Standard bearer Martin Gill
Scottish salmon farmers have been subjected to scrutiny from the early days
DURING last year’s parliamentary inquiry into salmon farming, a ringing endorsement of the sustainability of the industry in Scotland was provided by a man who should know. According to Martin Gill, head at Fisheries and Aquaculture of certification body Acoura (now part of Lloyd’s Register), the level of auditing at Scottish farms constitutes ‘some of the most rigorous independent oversight of aquaculture practices, let alone farmed salmon production, in place in any country globally’.
Gill, a marine biologist by training, has more than 30 years’ experience in aquaculture and fisheries, and nearly 20 in the auditing of fish farms.
In his written submission to the Rural Economy and Connectivity (REC) committee, which was investigating the sector, Gill spelt out just how closely salmon farms are scrutinised.
‘Lloyd’s Register carries out several hundred farmed based audits annually on Scottish producers, this covers close to 100 per cent of all Scottish based salmon farms at least annually, and in some cases visits are carried out more often.’
Talking to Fish Farmer last month, Gill said the team of auditors in the UK is mostly made up of former farm staff, who as a consequence know what to look for.
‘The auditors are very experienced, high trained and most of them started out as fish farmers,’ said Gill. For example, Paul Macintyre, aquaculture director, has been with the company since the early 90s but he started at Marine Harvest (Mowi).
‘He has been a farm manager as well as a processing and packing plant manager. Matt James, senior aquaculture manager, was a Marine Harvest farm manager earlier in his career.
‘That is key because when they go on to a farm, it’s not just an auditor going down a checklist, they actually can put the requirements of the standard in context, they can see and feel that there is good practice going on.
‘Or they also know
where to lift the carpet and say, let me have a look here to see if there’s something not quite right.’
Salmon farmers in Scotland made a conscious decision very early in the development of the sector to go down the quality rather than the commodity route, said Gill.
‘They have a different business model to the Norwegians, who in general have been based on larger volume, lower price.’ Gill was recruited back in 2002 by Angus Morgan, former Marine Harvest executive and then chairman of Food Certification Scotland, an independent inspection and certification body that had grown out of the salmon sector in the 1990s. The not for profit organisation assisted in the development of the Tartan Quality Mark, the first accredited quality scheme for the marketing of fish products in the UK.
Gill, who described the salmon industry as ‘a pathfinder’, said it also took the decision to go down the Label Rouge route at the same time, for
the French market.
‘Label Rouge was, and I believe still is, the highest quality scheme, a really true product quality scheme that actually looks at quality characteristics of the salmon carrying the LR quality mark.’
For many years, Scottish farmed salmon was the only non-French produced food product to have that award, which is a reflection of the farmers’ commitment to quality, said Gill.
When he joined Food Certification Scotland (later Acoura) in 2002, other standards were starting to come on to the market, often driven by the retailers and the big brand processors, demanding quality and provenance.
Gill has since certified Scottish salmon farmers against all the main standards,,both domestic and international, that are available in the market today, including the Code of Good Practice for Scottish Finfish Aquaculture, GlobalGAP, Aquaculture Stewardship Council, Global Aquaculture Alliance Best Aquaculture Practice, Protected Geographic Indication, Chain of Custody standards, Friend of the Sea and others.
‘For these standards to meet the requirements of what is known as ISO17065 accredited third party Product Certification Standards, it is required that the participants (farms, hatcheries, broodstock units, feed mills, harvesting stations, packing plants and secondary processing plants) in the schemes are independently inspected and certified against a rigorous set of Production and Quality Standards,’ Gill wrote in his REC submission.
He said the companies often have a large client base so have to adopt and maintain certification to a whole range of standards, on top of which they very often have to comply with retailers’ and other clients’ own standards.
Assessors go on the 300 or so farm sites ‘day in, day out’, a minimum of once and quite often two or more times a year because of the multiple standards that have to be delivered, said Gill. They are also in the packing stations several times a year.
Yet despite such ‘rigorous oversight’, the sector’s sustainability is still questioned by its critics. What does Gill think the industry should be doing that it’s not doing to improve perceptions?
As a certificaiton body, he and his audtiors have to remain impartial at all times, but he said: ‘I do get a bit frustrated when we see this continual bad press because I think the industry tries extremely hard and invests heavily in the quality and sustainability of their product and operations.
‘No one is perfect and there’s always room for improvement. But from my point view, I witness very strong commitment to address issues when they are identified, and to innovate because they want Scottish salmon to continue to be successful and they want it to be sustainable and they want it to be the best quality salmon in the market, for both ethical and business reasons.
‘From the farms we go to, they are very knowledgeable, very focused on the health and welfare of their fish and their environment and everything else that goes with Scottish farmed salmon. That’s very visible.’
If farms do not meet the high standards demanded by the certification bodies, though, there are sanctions.
‘That’s called a non-compliance and they range from minor – for example, a paperwork error – or they could be a major one, like a veterinary treatment not being correct,’ said Gill.
‘All accredited standards have a specific process and they vary slightly between them in how they address non-compliance.
‘The usual practice is to raise it and give the client so many days to provide evidence of corrective action. The average across most standards is 28 days.
‘If it’s a major non-compliance, we have the authority if required to suspend them from the scheme immediately until we look at the issue in more detail.
‘It’s very rare. The main reason in Scotland is because all of the companies and all the farms are ingrained in this need for quality management systems. The various schemes have been in place for 20-25 years, so they are very tight systems, with robust procedures, so it’s second nature to the farming companies.
‘But sometimes things go wrong as they do in all farming situations. Things can happen, whether it’s a natural change that causes a problem or an error has been made or there’s an accident.
‘The important thing is to have robust systems to prevent problems where
“There is a very strong lobby against fish farming and I have no problem with that because it forces the industry to look at itself”
possible, but also to have responsive practices that can identify issues and address them responsibly and as a matter of priority.’
He said auditors don’t have power to stop farmers operating but do have power to remove their use of a logo, suspend them or, in extreme circumstances, withdraw their certification.
Aquaculture companies dread having to phone up a client and say, I can’t deliver your salmon today because we’ve had to remove the logo, so they take the process and requirements very seriously, said Gill.
‘There is a very strong lobby against fish farming and I have no problem with that because it forces the industry to look at itself, it forces them to review and to improve and innovate and move forward.’
The standards themselves are constantly updated, with the ASC salmon standard and the Code of Good Practice currently undergoing reviews.
‘Schemes are not stationary, they are reviewed on a regular basis, to keep them up to date with a changing industry,’ said Gill.
‘We don’t own the standards, we’re there to interpret and audit them on site. However, we are involved in several technical committees, advising on the auditability of the criteria being proposed, as well as the applicability.
‘The standards will develop as new innovation takes place – the use of cleaner fish, for instance, wasn’t in the Code of Good Practice when first published, but in the next review I’d expect to see further criteria relating to the management of cleaner fish start to appear.’
As for the ASC review, he hopes that changes to their standards will encourage new applications from the Scottish freshwater sector, which has been mostly excluded because of its production methods.
Uptake here has been slow not because they had bad practice, just a different production practice, said Gill, and the review, which has had comment and input submitted from his Lloyd’s Register colleagues, will address that.
‘Certainly, the commitment to uptake is there. I think it’s a challenging standard, but yes, I would hope and expect to see much wider uptake.’
He also hopes to see more streamlining of the various standards in the future, conceding that there are too many of them.
‘It could be considered great business for certification bodies because there’s a demand that we go and deliver all these different standards. But on the other hand, we recognise that it’s a serious burden to aquaculture producers, both in terms of time and money.
‘The various standards overlap significantly and in some cases up to about 80 per cent of the content, but there might be 20 per cent of difference – for instance, the RSPCA one will lean more towards animal welfare related issues, ASC may focus more on social welfare and environment, Label Rouge focuses more on the product quality of the salmon.
‘Going forward, I would expect and hope to see an element of benchmarking and equivalence between the standards so we could go on to a salmon farm in Scotland and deliver, for example, the Code of Good Practice but then bolt on a module for the additional criteria that are relevant to another standard.
‘We already combine audits where possible but there are occasions when we visit the farm and have to do a whole audit for one particular standard, then a separate audit for Global GAP.
‘If we have to go on a farm three times a year to do three different standards, we’re charging three days of an auditor’s time, plus travel costs. If we could go for, say, two days and combine those three audits, there is a significant potential cost saving to the client.
‘Although that’s less revenue for us, I think it’s the only sensible thing to do. I’m very supportive of that, but is it going to happen? There’s a lot of talk!’ he said.
Since Acoura became part of the UK based Lloyd’s Register Group at the end of 2016, Gill’s remit has become much more global, with clients in 40 countries.
From a small, specialised company, based in Inverness, he is now part of one of the big global certificaiton bodies. Previously Acoura had a global footprint but limitations on being competitive in some key aquaculture markets. For example, it was difficult to be competitive delivering services to China from Inverness.
But Lloyd’s has eight offices in China, and Gill makes regular trips there. His role now is the strategic roll out of seafood expertise across the Lloyd’s Register network globally, to be able to scale the companies offering and provide services locally and competitively charge at local rates.
The global standards and requirements are the same worldwide – BAP is growing over 30 per cent a year globally and so is ASC, and that is set to continue, said Gill.
‘In China, certification was traditionally in the export related sector, demanded by western processers or buyers. Now, with the growing middle class who are more aware of consumer demands and sustainability and food safety, we see the domestic market for certification growing.’
While the future for him is to scale up globally, this won’t take attention away from the industry here.
‘We may now be Lloyd’s Register- a huge global business- but Scottish salmon is a core client we hold very dear. Our relationship has been in place since the 1990s and I hope that will continue.’