm of some 199 tonnes between April and May 2016, which would broadly match the loss reported to FHI.

The Scottish Salmon Company itself, in its own Quarter 2 and First Half Year Report for 2016, published on 24th August 2016, had reported on the escape:

“Operating costs for the quarter are £23.5m (Q2 2015: £26.80m) (a cost per kg of £3.68 compared to £3.27 in Q2 2015) and have been affected by losses at one site, in the Hebrides, which is currently under investigation. While the average fish size was around 600 grams, this together with smaller losses at other sites, represents a loss in harvest volumes of around 1800 tonnes which will impact Q4 2016 and the start of 2017. The site which is in a particularly remote location, was affected by unseasonably poor weather during the first part of the year. We have undertaken a review of infrastructure, processes and configuration to mitigate the risk”.

“We have adjusted our annual target for this financial year to around 26,000 tonnes. This is a combination of the lower than expected harvest volumes in the year to date due to biological issues and the impact of the losses at our site in the Hebrides. We are also reviewing our strategy in relation to 2017 in response to these losses”.

Biomass data for the Scadabay farm held by the Scottish Environment Protection shows that the site’s peak biomass, that occurred in November 2016, was still some 500 tonnes lower that the CAR licence issued by SEPA actually permits at Scadabay.

The site had completely harvested out by April 2017 and was fallow from May 2017 to at least March 2018 (the last month for which biomass data has yet been published).

Marine Scotland’s 2016 Production Survey, published in September 2017, was still reporting a total of 311,496 fish reported as escaped in 2016, which included the Scadabay loss.

In October 2017, the Scotland’s Aquaculture database was also still reporting 300,000 fish lost.

In December 2017, it was also still being reported by industry websites that “The Scottish Salmon Co.’s Scada Bay grow-out was pounded by bad May weather until it released 300,000 fish of 625 grams”.

3) In respect of the information on Scadabay, the Scottish Information Commissioner has now issued another decision* against Scottish Ministers for their failure to comply with freedom of information law. (Decision 120/2018: Salmon and Trout Conservation Scotland and the Scottish Ministers | Scadabay Inspections: failure to respond within statutory timescales | Reference No: 201801191 |Decision Date: 6 August 2018).

This is now added to seven other decisions obtained in the last 15 months by S&TCS concerning requests about salmon farms that have not be answered by Scottish public authorities in compliance with the law.

43/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation relating to the use of sea lice medicineFor applicant26 Mar 2018
013/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyCorrespondence with Marine ScotlandFor applicant31 Jan 2018
010/2018:Salmon and Trout ConservationScottish Environment Protection AgencyReport on the environmental impact of sea lice medicineFor applicant29 Jan 2018
199/2017Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation concerning sea lice medicineFor applicant30 Nov 2017
191/2017Salmon and Trout Conservation ScotlandScottish MinistersReport on the environmental impact of sea lice medicineFor applicant20 Nov 2017
142/2017Salmon and Trout Conservation ScotlandScottish MinistersControl and reduction of sea lice on fish farmsFor applicant04 Sep 2017
063/2017Salmon and Trout Conservation ScotlandScottish MinistersControl of sea lice on fish farms: failure to respond within statutory timescalesFor applicant02 May 2017

4) The NASCO Williamsburg Resolution

Resolution by the Parties to the Convention for the Conservation of Salmon in the North Atlantic Ocean to Minimise Impacts from Aquaculture, Introductions and Transfers, and Transgenics on the Wild Salmon Stocks - The Williamsburg Resolution (Adopted at the Twentieth Annual Meeting of NASCO in June 2003 and amended at the Twenty-First Annual Meeting of NASCO in June 2004 and at the Twenty-Third Annual Meeting of NASCO in June 2006.