In the ongoing saga of what I view as a coverup of the effect of farm salmon disease on wild salmon, I have written to Canada's newest Minister of Fisheries. Recent internal CFIA emails reveal that the agency only wants only one lab in all of Canada to test for ISA virus in BC farmed salmon and that lab is shrouded in controversy due to its chronic inability to find diseases and pathogens that other labs are reporting. This is not acceptable and threatens not only wild salmon, but Canada's reputation, again.
I think there is reason to believe that this Minster could be brave enough to look the salmon farming industry in the eye and finally make an honest evaluation of the risk to Canada and take the steps required to protect wild salmon and aquaculture. I hope I am not wrong. We will see - so far he does not acknowledge my correspondence to him.
June 24, 2016
Dear Fisheries Minister LeBlanc
Thank you for your words of commitment to ensure healthy oceans and fisheries for Canadians. We share your sense of duty, and are writing to alert you to recent actions undertaken by federal government officials that appear to us to run counter to ensuring healthy fisheries. We believe that these actions put wild Pacific salmon, aquaculture and Canada’s international reputation at risk, and sincerely hope that you will give our concerns serious consideration. While the information below concerns the Canadian Food Inspection Agency, it also concerns our fisheries and aquaculture and I believe strong leadership is desperately needed.
On January 6, 2016, we co-published with others a paper reporting European strains of the Infectious Salmon Anaemia virus (ISAV) in BC farmed and wild salmon. ISAV is an internationally reportable virus, and the Canadian Food Inspection Agency (CFIA) is in charge of containing it and notifying trading partners of its presence.
In an effort to understand why the CFIA refuses to recognize our published research on this highly feared virus, we requested internal CFIA correspondence on our paper under Canada’s Freedom of Information legislation. After reviewing it, we thought you should be made aware that (i) the CFIA’s surveillance for ISAV appears to be “unacceptable” to Canada’s trading partners, (ii) that program appears to be biased towards protecting industry from economic impacts that the virus can cause, and (iii) that their response could result in further serious biological and trade issues. ISAV is spreading worldwide where Atlantic salmon are farmed and is known to lie dormant for a period of years and then become highly virulent causing widespread death of salmon. Thus it is precisely the category of threat that Justice Bruce Cohen warned us of in regards to serious, irreversible potential impact of salmon farms on wild salmon.
Following the publication of our paper, it appears the CFIA became aware of concerns regarding their ISAV surveillance in British Columbia farmed salmon. In response, they contracted 1,105 ISAV tests on BC farmed salmon to be completed by the end of the fiscal year – March 31, 2016 - a very tight timeline for so many tests.
What happened next raises very serious concerns not only about the CFIA’s commitment to protecting Canada from this virus, but also protecting Canada from international scrutiny that will follow if contaminated product is discovered being shipped internationally.
In February 2016, the CFIA abruptly terminated ISAV testing of BC farmed salmon that was underway at DFO’s Freshwater Fisheries Institute in Winnipeg and hurriedly drew up a contract with a BC government laboratory, despite internal concerns that the BC laboratory may not meet CFIA standards. The DFO laboratory was instructed to return all samples of BC farmed salmon received only the week before. Senior CFIA officials prejudged that the results by the BC laboratory would be negative (email Klotins Jan 26, 2016).
Below are excerpts from a CFIA internal email train discussing the sending of samples of BC farmed salmon to the Provincial Ministry of Agriculture and Lands (BCMAL) Laboratory called the Animal Health Center for ISAV testing. These communications raise concerns about the legitimacy of what appear to be hastily prepared justifications for this “ad hoc” arrangement.
The key question is does their method meet CFIA performance requirements. If it does then proceeding with the testing would be a reasonable risk, when compared to the risk of not having the samples tested in a timely matter. Shelagh McDonagh, CFIA National Manager, Laboratory Quality Assurance and Accreditation Jan 19, 2016
“Do we need to have the BC method assessed…?” Stephen Norman, Laboratory Director CFIA, Ottawa Jan 19, 2016
“… we would need a really solid sole-source justification that only the BC lab could do this work.” Stephen Norman Jan 19, 2016
“Essentially this is the only laboratory that can meet the requirements set out in the CFIA policy,” SOLE SOURCE CONTRACT JUSTIFICATION Jan 20, 2016.
“I understand we are doing this one “ad hoc” due to the urgency to get this testing done, however for the future (if using non-DFO methods is the path we are taking), we will need to develop an official documented process for the review and approval of alternate test methods.” Maria A. Perrone, Director, National Animal Health Laboratory Services CFIA, Jan 26, 2016
“… before they start the testing, it would be good to know that the testing methodologies have been approved.” Andrea Osborne, CFIA Regional Veterinarian Jan 26, 2016
At this point, the CFIA was in their 5th year of ISAV testing in BC, following the Cohen Commission ISAV hearings that produced ISAV results for BC from 5 government, academic and international laboratories. Why now the sudden need for the CFIA to switch laboratories? How could they justify a claim that only the BC laboratory could do this work now that ISAV had been reported in a major scientific journal, when they already had an arrangement with a federal laboratory? Why were they so adamant to use only “non-DFO methods?” Why didn’t they continue using the DFO laboratory to perform parallel tests, with the BCMAL laboratory, to provide corroboration of the results?
Specifically, we see that, even as senior CFIA managers express uncertainty over whether the BCMAL laboratory meets “CFIA performance requirements”, it was approved the very next day on Jan 20, 2016 as “the only laboratory that can meet the requirements set out in the CFIA policy.”
All previous CFIA reporting on ISAV in BC has been for wild salmon only. This ATIP is the first evidence of CFIA testing for ISAV in BC farmed salmon. Did trading partners’ inquiries into the certification of BC farmed salmon as ISAV-free trigger the CFIA testing of 1,105 farmed salmon? If so why switch laboratories?
If the BCMAL laboratory was the “only lab” that met CFIA policy – why wasn’t the CFIA already using this facility?
On February 2, 2016, DFO Science Advisor, Candace Fisher, contacted Dr. Sunita Khatkar of DFO’s Winnipeg Laboratory and told him to halt ISAV testing on the BC farmed salmon he had received the week before and to send the fish samples back to BC to the BCMAL laboratory. On February 16, the samples were shipped to the BCMAL laboratory.
Furthermore, the CFIA instructed the BCMAL laboratory to test only for the benign strain of ISAV, called HPR0, not for the virulent strain, HPR5, which was also reported in our paper.
Before testing commenced, Dr. Kim Klotins CFIA National Veterinary Program Specialist - Ottawa made it clear there would be no ISAV detected in BC BC. She prejudged the results after special arrangements were made to use a controversial lab:
Jan 26, 2016 “Let’s make this very clear – this is not a new strain... there is nothing to pick up…. Nellie and Kyle have determined that this so-called variant is due to laboratory error…- my understanding is they along with [REDACTED] froMAL, will be informing the editor of Virology Journal.” Dr. Kim Klotins. to Stephen Norman, Maria A. Perrone, Shelagh McDonagh, Andrea Osborne, Melanie Sheppard, CFIA Vice President, Science; Animal Health Science
Indeed, Ms. Nellie Gagne, DFO and Dr. Gary Marty, BCMAL (but not Dr. Kyle Garver of DFO) did contact Virology Journal asking that the paper be retracted, but the journal dismissed their concerns and the paper remains.
Some CFIA staff did express concern that “this time” they needed to use a test that would capture the ISAV sequences we reported in Virology Journal. It is important to note that the CFIA had been made aware of every ISAV test result we generated since 2011. The findings we published were not new to them.
“This time, I think we need to ensure that the ISA test in use will pick up the artefact of testing that was published by Kibenge et al in Virology Journal” Dr. Andrea Osborne, CFIA Veterinarian. Jan 26, 2016
The CFIA not only redirected all samples from Winnipeg back to BC; they also went to BC salmon farms and collected 736 more samples and shipped them the short distance from Vancouver Island to the BCMAL laboratory in Abbottsford. Somehow they failed to keep these samples cool. All the ice melted to room temperature.
“We received the samples today morning. Frozen gel packs were thawed, at room temp-samples were at or slightly below room temperature… let me know whether samples are acceptable for further processing” name redacted, BCMAL
“… they are fine to be tested. They can be stored for up to a week and still be viable in RNAlater” Andrea Osborn
While the CFIA felt this was acceptable practice, we disagree. The reason scientists pack samples in ice is to maintain sample quality, which is particularly important with the ISA virus. In our view, they should have re-taken the samples and used a car to make the short trip (under 4 hours) to the laboratory to provide the quality of samples that produce high-confidence results.
On a related issue, a DFO scientist recently reported a salmon heart disease of significant legal and biological consequence in BC farmed salmon. This announcement on March 20, 2017 triggered adjournment of an appeal by DFO and Marine Harvest regarding transfer of disease-carrying farmed salmon from hatcheries into marine pens. The BCMAL laboratory, however, supports Marine Harvest’s views that this heart disease HSMI does not occur in BC, as Dr. Gary Marty refutes the finding by the DFO scientist.
We feel it is important to provide you with a critique on the BCMAL laboratory authored by eight scientists from three universities who express deep concern that Dr. Gary Marty of the BCMAL laboratory is dangerously downplaying the risk that disease in farmed salmon poses to wild salmon. Dr. Marty stated that he would respond to this critique, but we are unaware of any response. Download Critique Dr. Gary Marty
We are writing to you because we feel that the CFIA’s exclusive use of the controversial BCMAL laboratory for ISAV testing puts both wild Pacific salmon and Canada’s international reputation at risk. When dealing with a virus as potentially virulent as ISAV in the marine environment where currents can move particles 10km in 6 hours, we feel it would serve Canada to ensure that all steps were taken to prevent an outbreak. In our view the actions of the CFIA as documented in the ATIP we received, are not defensible and put Canadian interests at risk.
Given the controversy around this BCMAL laboratory and the disparity in results between this and other laboratories, it would seem in the national interest that several laboratories share the responsibility of testing BC farmed salmon for internationally reportable viruses such as ISAV. If this lab is using samples that have not remained chilled and tests that are different than those that have detected ISAV, and different than the previous 4 years of ISAV surveillance confidence in the health status of BC farmed salmon is unnecessarily eroded. Failure to contain ISAV led to $2 billion in losses to the salmon farming industry in Chile, involving some of the same companies as operating in BC. The risk of impact is even greater in BC because, unlike Chile, we have wild salmon in addition to a salmon farming industry.
Thank you for reviewing our concerns. We hope that this information will assist you in achieving your goals to ensure healthy fish populations in Canada. We request urgent review of this matter as ISA virus is a serious concern. We remain available to provide the substantive documentation that ISA virus occurs in BC and to assist you in other ways upon request.
Dr. Richard Routledge