September 7, 2010
Mr. Edward Porter, Team Leader, Regulatory Operations
Aquaculture Management Directorate, Fisheries and Oceans Canada
200 Kent Street, 14th Floor, 14-S010, Ottawa, ON K1A 0E4
Dear Mr. Ed Porter:
Let me say first that I find it wrong that you demand people respond to sweeping changes to the salmon feedlot regulations while they are on vacation.
In regards to your Fish Pathogen and Pest Treatment discussion document, I feel I have to be frank and say….. you have GOT to be kidding!!
“Under these proposed regulations the above categories of substances, when used to treat or destroy fish pathogens and pests would need to conform to the following conditions:
• The Responsible Minister is satisfied the deposit will not adversely affect non target fish, fish habitat or man’s use of fish outside the treatment area as determined through a risk assessment conducted to the satisfaction of the Responsible Minister.”
Leaving the release of drugs and pathogens up to a Minister is a recipe for corruption, damage to our oceans and public resources and a threat to public health. Who wrote these new regulations, a CEO in Norway? Fisheries Minister Shea, seems to have very little idea of what is going on out here. As an example she thinks there is no strong evidence that the virus ISA can be imported with Atlantic salmon eggs even though scientific papers offer the opposite conclusion. Minister Shea’s unsubstantiated opinion is being used to allow continued import of Atlantic salmon eggs. This combined with the recent discovery of the HSMI virus in over 400 Norwegian salmon farms over the past decade means eggs have entered this country potentially carrying ISA virus and HSMI virus. When you combine this with the BC salmon feedlot industry’s refusal to release disease records it makes a person concerned. Ministers are political figureheads they are not equipped to make significant decisions at their whim.
Since April 1, 2010 a provincial minister, Thompson (MAL), is actually allowing salmon feedlots to turn away government vets from testing farm fish for disease. This appears on their website. This is a Minister making a decision that is not good for people, it is good for foreign owned companies.
What good is it to the people of this coast, if a Minister 100s or 1000s of km away is “satisfied,” when people are gathering food in the ocean around these feedlots with no information about disease and the toxic anti-parasite drugs, antibiotic and disinfectant use. Salmon feedlots are the only feedlots that never shovel manure. They dump it all straight from their livestock, through nets into the public waters of Canada. The drug used to kill sea lice is neurotoxin. A Minister thousands of km away may find herself “satisfied”, but what of the woman feeding her child from the sea. Work I am currently involved in shows impact on bacteria from salmon feedlots covers an enormous area.
By leaving important decisions open to a Minister’s discression you make them vulnerable to legal disputes over toxic substances entering the food chain, you open the door to Prime Ministers rewarding benefactors with easily “satisfied” Ministers. There have to be hard and immutable laws about exposing the public to toxic chemicals. This cannot be left to a Minister!
You must protect the public from feedlot drug use and feces. Put these operations on land in biohazard secure tanks.
Clearly Stephen Harper is prepared to go into the next election without the support of British Columbians.
Alexandra Morton
