PRV: DFO Doesn't do Evidence and Science, nor Precautionary Principle

As we all know, DFO likes to say it uses 'evidence and science' to make decisions. Well the PRV case is one where it refuses to test fish, refuses to act in accordance with a court decision requiring it to change policy and test for PRV (twice), and has now put off the decision until the month of the federal election, October, in Canada, by saying it will consult with Indigenous people - even though they had four months from the Feb decision to do so, and didn't.

Here is the June 4th take: https://www.facebook.com/alexandra.morton.1671/posts/2469478909947322

Here is one of several posts I have done on DFO refusal to use evidence and science: https://fishfarmnews.blogspot.com/2019/05/dfo-does-not-use-evidence-and-science.html.

Here is another on refusal to use E&S: https://fishfarmnews.blogspot.com/2019/02/evidence-and-science-based-decisions-at.html.

And a third on refusal to use E&S: https://fishfarmnews.blogspot.com/2019/02/transparency-in-fish-farming-well-no.html.

These three list more than a dozen cases of refusal to use E&S by DFO. I can go back in my files and find many others, but feel that a dozen cases prove the point.

Now, moving on, is it just me or do you think they will take a negative decision - as in more non-evidence and more non-science so close to the election? Sorry to be cynical, but it is unlikely this case is moving forward in 2019. Let's all vote Green and boot the Liberals out of BC. They know they are going to lose Alberta, but they may well lose BC, too. (Kinder Morgan, Bill C-48, killing off wild salmon and killer whales...).

Now, here is some history about the PRV case worked on by Ecojustice: https://www.ecojustice.ca/case/protecting-wild-salmon-from-piscine-reovirus/.

"Specifically, Ecojustice said, the minister’s practice contravened Section 56 of the Fishery (General) Regulations, which states that the minister cannot issue a transfer licence for fish that “have any disease or disease agent that may be harmful to the protection and conservation of fish.” The Federal Court agreed.

"In a 200-page decision issued in February 2019, the court ruled that the minister’s PRV policy is illegal for several reasons. Critically, it found that the PRV policy does not comply with the precautionary principle. This important principle says that, whenever possible, harm to human health and nature must be prevented before it happens — particularly in situations in which scientific understanding of potential risks is incomplete.

In its decision, the court gave the minister four months to come up with a new, precautionary, and science-based policy. That is the June 4, 2019 date they have just passed doing nothing except sending in DFO lawyers to extend 'consultations' to October.

And do remember that BC is the only jurisdiction on the Pacific coast that allows fish farms in the water. Alaska, Oregon, California have none, and Washington outlawed them after the Cooke Aquaculture escape of 263,000 Atlantics in 2017. 

Here is some more: "PRV is highly contagious and research shows that it is present in up to 80 per cent of farmed salmon."

Now, "The court’s decision in this case made it clear that, in order to do this [protect wild salmon], the minister must use a precautionary and science-based approach to protecting wild salmon — especially when there is a risk of transmitting a potentially deadly virus or disease."

This, below, is the evidence and science for the PRV/HSMI, jaundice/anemia in BC, by, DFO scientists no less, but DFO ignores this further case of E&S - it includes Di Cicco and Miller et al, among other scientists.


"Abstract

Piscine orthoreovirusStrain PRV-1is the causative agent of heart and skeletal muscle inflammation (HSMI) in Atlantic salmon(Salmo salar). Given its high prevalence in net pen salmon, debate has arisen on whether PRV poses a risk to migratory salmon, especially in British Columbia (BC) where commercially important wild Pacific salmon are in decline. Various strains of PRV have been associated with diseases in Pacific salmon, including erythrocytic inclusion body syndrome (EIBS), HSMI-like disease,and jaundice/anemia in Japan, Norway, Chile and Canada. We examine the developmental pathway of HSMI and jaundice/anemia associated with PRV-1 in farmed Atlantic and Chinook (Oncorhynchus tshawytscha) salmon in BC, respectively. Insituhybridizationlocalized PRV-1 within developing lesions in both diseases. The two diseases showed dissimilar pathological pathways, with inflammatory lesions in heart and skeletal muscle in Atlantic salmon, and degenerative-necrotic lesions in kidney and liver in Chinook salmon, plausibly explained by differences in PRV load tolerance in red blood cells. Viral genome sequencing revealed no consistent differences in PRV-1variantsintimately involved in the development of both diseases, suggesting that migratory Chinook salmon may be at more than a minimal risk of disease from exposure to the high levels of PRV occurring on salmon farms."

This is the link to the PRV/HSMI paper: https://www.psf.ca/sites/default/files/ISH%20Manuscript%20%2B%20Suppl%20mat.pdf.

Moving on, the Vancouver Sun had this to say about the victory for wild salmon: "The court ruling stated that PRV is a highly infectious virus, first discovered in Norway in 2010. It is now also present in waters off the UK, Ireland, Chile, the U.S. and Canada. It is found in B.C. in both wild and farmed salmon."

This is the Sun link, Feb 2019: https://vancouversun.com/news/local-news/court-quashes-government-policy-not-to-test-baby-farmed-salmon-for-disease.

The Sun gives you a take for the general reader, so for most it is worthwhile reading.

So, we have established that PRV is nasty, DFO won't test for it, and it's unlikely they will get to this before the October federal election -  after all there are hundreds of thousands of BC residents against fish farms. 

And, who is for fish farms you ask? Well, the total employment is 1,800 according to the BC government's own statistics in the BC Stats Report update to 2019. That is about half of one percent, as in less than 1% of those against fish farms.

See: https://fishfarmnews.blogspot.com/2019/03/mar-21-2019-bc-stats-report-2016.html.

Now, the final thing is getting a better handle on what the precautionary principle means.
 
Fortunately, in the BC Agriculture Minister's finfish committee (it had fish farms on it) Tony Allard, who is a lawyer, wrote a good long piece on the principle, in their voluminous report. Lots of arguing in this committee, I'll bet.

Here is my summary of his take on the precautionary principle: https://fishfarmnews.blogspot.com/2018/10/precautionary-principle-has-defined.html. 

You can read it for a shortened and to the point take, and then go to the whole version if you want more pain, er, depth.

And here is what it means:  

Allard's summary: "The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk, even if there is scientific uncertainty."

After the east coast cod collapse (a lot like what is happening in BC now with the west coast salmon collapse, and DFO in Ottawa): "The Oceans Act was passed in 1996 to ensure that such a catastrophe never occurred again in Canada. The Oceans Act extended Canada’s jurisdiction over marine waters and required an ecosystem approach to the management of the marine environment based on the precautionary principle"

And: Allard points out that: "Canada’s Policy for the Conservation of Wild Salmon expressly requires the precautionary principle to be applied with respect to the conservation of wild salmon"

And: "The precautionary approach, defined in the Oceans Act as “erring on the side of caution,” is a key principle to be applied in the management of ocean activities."

And: "...the framework that government must use includes the following: "The application of precaution is distinctive within science-based risk management and is characterized by three basic tenets: the need for a decision, a risk of serious or irreversible harm and a lack of full scientific certainty.145"

And: ""Since the Framework provides a series of principles a decision-maker must follow to protect the environment, it is not surprising that the Framework makes it expressly clear that any impact on the assessment of trade occurs only after the decision- maker has determined the level of protection is consistent with society’s values. Accordingly, the Framework’s last principle makes it clear that the impact on trade is to be considered only after the decision to apply precautionary measures has been made"

And: In closing, Allard puts it this way: "The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk even if there is scientific uncertainty."

And that the minister must do what is reasonable, not what he thinks is reasonable, but what the situation requires as the most reasonable outcome, such as putting fish farms on land."

And, thus industry claims of wasted investment are not valid.

Finally, you may know that my list of on-land fish farm systems now sits at 281 such RAS systems: https://fishfarmnews.blogspot.com/2016/05/152-different-on-land-fish-farm-systems.html. 

Yes, that is nearly 300 on-land fish farm systems. This is a no-brainer, even for a fish farm, because they can continue to operate in BC with their present employees, only now on land.

If only DFO were sufficiently illuminated. "DFO build an on-land fish farm in Ottawa, just don't use BC/Iceland stocks of eggs/fry because you'll get PRV/HSMI."

Come on, that's funny.

Remember, it's only four months to the election: Vote No to Liberals. "You voted no to wild salmon by voting no to PRV testing, so we are voting no to you." 

***

Hold on a sec while I lift myself up from the floor after I fell out of my chair. DFO says it will test for PRV:  https://www.cbc.ca/news/canada/british-columbia/testing-bc-fish-farms-prv-virus-1.5163032?utm_source=Watershed+Watch+Email+List&utm_campaign=73bdaa2444-EMAIL_CAMPAIGN_2019_06_05_10_07&utm_medium=email&utm_term=0_405944b1b5-73bdaa2444-166907249&mc_cid=73bdaa2444&mc_eid=5777c92bcd.

The only thing is that its 'report' that showed PRV doesn't affect Fraser sockeye was panned by experts on the committee because DFO would not give them the research to look at before it, on their behalf, said the experts agreed PRV doesn't affect Fraser sockeye.

Hmm. Read Stan Proboszcz' rebuttal to DFO on this one: https://fishfarmnews.blogspot.com/2018/02/new-science-copmmittee-dont-bother.html. This one has Stan's take on the 'non science' from DFO on sockeye, two links, actually.

And on science in general at DFO:  https://policyoptions.irpp.org/magazines/april-2018/integrity-of-the-dfos-science-advisory-process-in-question/.

And Brian Riddell's response to the Rapid Science Response: https://fishfarmnews.blogspot.com/2018/11/fake-science-by-dfo-riddell-response.html.

Well, I'll fall off my chair again, if DFO finds no problem from PRV when DFO has already found a problem with PRV.

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And... I fell off my chair, yet again, with the news, just in, Feb 11, 2020:  
 
Here in BC, DFO has refused scientific evidence on harm and killing of wild salmon by PRV four times now:  https://alexandramorton.typepad.com/alexandra_morton/2020/01/the-virus-prv-brings-out-the-worst-in-dfo.html?fbclid=IwAR1RVl5HttXekuttvJChNOwu51SufY3oxLT3uc7hZ_TScKjBL5nyr0siMuE.