Scottish Technical Standard
Containment Working Group chair on pinning down the details - and date for next meeting
WITH the new Scottish Technical Standard (STS) due to come into force next year, time is of the essence in finalising not just the details of its requirements but how it will be implemented.
Overseeing this mammoth responsibility is the Containment Working Group (CWG), many of whose members have been sitting around the table together since 2013, with a remit to prevent fish farm escapes.
But there is one new face and she happens to be the chair. Anne Anderson, director of sustainability at the Scottish Salmon Producers Organisation, took over from her SSPO colleague Jamie Smith earlier this year when he left the organisation.
Anderson, who joined the SSPO from Sepa (the Scottish Environment Protection Agency), is not easily daunted, but she admitted that Smith was a ‘big loss’, and acknowledged that there was still much to be done – not least finding a date to get everyone in the same room.
Her first and only, at the time of going to press, meeting of the CWG was on April 29, when there were about 30 people in attendance, a ‘cast of thousands’ that is proving difficult to corral.
Anderson is relying on the expertise of the group to identify and prioritise those aspects of the STS, which was published in 2015, where a review is deemed necessary.
‘Everyone is working towards the 2020 implementation but there are areas where further work will be required and we need to explore some of these,’ she said.
‘Some of the standard is considered extremely above what is required – unrealistic and potentially too burdensome- and becoming almost unwieldly, as a consequence, in the delivery. With other aspects, it’s the opposite.
‘I think you find that with any standard or set of rules or criteria. It takes time to find the level for the majority.’
It will probably take several iterations to settle out and the purpose of the meeting (for her) was to hear the different views around the table.
As the new chair, she asked the group to suggest any changes they would recommend and which they needed to invest ‘swift task time’ to address.
Marine Scotland, the government agency that sits on the group, has been asked to summarise the list of changes and once Anderson has heard from everyone, she will find the ‘midpoint’.
Smith, who took over the chairmanship in 2018 following the retirement of Mowi Scotland’s Steve Bracken, who had been in the driving seat since the beginning, highlighted three main areas that needed pinning down.
These were training; incorporating innovation into the standard so it could accommodate technological advances; and implementation.
By the time Smith left, he said much progress had been made in the training requirement and Anderson agrees this is ‘coming along fine’, with Iain MacIntyre of the Scottish Salmon Company overseeing a set of on-farm training measures he has already introduced at the SSC.
And she also agreed with Smith that continuing to update the standard was very important and that it would be a work in progress.
But perhaps the biggest sticking point – whether to implement the standard via legislation or through the industry’s (voluntary) Code of Good Practice – could be resolved quite simply, Anderson believes.
She said she would not recommend the Code of Good Practice route, more for political and public perception reasons than anything else.
‘I think if you look at the wider context in which the industry operates, there is a huge amount of work that’s done exactly as expected by regulators but it’s not recognised as being done.
‘A case in point would be the sea lice numbers and sea lice submissions. That’s been a formal requirement by the Fish Health Inspectorate to provide that information. People say the industry doesn’t do mandatory provision but it does.’
She doesn’t recommend legislation either, but thinks the standard could become part of licensing agreements.
‘A Code of Good Practice should always be about moving beyond what legislation sets. But I think in the era we’re in, there are other mechanisms which could be appropriately used.
‘In terms of having the core standard that you’re expected to adhere to, there are a number of mechanisms that are open to the Scottish government to deploy- one of which would be through the conditions of a licence.
‘There is a real need to review the licences that the industry holds, go back into the core requirements…and ensure it is translating the detail that is required.’
In the wake of the two Scottish parliamentary inquiries into salmon farming last year, the Scottish Technical Standard must provide confidence in the industry, she said.
‘The industry, as much as its detractors and the wider public, needs strong regulation – it’s a supportive tool. There isn’t anything individuals should be shying away from.
‘The difficulty we have is this wooliness, this lack of understanding of the controls and the application of those controls.
‘We see that woven through the reports both from the ECCLR [Environment, Climate Change and Land Reform] and the REC [Rural Economy and Connectivity] committees. I don’t think we want to repeat that. We need to make it clear.’
Some of the detractors Anderson mentioned sit on the Salmon Interactions Group, chaired by John Goodlad, which was set up, along with the Farmed Fish Health Framework [FFHF] last year. They have their own views on containment.
‘There is not so much a crossover, although that doesn’t stop individuals commenting. There are a number of individuals who sit in at all three [industry groups]. I for one!
‘There has been quite a lot of dialogue around containment, with respect to escapes, a topic that has arisen at the Interactions Group,’ she said.
But it is ‘further down the list on the Farmed Fish Health Framework, where the industry attendees are very conscious that their counterparts attend the containment group so this is being dealt with’.
The implication is that the people on the FFHF will know how much the sector is spending on containment but many of the Interactions Group come at it from a different angle.
The ever greater scrutiny of the industry, which its leaders say they welcome, increases the pressure to produce a Scottish Technical Standard that is beyond reproach.
Anderson is aware of the hurdles ahead, but said the industry was committed to deliver, ‘the progress reports are all in train’, and there will definitely be another meeting this side of Christmas.
‘There is a big workload; as you’d expect from the REC, everyone was criticised and everyone wants to be seen to be doing something.’
Everyone is working towards the 2020 implementation but there are areas where further work will be required”