Does Fisheries and Oceans Canada’s (DFOs) science advisory process have integrity when tasked with answering questions on salmon farming? If there is any hope of changing the trajectory of many iconic but endangered wild salmon stocks, there must be a resolution to political and industrial interference that continues to influence fisheries science advice at the federal level.
Since 2001, a scientific debate has been active in British Columbia around parasitic salmon lice from open-net salmon farms and their impacts on wild fish. Two “camps” of scientific opinion have been obvious. On one side, academics and NGO scientists have published articles in peer-reviewed journals detailing the negative effects parasites from salmon farms can have on migrating wild salmon. On the other, government and industry-supported scientists have published papers that cast doubt on these conclusions, thereby fuelling the debate and encouraging the continued operation of salmon farms on wild fish migration routes.
It is well established that manufacturing a scientific debate on the impacts of smoking and climate change benefits tobacco and petroleum companies. Some believe the salmon-farming debate is not very different.
The DFO is the regulator of the salmon-farming industry, but it also promotes the industry and their products. These dual roles were identified by the 2012 federal Cohen Commission on the decline of BC salmon stocks as a potential conflict of interest that may impede DFO’s ability to protect wild fish stocks. Justice Cohen recommended that the federal government remove industry promotion from DFO. An expert panel of the Royal Society of Canada reached a similar conclusion — that DFO’s conservation of biodiversity may be impeded by its relationship with industry. More recently, DFO scientist Kristi Miller broke ranks and testified to a parliamentary committee, raising concern the agency’s science may be influenced by the industry. Despite this, and a commitment by the prime minister to implement all of Justice Cohen’s recommendations, no known action has been taken to remove the salmon-farming promotional mandate from DFO.
Meanwhile, the salmon-farming debate continues. Evidence uncovered by the Cohen Commission rekindled the feud around the impacts of the industry. The subject this time: viruses.
DFO’s scientific stance seems to diminish the relevance of a particularly worrisome virus — piscine reovirus (known as PRV) — as a risk to wild salmon. As in the salmon lice debate, DFO appears to favour Scientific Certainty Argumentation Methods (SCAMs). Environmental sociologist William Freudenburg, who coined the term SCAMs and studied their use in the climate change debate, wrote:
Given that most scientific findings are inherently probabilistic and ambiguous, if agencies can be prevented from imposing any regulations until they are unambiguously “justified,” most regulations can be defeated or postponed, often for decades, allowing profitable but potentially risky activities to continue unabated.
Within the context of SCAMs, we can compare three conclusions from DFO’s 2015 CSAS report on PRV with more recent published conclusions from academics, NGO scientists and Kristi Miller’s lab.
- 2015 DFO conclusion 1: “There is no evidence from laboratory studies in British Columbia and Washington State that PRV infection is associated with any disease state, including HSMI [heart and skeletal muscle inflammation]”
Wessel et al. 2017: PRV can cause heart and skeletal muscle inflammation
- 2015 DFO conclusion 2: “HSMI has not been reported on BC salmon farms”
Kristy Miller’s lab 2017: HSMI was reported on BC salmon farms in 2017
- 2015 DFO conclusion 3: The information suggests “a low likelihood that the presence of this virus in any life stage of farmed Atlantic and Pacific Salmon would have a significant impact on wild Pacific Salmon populations.”
Morton et al. 2017 Salmon farms may spread PRV to wild salmon and impede their ability to migrate upstream and spawn.
Mirroring the salmon lice debate, DFO’s PRV conclusions appear to exploit the uncertainty around the evidence and steer away from exercising precautionary action to protect wild fish. The 2015 DFO report ends with unsubstantiated platitudes about BC’s “robust” disease surveillance program that purportedly minimizes the threat of diseases spreading from farms to wild fish. It appears DFO’s premier peer-review science advisory process, CSAS, produced premature conclusions that coincidently aligned with industry conclusions, but that are now in question. This raises the question: Is the salmon-farming industry influencing DFO’s CSAS?
Science advice on fisheries and habitat — CSAS
DFO is responsible for three oceans and thousands of lakes, rivers and species, and its decisions need to be informed by sound science. The Canadian Science Advisory Secretariat, established in the early 2000s, is headquartered in DFO and coordinates science review processes throughout the country with the goal of providing high-quality scientific advice to the minister of fisheries and oceans, managers and other interested parties. CSAS coordinates over 100 science advisory processes a year and responds to specific questions on various subjects, such as the state of fish stocks, species at risk and other fisheries issues. Federal scientists from DFO and other agencies typically comprise a significant segment of each advisory process; however, external experts are also invited to participate in the peer reviews.
CSAS and salmon farming
The Cohen inquiry had significant implications. It identified pathogens from salmon farms as a risk to wild fish and made several related recommendations. Two of particular interest state that salmon farms located along a key wild salmon migration bottleneck should be removed unless the minister of fisheries is satisfied they do not pose more than a “minimal risk of serious harm” to wild fish. The minister is also required to summarize the information relied on and include detailed reasons for the department’s decision. Cunningly, these recommendations shift the burden of proof and place them firmly on the federal government, if it insists on allowing farms to operate.
When the minister needed “detailed reasons,” a new series of CSAS processes was initiated, examining the risk of various pathogens from salmon farms on wild salmon. The first examined the risk of infectious haematopoietic necrosis virus (IHNV), another salmon virus. I was asked to sit on the steering committee as a representative of the conservation community. I accepted.
This CSAS meeting was held December 5-8, 2016, in Vancouver. It examined five technical papers. The first four covered oceanography, salmon-farm disease management practices, Fraser sockeye salmon biology and IHNV. The fifth drew on information from the other four and purported to examine the risk to wild sockeye salmon from IHNV arising from salmon farms. The final Science Advisory report was published days before Christmas 2017, over six months late.
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After participating throughout DFO’s CSAS process, I developed some recommendations for its future conduct.
(1) Separate CSAS from DFO: During the process, I witnessed several instances that suggested DFO scientists were hesitant to freely express views that might be unfavourable to industry. During the peer-review meetings, two DFO scientists quietly urged me to raise concern about the use of a confidential memorandum of understanding (MoU) among several salmon-farming companies. Allegedly, the MoU detailed voluntary industry disease management practices. The shocking thing was that this MoU was being used to substantiate a final conclusion in the CSAS report that there is reasonable certainty that an IHNV outbreak on salmon farms in the Discovery Islands is very unlikely. Yet an author of the report refused to provide access to review the MoU. The inability to review the details of substantiating information is contradictory to the fundamental principles of transparency and peer-reviewed science.
In another instance, a report author deferred to DFO aquaculture management staff several questions about possible constraints that may arise in their research due to the use of summarized farm data. I think that serious concerns arise when scientists do not feel free to answer questions about their research, whether it aligns with industry or not.
These two problems give rise to questions around political interference impeding good science advice, similar to those raised over the mismanagement and collapse of east coast cod stocks.
CSAS professes to follow the Government of Canada’s Science Advice for Government Effectiveness guidelines, yet seems to violate a stated core principle around transparency and openness.
Having a science advisory process that is at arm’s length from DFO could improve the integrity of the science advice produced on fisheries issues. Good advice is critical at a time when many salmon stocks are in decline.
(2) Make potential conflict of interest disclosure explicit and mandatory: After I experienced the CSAS process, it was apparent to me that some steering committee members, participants, report authors and reviewers had current or recent connections to the salmon-farming industry. Unlike many scientific journals, CSAS does not have explicit requirements for the disclosure of potential conflicts of interest. As a steering committee member, I requested that it include explicit conflict-of-interest criteria but was assured by the chair and lead organizer (who both held current and recent high-ranking DFO aquaculture management positions) that this was unnecessary. I was also assured that all steering committee members and participants would be listed in the final reports. No such list was published that I can see.
CSAS is supposedly based on DFO’s Values and Ethics Code, which states government will take “all possible steps to recognize, prevent, report, and resolve any real, apparent or potential conflicts of interest between our official responsibilities and any of our private affairs.”
I witnessed no explicit steps during the process.
Aside from direct financial benefits, there are many potential sources of conflicts of interest in science communication. The CSAS process should immediately integrate strong conflict-of-interest disclosure requirements for all participants, authors and steering committee members.
The long-standing scientific debate around salmon farming and around CSAS and DFO’s potential conflicting interests requires immediate resolution. In February 2018, it was announced that Minister of Science Kirsty Duncan has asked Canada’s chief science adviser, Mona Nemer, to lead an independent expert panel on the appropriate use of scientific evidence in decision-making around protecting the marine environment, as it relates to salmon farming. More recently it was revealed that the “independent” panel will be substantially supported by DFO staff. Time will tell what Canadians will get from yet another investigation into the salmon-farming industry. Canada’s commitment to science-based decision-making and to iconic wild salmon are at stake.
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