Review of Soil Association standards for organic farmed salmon
Over the past 18 months, the Soil Association has conducted an extensive review into the welfare needs and environmental impacts of farmed salmon. This work was undertaken to decide if we should continue to set and offer certification to Soil Association Higher Standards for organic farmed salmon. Our analysis included a comprehensive evaluation of current welfare and environmental outcomes, and the extent to which Soil Association standards and government regulation could address areas of concern within a suitable timeframe.
Although our organic standards are the strictest in the salmon industry, our research concluded that risks to fish welfare and environmental outcomes are not at a level the Soil Association finds acceptable. More needs to be done to respond to the risks of critical issues including fish suffering amid sea lice outbreaks, mass mortality events, and the release of harmful chemicals into the environment. These problems are more pronounced in conventional systems, but they are still unacceptable on Soil Associated certified farms.
The outcome of the review has identified a possible pathway that combines significant changes to our standards, alongside relevant action on regulations by Scottish Government and active participation by industry, to swiftly address the concerns and drive measurable improvements.
We have, therefore, laid out proposals for the outcomes we need to see within 12 months in order to verify that this level and pace of change is achievable. This will start with the changes our standards will lead in the sector, while also identifying the critical role the wider actors in the sector need to play alongside us. This includes both the Scottish Government and the wider industry being willing to support our work to deliver these changes, as well as addressing key issues within their control.
Due to the level of concern we have over environmental and welfare outcomes, we need to deliver this work at pace. We need to see clear action and progress within one year, otherwise we will begin the process of withdrawing from setting the standards to certify organic salmon. This is because we will take the lack of sufficient progress as an indicator that meaningful reform will not be possible at the pace and in the direction that our research has indicated is necessary.
The Soil Association is consequently seeking substantial reform in five key areas – mass mortality, veterinary treatments, welfare, sustainable feed, and environmental impact.
Our comprehensive review has detailed the areas for standards development that we would like to enact over the next five years. However, as well as regular review points to check progress, we also want to see more immediate commitment and urgent progress on a number of key issues, detailed below.
Essential change for Soil Association’s continued involvement in setting standards for organic salmon
We cannot condone mass mortality events that have occurred on organic sites. We realise organic salmon farms must be better prepared to respond to these events, should they happen.
Our research has concluded that mass mortality events could be an indicator that a salmon farm is not in a suitable location. Such events are also linked to warming sea temperatures, which in turn lead to increases in problems like micro-jellyfish swarms.
As it currently stands, we do not believe that the Soil Association Standards or Scottish Government’s regulatory processes are going far enough. They neither account for novel and unprecedented challenges that climate change is presenting, nor what they may yet present.
Within one year we aim to:
Update standards and reporting that look to limit, prevent and ultimately avoid these events occurring. This will be via a combination of suspending certification for sites with two or more mass mortality events, after which a full site suitability assessment would be required and decertification would occur unless the licensee could demonstrate that adequate steps were in place to prevent reoccurrence.
This would happen in conjunction with the identification of unsuitable site areas, and collaboration with Scottish Government to quickly identify and address changes to regulations in these areas.
The Soil Association has a long history of campaigning against harmful chemicals, and we are opposed to the use of these treatments in salmon farming. However, we have, to date, accepted that producers need access to some treatments so that they can follow veterinary advice and treat animals that are sick or suffering with parasites, like sea lice. Two of the most harmful veterinary medicine treatments used by the sector, emamectin benzoate and azamethiphos, are banned in Soil Association organic standards.
Deltamethrin can be used by organic salmon farmers at marine sites, with strict withdrawal periods before fish can be harvested, and its usage is a third of that used by the non-organic sector. Current standards stipulate a maximum of two allopathic treatments in a 12 month period, meaning deltamethrin could only be used twice per year, and only as a last resort. It also cannot be used preventatively. Organic, therefore, presents a much better option, but we remain concerned about the environmental impacts of deltamethrin, which is a persistent chemical. As such, we do not believe that a system that remains dependant on its use can be sustainable in the long term.
Within one year we aim to:
Set a new standard that prohibits release of deltamethrin into the environment. Producers would still be permitted to use the chemical, according to the same existing restrictions, but they would not be allowed to release it into the sea. This would serve as an important first step in phasing its use out in the long term. However, it means we also need commitments from industry and government to rapidly progress technologies that enable safe disposal of deltamethrin without any risk to non-target organisms.
As part of our review, we convened an independent, international expert group, the Farmed Salmon Welfare Panel (FSWP), whose remit was to identify key components of a ‘good life’ for farmed salmon. The FSWP agreed that of the different life stages, it is most challenging to provide a good life for farmed salmon smolts at sea in the grower phase in sea pens. Most members of the panel* consider there’s a high risk that currently smolts at sea do not have a good life, but that with substantial system changes a good life could be possible. Following their report, we identified key areas for standards development that we believe could deliver a good life for salmon and have mapped a pathway for developing standards and reviewing their impact. We will seek independent experts to review the impact of these standards to check that that they are delivering outcomes consistent with a good life.
Within one year we aim to:
In addition to the daily routine checks on fish health and welfare, we will require organic salmon producers to carry out additional Welfare Outcome Assessments according to defined welfare indicators. These will need to be recorded for monitoring and reporting. This is a relatively new area of thinking that we have applied to terrestrial farmed species. It requires licensees to show not only that they are meeting our standards, but also that animals are experiencing good welfare as a result.
Currently, there is not a consistent approach to welfare assessments across salmon farms, making it difficult to have confidence that the best preventative management practices are taking place, which are always at the heart of organic. Our work over the next year will develop welfare outcome assessments for salmon, enabling us to set a new standard that producers must carry them out weekly, plus after any treatment or handling. We also will look to work with other standard setters, including RSPCA Assured, to roll out these welfare outcome assessments, as part of our goal to drive improvements across the entire sector, not just organic.
Develop a more detailed reporting system for Soil Association Certification to use. Currently producers must provide data on mortality and chemical vet treatments to the regulator, but our research has concluded that this data-based reporting is not preventing welfare issues or ensuring salmon live a good life. We need to develop a system that means salmon farms are providing us with clear, consistent, real-time information to allow us to better identify when issues are occurring. This will include the new WOAs and will allow us to help licensees to improve management practices. It will also give us information to further develop standards to improve welfare. In late 2024, we brought in a standards update that strengthened reporting requirements on mortality and sea lice levels, so this work has already begun. This will inform the work to develop a holistic, effective reporting system that catches signs of welfare issues before they become a problem.
* Dr Natasha Boyland from Compassion in World Farming did not agree that there is evidence to support that a good life can be achieved in a commercially viable farmed setting.
Although the Scottish farmed salmon industry tends to source feed from certified responsible sources, we are concerned that it could compete with food supply chains and place too large a strain on fish stocks. This is a growing concern as the industry continues to expand.
Currently organic producers are required to prioritise ingredients from sustainable sources, with trimming and waste products used in preference to whole fish - but they can use whole fish caught from sustainably certified fisheries to feed farmed salmon if needed.
Within one year we plan to set a new standard requiring all feed used in the production stage (in net pens at sea) to contain marine ingredients that only come from trimmings or by-products.
Our work over the next year would support producers to make this transition, and we are seeking commitments now from industry that they are happy to work to this goal.
The impact that salmon farming is having on other habitats is not well understood. But our research has led us to conclude that we need to apply the precautionary principle more rigorously to protect marine environments. We are also concerned about the cumulative impact of salmon farms, and evidence that some sites may not be in an appropriate location.
It is the role of Scottish Government to set the legislative and regulatory framework for fish farming, and to ensure that the consenting and leasing process considers each site for suitability and its impact on the environment. But our research has concluded that neither the regulatory process nor Soil Association Standards are sufficiently reducing risks to sensitive habitats, when applying the precautionary principle.
Within one year we aim to:
Set Soil Association standards that ensure organic sites are not located in areas where they are likely to negatively impact sensitive wild salmon runs or the UK’s maerl habitats. We want our standards to protect all marine environments, but these specific habitats are globally important. We believe that delivering action within the next year to protect these would be a good indicator that the sector can reach a sustainable footing. Currently licensing arrangements do not provide appropriate protection for these habitats, and so our work over the next year will look to go further and define safe distances from them.
What we need from Scottish Government to support and enable these changes
We will be calling on Scottish Government to:
Develop robust strategic guidance to specify which areas are suitable or unsuitable for siting of all salmon farms, for example, due to proximity to Marine Protected Areas. The regulator needs to ensure appropriate locations for salmon farms. In order to take a harder stance on mass mortality, we need to also reduce the risk. This will provide us with the necessary confidence that producers will not simply move to another inappropriate location, if we decertify an existing farm, due to a lack of guidance and information within the consenting and licensing process.
Set out a clear plan to limit or halt production on sites found to have 'persistent high mortality' levels. This should build upon the existing commitment to report to the Rural Affairs and Islands Committee in September with an analysis of data relating to mortalities.
As above, we welcome introduction of stricter conditions on the reporting of sea lice data, amending secondary legislation under the Aquaculture and Fisheries (Scotland) Act 2007. We want to see reporting of all sea lice species data, more regularly, and enhanced mechanisms to share data with other salmon farmers to inform preventative actions. If this data were of this higher quality and more up to date then all operators, not just organic, could be more confident of the sea lice situation in which they are operating and take preventative action to reduce the need for chemical vet treatments. Again, we need the entire sector to work together to tackle this major issue to have confidence that organic salmon farming is viable.
Introduce additional regulations and guidance under the Animal Health and Welfare (Scotland) Act 2006 to set specific baseline standards for the welfare of farmed fish. We would want this to include putting the Code of Good Practice for Finfish Aquaculture on a statutory footing. This should also include regulatory standards on sea lice. Action from government is essential because any farm that is experiencing high levels of sea lice presents a risk to other nearby salmon farms, and indeed the wider environment. We therefore need the entire sector to work together to tackle this major welfare issue in order to have confidence that organic salmon farming is viable.
Next steps for Soil Association’s organic salmon standards
Our proposals require some dramatic changes and commitments made not just by organic salmon farms but the entire industry. The changes that we have set out will be considered holistically following our usual standards development process covering all organic aquaculture standards. Also, our review in a year will consider if significant progress has been made against them.
While most of the goals that we are seeking to achieve in the next year are based around developing our own standards, we need to be confident that the industry will join us on this journey and at the pace we are seeking.
We are therefore now seeking commitments from government and industry to demonstrate there is a pathway to building a sustainable future for organic farmed salmon. If these commitments cannot be secured, or if sufficient progress is not made within a year, the Soil Association will need to withdraw our involvement in setting organic standards. However, we sincerely hope to see the appetite for innovation and positive change continue, so that we can ensure that farmed salmon can live a good life without damage to the environment.
More information
The full evidence pack detailing the analysis and research in our review is available on request by emailing: standards@soilassociation.org
