This document contains the Canadian Food Inspection Agency's new plan to test for ISA, IHN, and IPN, but not Marine Anemia in BC:
http://www.inspection.gc.ca/animals/aquatic-animals/diseases/reportable/isa/eng/1327197013896/1327197115891.
Since before the Cohen Commission testimony in December, the CFIA, that has a conflict of interest over testing wild Pacific salmon because they deal only in foreign trade issues of farmed salmon, has repeatedly dug in its he
els and continued to say the same thing about ISA in BC that they have said all along. That is that they changed the Moncton lab's assessment of a faint positive ISA test in one of 49, sockeye fry samples - samples the lab admitted were too degraded for testing - into a negative result for ISA. The CFIA ignores the hundreds of positive tests by the world expert labs, including, Kibenge, Miller and Nylund.
And here is an article, one of many, regarding a Cooke Aquaculture infection of ISA right now in Nova Scotia:
http://www.globaltoronto.com/canada/suspected+outbreak+of+salmon+virus+at+nova+scotia+fish+farming+operation/6442583545/story.html. The CFIA, rather lately, has now admitted that Cooke has ISA, Mar 10:
http://www.inspection.gc.ca/about-the-cfia/newsroom/news-releases/infectious-salmon-anaemia/eng/1331155048243/1331155084131.
Its backing up the farm for being good enough to slaughter the fish -
that we as taxpayers pay for - means everything is A OK and business as usual. This will not work in BC with our five species of salmon, and those of a dozen countries.
Then the post brought in more Kibenge tests of Morton procured salmon - in March, 2012. Five of 21
farmed Atlantic salmon sold in a small BC chain store have tested positive for ISA and one more chum carcass in the Vedder River has tested positive:
http://www.inspection.gc.ca/about-the-cfia/newsroom/news-releases/infectious-salmon-anaemia/eng/1331155048243/1331155084131. The CFIA does not admit these tests for BC. The situation is getting ridiculous, and strongly suggests that
the 4726 fish tested by the provincial system as negative for ISA need to be retested by Kibenge, Miller or Nylund. But there is more. Using the 'chain of custody argument the CFIA said the samples were too degraded to reach a positive result and has turned all of Morton's March ISA positive fish into negatives, and will use the Moncton lab to 'confirm' the OIE world stature lab.
The CFIA needs to be taken out of the ISA testing regime.
Here is my critique.
1. CFIA has a conflict of interest and should not lead this project. The Kim Klotins testimony and the Joe Beres email during the Cohen Commission hearings in December made it clear that the CFIA is only interested in suppressing ISA issues in farmed Atlantic salmon and that they view the issue as winning a PR war. What is required is independent officials and academics with no ties to fish farms.
The CFIA's stamping its feet and claiming ISA is not in BC - after Cohen - by continuing to say the Rivers Inlet sockeye fry exhibited no ISA (before Cohen) is not a truthful or complete and fair assessment of that testing. It changed its Moncton lab's finding of one faint positive and that the 49 samples of sockeye were to degraded to do accurate testing - to false readings.
Furthermore, it has refused to talk about the coho, chinook and chum positive ISA readings that were analyzed by the Kibenge and Nylund labs.
Kibenge and Miller, in Canada,
testified that they were intimidated by the CFIA.
2. The expression
'Industry led' testing needs clarification. If this includes the commercial fishing, the sport and the processing sector, conflict free academic, and environmental NGOs, aboriginals, officials from other countries, including the Pacific nations with Pacific salmonids, and the expert labs under Miller, Nylund and Kibenge, and freely allows individuals to collect samples for ISA testing, then have them tested, the input will contain those affected by this testing. And the process will have credibility.
But if the expression means fish farms only, it will have the conflict of interest that has always existed in fish farming and no credibility
3. Other partners include
DFO, its Moncton, and the BC testing system. Minister Ashfield has on several occasions said there is no ISA in BC and that testing has been negative, even though the Fraser River samples for coho and chinook were also positive.
DFO does not want to find ISA. Most importantly, DFO has a conflict of interest in promoting fish farms but also having responsibility for wild salmon. Richards opened the gates to ISA infected eggs on the ground that the fish farms might sue on restraint of trade, but she has no expertise in trade issues. Miller has found ISA all the way back to 1986.
The BC system was found to say it was using one PCR test for ISA, but was not using it. It also used a grad-student-developed probe/primer that was not peer reviewed. That means it could not find ISA, and the 4,726 fish so tested need to be tested by an expert lab. The 1100 recorded symptoms of ISA may likely be true and thus be ISA. And Marty has used Marine Harvest lice data to do a scientific study that was later shown to be wrong. This implies a conflict of interest, too.
The Moncton Lab was shown by the experts to not be able to find ISA, because their equipment was old and their procedures were not up to international standards. This is the lab the CFIA and DFO will rely on.
Furthermore, the CFIA has said previously that it won't allow testing paid for by individuals. This means that the citizens of BC will have to fund testing by Nylund in Norway.
4. The Exec Summary says
the wild, anadromous species known to be infectable will be tested in the first two years. The table on P 42 lists coho, steelhead/rainbow, sea trout/brown trout. Sea trout is an Atlantic Ocean term not used in BC, and CFIA seems not to know this. And there are precious few sea-run browns, if any, as BC does not acknowledge that these exist, an unintended outcome of stockings as much as 80 years ago. But
the list does not include chinook, chum, sockeye or pink salmon, nor does it include, Dolly Varden, herring, nor the bottom fish that may well be carriers.
Morton's tests with Kibenge and Nylund show sockeye, chum and chinook have ISA virus. See the Kibenge world spread of ISA document here:
http://www.oie.int/eng/A_aquatic/Docs/Presentations/1.11Kibenge.pptAnd Miller has shown that 25% of Clayoquot chinook have ISA. Her samples show ISA in sockeye from 1986, two years after Atlantic eggs began flowing into BC for fish farms.
5.
Farmed salmonids are also being targeted for surveillance activities. As the CFIA has a focus on suppressing disease findings because of its conflict of interest regarding foreign trade in farmed fish, there is no reason to accept its findings. Armslength testing by people and facilities that cannot be affected by the CFIA and reporting to the public are what is needed.
Certainly, when the farmed industry suggested to Miller that they would make their farmed Atlantics available for ISA testing, they then wanted management control of the project, wanted her to test for the parvovirus first, and access to farmed fish was taken off the table. She declined to be a part of this 'plan'. The CFIA was shown to accept, on a phone call basis with, fish farms when they said they did not have ISA. Unacceptable.
6.
The reporting of any positive findings will be done by notification to the appropriate stakeholder and industry groups and to the World Organization for Animal Health (OIE). As noted above, if the system is oriented to not finding ISA, there will be no ISA reported. And what does the term 'appropriate stakeholder' mean.
7.
ISAV and IPNV are not currently known to be present in British Columbia (BC). ISA is in BC and I will spend no more time on this counter-factual claim by the CFIA - except for one thing: the document goes on to say there is no ISAV in BC; this little switcheroo, is a semantic difference, meaning the disease is not present, even though the virus is here and brought from the Atlantic ocean for fish farms. Go read the OIE tables on what constitutes a disease presence:
http://www.oie.int/fileadmin/Home/eng/Health_standards/aahm/2010/2.3.05_ISA%20.pdf. Real proof is a viral isolate, but in ISA's case, this can be hard to achieve, hence, the odd conditions in the OIE manual for proving ISAV.
8.
Compartmentalization? What does this mean? That ISA can travel on the boots of humans, therefore, the route of infection cannot be traced to the Norwegian derivative fish farms in BC that also have farms in as many as 21 countries, and thus its own staff may have brought ISA in? Hard to say. But certainly, that is their stance after egg transfer company Aquagen was shown to have brought ISA to Chile - a $2 billion loss.
9.
Chain of custody of fish samples must be maintained. The CFIA means that anyone who does any collection and testing of ISA, as happened in the fall of 2011, outside of itself, is not valid. Good thing Morton, Kibenge (Fred and wife Molly), SFU, Miller and Nylund established ISA is here before the CFIA could intimidate and dismiss their findings.
On the other hand, it is fair to note that samples have to be taken in a precise way, and the sampler needs to avoid taking the ISA to the next site and then 'finding' it there.
10.
The scenario tree divides the population of interest into smaller groups,within which each individual has the same probability of being detected as diseased given that the population is infected. It does this by describing both the structure of the population and all events that influence the probability that disease or the disease agent, if present, will be detected by that SSC. This sounds good but there are 9,562 different strains of the five species of salmon in BC. DFO has stats on only 57% of salmon demes. And DFO has announced it will lay off 200 science staff.
Hence there is no 'structure of the population' in almost 43% of cases, some 4,112 strains of BC salmon.
11.
The following is a list of lead organizations involved in ISA testing. It includes the province's system that has been shown, above, to be using an unverified probe/primer, and the BC Salmon Farmers Association for its data. It is good to note, however, that the fish farm group has fought release of this data every step of the way since the early '90s, and finally had no choice because Cohen made the release of the BC info public in December. When less detailed info was required by Cohen in August 2011, the fish farms fought its release, and when compelled by Cohen, immediately changed their tune and trumpeted how open and transparent they were (only to become entrenched once again by Dec 2011).
12. The
stochastic decision tree has some nifty math, but no where in this plan is there testing of the water column for up to ten kms from each farm. There are two issues: the farms are not far enough away from one another to be independent; and, as many as 60 billion virus particles are released from one infected farm in an hour and carried by the tide. Looked at another way, this might explain why the Clayoquot Sound fish are diseased to the 25% level - more than 100,000 fish per farm - because it is a dead end, and thus does not flush. (As it is a UN Biosphere Reserve, there should not be fish farms here anyway).
13.
Tests are to prove absence of disease. This stance is maintained by the CFIA throughout the report. Seems to me that we should be proving presence of disease.
14.
Design prevalence factors are assumptions at a defined percentage. Here are three:
trading partners requirements; biological plausibility; and, resources and political considerations. You may recall that biological implausibility of ISA was cited by more than one expert in Cohen testimony. So does that mean the percent is: 0%? And should political considerations and resources get an assumed percentage? Since DFO, the CFIA, the province of BC and the ministers all think ISA is not in BC, should the percentage be 100% that the design prevalence factors are good? Do percentages make sense for these factors?
15.
Time period of analysis - whether short or long. The problem is that ISA carries on at a mortality of about 1.5% and then, at an undetermined point - and they are testing for ISAV rather than ISA - can rapidly exceed more than 50% mortality with 100% of fish having to be slaughtered and disposed of, just as is currently happening to Cooke Aquaculture in Atlantic Canada.
16.
All five species of wild salmon will be tested. Good thing. But the note that they are being tested because they have 'trade significance' ignores that the sport industry at over $500 million in revenue, perhaps 60% of which is from anglers from other countries, is not considered trade. And the sport sector is the biggest and highest employer of the commercial, aboriginal, aquacutrue and processing sectors. 7,500 employees compared with only 820 for aquaculture - that means 915% larger than fish farms.
17. Among other places,
wild salmon will be collected at processing plants. The problem here is that fish in packers are stored together in holds, so one fish can contaminate the thousands of other fish in the hold.
18.
The current scientific evidence on the susceptibility of Pacific salmon species to ISAV is limited. There is a large amount of science/news on the susceptibility of Pacific salmon to ISA. Here are dozens of them:
http://isearch.avg.com/search?cid={59265ce4-372b-4df6-925d-b95785f49726}&mid=c6f75560551047d19ab6d1526267478d-c18e2e88897e2d0377e4ddcc18a0f231c9c4f6db&ds=ins12&v=10.0.0.7&lang=en&pr=sa&d=2012-02-29%2012%3A11%3A48&sap=ku&q=ISA+in+Pacific+Salmon.
19.
DFO hatcheries can be considered sentinels for disease. Contrary to this assertion, it has been the provincial hatcheries that have a long history of being worried about fish farm diseases. There is an extensive email history of being concerned about DFO introducing ISA - which ultimately did happen.
It should also be pointed out that in freshwater, cross contamination is very easy. If one fish has it, the whole river and its hatcheries do. On the other hand, infection of skin or gills can mean recent infection, while heart or other internal organs means long-term infection, and infection not prone to occur from passing through an infected river.
20. We will use
QRT-PCR as a screening test and
confirmation will be on viral isolate. The problem is that ISA is very hard to isolate, hence, all such cases will be 'negative' to the CFIA.
21.
The l% design prevalence is assumed, and thus 75 fish per strain. Good luck. As DFO has no data on 4,112 strains of Pacific salmon, good luck trying to do a good job. Oh, and there are those pesky runs teetering on extinction. Do remember that the Kibenge report noted a 100% infection rate of all 64 Cultus Lake sockeye. Now only one or two returns, likely because DFO ignored the report in 2004.
22.
4900 fish (1750 adult and 3150 juveniles and spawners) will be collected per year for two years. So, let's see, that means one half of a fish per strain in BC. Hmm.
23.
A five course series is required for collectors and inspectors. And this comes when DFO is letting go 200 science people? And the Harper government is looking to downsize by 5 - to 10% of the rest of DFO and government? Good luck getting funding.
24.
Ideal collection conditions are inside a building, and staff can make their own structure. Given that BC has 25,000 km of coastline, and the Pacific is a big ocean and it rains on the wetcoast, conditions are not ideal. And ka-ching.
25.
We will collect and process 175 fish per day. This computes to 25 fish per hour in a 7 hour day for one person. That means 2.4 minutes per fish, or 4.8 if there are two people. Good luck.
Oh, and just how are you going to collect those steelhead? Fish for them? Good luck. And isn't it against the law to kill wild steelhead? I know many steelhead fisheries that only have 100 wild fish as the entire run. The CFIA shouldn't be killing endangered runs, even though steelhead are the prime species that I would pick first.
26.
We will test apparently healthy fish. What about the obviously diseased ones? Discard them?
27.
Steelhead, unlike salmon, spawn more than once. This is not really true. My guess is it is max 35% and then triple spawners are more like 10%.
Footnotes 6 and 7 (p19 and 20) say testing for steelhead will be non lethal, but still 175 fish. I can see gill, mucous, anal fluid and stomach pump material. Infected livers and kidney would shed into anal fluid, but hearts? And 175 steelhead per run? Good luck catching those. The CFIA might have to angle for several months and tag sampled fish. This plan may seem good in Ottawa, but the CFIA will need an army of top notch anglers to catch even 10% of their target number in the swelling rivers of autumn.
On the other hand, if they pay me, I will catch steelhead for them. I'll work overtime, seven days per week. I am starting to like the CFIA.
28.
Hatcheries only produce a small percentage of the total number of juveniles which enter the ocean in any given year. This may be true on the Fraser for, say, sockeye, (140 million wilds from the Chilko River alone in good years) but far more rivers the enhanced fish outnumber the natural ones. On the other hand, if they mean all hatcheries and all rivers, the overall numbers support what is being said.
29.
Table 4. Sampling juveniles and spawners by sampling area per year. This table demonstrates the stunning lack of coverage in the CFIA program. The North and QCs will have 175 adult fish taken. The Skeena is five miles wide for dozens of miles it is so huge. On the other hand, in the QCs (Haida Gwaii) there are dozens of little streams that have salmon, but they may have only 100 yards of spawning gravel before they rise precipitously up the mountains. So each species in each stream is its own genetic fingerprint, but the CFIA program will only do, say, half of its Northern sampling, a total of 87 fish?
The next area is all of east Vancouver Island and the mainland from Rivers Inlet all the way to just north of Vancouver. A huge area with thousands of strains of salmon, will be sampled for only 175 fish? Ditto for the other areas.
30.
A formal collection agreement with the CFIA is required for any collection of samples done on behalf of the CFIA. This seems reasonable, but what it does is forbid anyone else from taking samples and being part of the CFIA study. This means that the public will have to do their own work and send the samples outside of Canada for testing.
31. The industry role is defined for
commercial fishermen only. This means environmental orgs, individual scientists, environmentalists, concerned public members, the sport industry and aboriginals cannot be part of the project.
32.
It is proposed that CFIA, as Canada’s veterinary competent authority, will provide an oversight function to industry-led surveillance effort, which will include an annual visit to sites. As before, the CFIA has no credibility in this issue. The CFIA dealt with a case of ISA on the phone and took the fish farm saying it had no problem as truth. This is not the way to do surveillance.
The role needs to be adversarial in the way that police deal with issues,
and visits need to be unscheduled and more often than once per year. Do recall that Marine Harvest has just paid a fine, Jan 18, 2012 for possession of herring and wild salmon. News reports noted tons of wild fish being destroyed. This kind of thing will never be discovered without unscheduled visits of officers that can lay charges and are not working for a body that has a conflict of interest with farmed fish. The only reason the issue came up is that onlookers watched herring and salmon falling out of off-loading boats in Port Hardy.
33.
Administrative animal health regulations and oversight by the competent authority will help maintain trading partner confidence for either specific commodity groups or the entire region. The CFIA keeps saying this, but this does not agree with what has just happened in the USA. It eliminated a 26% duty on Norwegian farmed fish originally issued for anti-dumping reasons. Norway has had ISA continually since 1984, so why would the USA accept ISA infected fish, if the CFIA contention were true?
In addition, the losers in this duty change will be Canada and Chile who are the main suppliers to the USA market. And Norway is right now going after the markets of Scotland's Atlantic production. BC fish farms are in bad shape, as MHarvest just laid off 60 employees because of difficult times. It is going to get much worse. And, Chile, has once again hit an oversupply position, and fish prices will drop. It may prove fortunate for BC if another ISA crisis hits Chile - 23 farms are now cited for ISA and one farm was just slaughtered for viral disease.
34.
It is proposed that a proportion of [farm]
sites be visited by the CFIA on an annual basis (between 10 and 20 sites visited annually). This is ridiculous.
There are approximately 125 marine leases and 100 freshwater leases in BC that grow anadromous salmonids. This means that it will take between 11.25 to 22.5 years for the CFIA to get to any individual fish farm! ISA will have wiped out BC salmon by that time.
35.
There are 4 principal salmonid aquaculture companies in British Columbia: Grieg Seafood BC Ltd. (20 marine sites and 1 freshwater site), Marine Harvest (61 marine and 11 freshwater sites), Mainstream Canada (27 marine and 4 freshwater sites), and Creative Salmon Company (6 marine and 1 freshwater sites). Thanks for the info. So few fish farms can create so much environmental damage - 114 sites. Hard to believe.
36.
Fisheries and Oceans Canada (DFO) oversees the National Aquatic Animal Health Laboratory System (NAAHLS) to support CFIA’s delivery of the regulatory mandate of the NAAHP. Tell us what the actual facilities are. The Moncton lab that can't find ISA?
37.
Plan review and meetings with stakeholders, Federal and Provincial authorities to explain the surveillance plan, garner support and assistance, and clarify roles and responsibilities. As before, who are the stakeholders?
38.
The dissemination of final positive test results... will be done via prompt e-mail notification to selected stakeholder and industry groups and to the OIE... Who are among the selected stakeholders? And, why can we not know about individual locations of disease? See:
the identification of affected premises is not provided. The BC tables provide site specific data, and these are now public, thanks to Cohen.
39. Dissemination of info will be:
to maintain and enhance welfare, productivity, and economic viability of aquatic animal industries in Canada. This means the purpose of the whole exercise is to maintain fish farms as they are, in the ocean. This is an outcome that is not viable in BC anymore. Everyone knows fish farms should be on-land, and the CFIA studies are superfluous to this knowledge and outcome.
40.
Outbreaks of ISA have occurred in Atlantic salmon cultured in New Brunswick in the Bay of Fundy. However, the last detection of a pathogenic strain of ISAV in this area occurred in 2007. Here is my table, based on Kibenge and others, of ISA in the world:
http://fishfarmnews.blogspot.com/2011/10/isa-infections-world-wide-sine-1984.html. The CFIA comment does not agree with the table. Oh, and the Cooke Aquaculture destruction of two farms in Atlantic Canada in Feb/Mar 2012 for ISA has not yet been added to this table.
41.
ISA occurs in spring or early summer in water temperatures from 3°C to 15°C. This includes BC water as it is typically 6 - 11 degrees all around the year; however, if we believe the quote, ISA occurs as wild smolts out migrate, and early spawners return, as in sockeye and pinks.
42. ISA:
Vertical transmission has not been demonstrated; egg surface-associatedtransmission does occur. This runs counter to the study on Aquagen that showed vertical transmission to Chile from Norway.
43.
7.2. ISAV, IHNV, IPNV Case Definitions. This table does not recognize Kibenge's work on genotyping the ISA strains in Chile. There are 28. Looking for segment 6 or 8 only, could lead to negative results when they are in fact positive for ISA. However, the table also says non-pathogenic ISA can be determined by positive tests from two different assays.
44. The bottom of page 41 is reasonable
indication of wild river/marine area infection provided you believe the lab, and the process is free of conflict. It is not, but the unswayed experts Miller, Kibenge and Nylund should be involved and free to report their findings. And, if they have been required to sign any agreements about testing only chain of custody fish, this should be public information - Nylund is probably not in this category as he works in Norway. And their 'informal' expert comments should be publicly reported without any meddling by the CFIA, DFO, BC and so on.
45.
Appendices. There is some spectacularly interesting information in the Appendices. You may want to go here first and cruise around before committing to the drudgery of the report itself.
Whew, this was a lot of work.
