Marine Scotland - use of hydrogen peroxide in fish farming: EIR release

Information requested

Question 1
You will see that SEPA has not commissioned research into the time period Hydrogen Peroxide remains sufficiently active in seawater to impact on the health of wildlife and specifically crustaceans, but they sent on the literature list, which is also annexed. 

Has Marine Scotland commissioned any such research and if so please supply copies of any report(s).

Question 2
You will see that SEPA has not engaged in correspondence, nor had meetings with, operators of fish farms about the use of Hydrogen Peroxide in general or at particular locations, about the extent to which its use may be damaging to the natural environment, or about limiting or prohibiting its use in future. 

Has Marine Scotland done so? Further, has Marine Scotland discussed the use of H2O2 with any industry bodies such as the SSPO or with the Scottish Aquaculture Innovation Centre? If so please supply copies of such correspondence, whether in writing or by email, notes of telephone conversations and notes of meetings.

Question 3
Does Marine Scotland have plans to set maximum limits on the use of Hydrogen Peroxide in open cage environments? If so, please supply details.

Onsite treatments using well-boats and/or hydrolicer devices.

Question 4

We are concerned that treatments in wellboats and the Hydrolicer and similar devices are currently totally unmonitored and unregulated and that following completion of such treatments it seems that the residual waste water, containing toxic chemicals that may be dangerous to wildlife is being discharged into the sea, rather than, for example, being retained for safe disposal on land. Is this correct?

Question 5
Such waste will obviously include large numbers of mature sea lice, not all of which (unlike many of the salmon) may have been killed in the process.

What information does Marine Scotland hold regarding the potential for sea lice to survive such treatments? Please supply copies of any papers or reports held by you on this.

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations.  We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA. 

This exemption is subject to the ‘public interest test’.  Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption.  We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes.  This is essentially a technical point and has no material effect on the outcome of your request.

The following 5 sections provide responses that relate to the 5 questions from your request.

1. The information you have requested is available from http://www.sarf.org.uk/cms-assets/documents/227037-611185.sarfsp001---review.pdf.

2. While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested. Therefore we are refusing this part of your request under the exception at regulation 10(4)(a) of the EIRs. This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about the use of hydrogen peroxide and “the extent to which its use may be damaging to the natural environment, or about limiting or prohibiting its use in future”, clearly we cannot provide information which we do not hold.

In answer to the second part of your question, regarding discussion with “any industry bodies such as the SSPO or with the Scottish Aquaculture Innovation Centre”, Marine Scotland carried out Scottish Aquaculture Research Forum (SARF) commissioned work and the information is available at http://www.sarf.org.uk/sarf-sp001.php and http://www.sarf.org.uk/sarf-sp005.php. 

In addition to this, a workshop was held at the premises of the SSPO in Perth on the 18th of November 2014. Comments from industry are provided in the document provided with this response (see document 001).

3. While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested because Marine Scotland regulates the discharge of hydrogen peroxide from wellboats adjacent to fish farm cages. Therefore we are refusing this part your request under the exception at regulation 10(4)(a) of the EIRs. This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about maximum limits on the use of hydrogen peroxide, clearly we cannot provide information which we do not hold.

In answer to the second part of your question, regarding “onsite treatments using well-boats”, Marine Scotland does not currently have plans to set maximum limits on the use of hydrogen peroxide.  

4. Marine Scotland regulates the discharge of hydrogen peroxide from wellboats adjacent to fish farm cages under Part 4 of the Marine (Scotland) Act 2010. No person may discharge a chemotherapeutant, including hydrogen peroxide, from a wellboat except in accordance with a marine licence granted by the Scottish Ministers. A marine licence to discharge hydrogen peroxide, from a wellboat is granted subject to conditions including the requirement for a licensee to maintain a log of operations for each discharge operation and provide this information to Marine Scotland on request.

5. Marine Scotland carried out Scottish Aquaculture Research Forum commissioned work and the information is available at http://www.sarf.org.uk/sarf-sp001.php.

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.

foi-19-00723 Document 001

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