Possible impact of fin-fish aquaculture on human health
Some submitters expressed concerns about the possible impact of the fin-fish
industry on human health. These concerns can be grouped into two general
issues: first, the direct impact of farming operations on residents of nearby
communities; and secondly, the possible impact on human health through the
consumption of farmed fish.
Impact on nearby communities
The committee received a number of submissions from local residents in
the Huon Estuary and the D'Entrecasteaux Channel areas. Residents pointed to
aquaculture activities which, they stated, affected their physical and psychological
health and wellbeing. Of particular concern to submitters were night-time
disturbances from bright lights used on leases, noise and vibration associated
with boat movements and disturbances from trucks on shore.
Submitters stated that noise arises from a variety of activities on fish
farming leases including:
the operation of special purpose vessels and equipment associated
with fish farms;
barges, service boats, feed supply and support vessels and tugs
moving between leases trucks entering and leaving shore based facilities;
venturation, a process of raising dissolved oxygen (DO) levels in
the water for fish health management purposes during the warmer summer months,
potentially 24 hours per day;
air lift, the process of recovering fish from the pens using
compressed air lift systems, which is commonly used during emergencies where
large numbers of mortalities occur that need to be removed from pens quickly;
fish feeding where pellets from the feed barge are blown by a
compressor along high density polyethylene (HDPE) pipes that run to individual
pen lighting powered by generators on the farm barge located
within the lease, which may be required to operate 24 hours per day depending
on environmental conditions; and
shore facilities and marine traffic associated with leases.
Light pollution arises from lighting of farming structures, including
fish pens, and boats.
The Marine Farming Planning Act 1995 requires a person preparing
a marine farming development plan (MFDP) to identify management controls that
contain any measure necessary to satisfactorily manage and mitigate the
negative effects of the proposal. Management controls may include provisions
relating to the restrictions on noise, light or presence in a marine farming
Submitters also pointed to the Huon River and Port Esperance MFDP, which states
3.9.2 Lessees are to ensure that light generated from marine
farming operations does not create a nuisance to the general community...
3.12.2 Lessees must comply with guidelines on noise emissions
made pursuant to the Environmental Management and Pollution Control Act 1994
for marine farming operations.
However, it was argued by some local residents that these conditions
have been ignored; indeed, light and noise from farming operations continue to
increase. One submitter from the Huon Estuary stated that the light 'has never
been as offensive or obtrusive as it is currently'.
Other residents commented on the light and noise from aquaculture operations:
Ten years ago we bought a magnificent block of land with
outstanding views and built a home. We looked across Port Esperance with
guaranteed peace and privacy day and night. We were attracted by the 'clean,
green image' of this area and impressed with the health benefits and serenity
of our land.
We now have lights right though our home at all hours of the
night and have had to cover windows to avoid being woken by an ever increasing
battery of colour and brilliance. One of our outlooks is across to Bruny Island
and up the Channel and this is currently under attack. There will be the cost
of more window coverings and a more commercial and ugly landscape developed.
We suffer sleep deprivation. We understand the loss of amenity
will affect the sale of our property yet, we were here first. No-one wants to
listen, least of all Tassal or Huon Aquaculture.
There is a continual expansion of water traffic with larger,
noisier vessels spoiling the tranquillity and creating sailing hazards across
this beautiful waterway.
Considerable evidence was received by the committee concerning the
operation of Huon Aquaculture's well boat, Ronja Huon. This boat
operates on the Huon River and Cnr Rosalie Woodruff commented that it has a
'very deep, loud and penetrating rumble from its motors, and has extremely
bright lights...that are clearly visible from the shore'.
It was stated that the Ronja Huon operates over extended times and a
While there is undoubted reduced 'towing' noise after the
introduction of the well boat, this is not the full story. This boat operates
almost 24/7, much more frequently than the previous towing operations. It operates
overnight and it has extensive and powerful light generating capacity to allow
it to do this. It is often accompanied by two smaller boats equipped with
powerful spot lights. Significant light pollution results. Light illuminates
the sky, the horizon and bedrooms along the coast. Moonrise, moonlight on the sea,
the dawn sky and auroras are obliterated. Flashes of light bright enough to
wake residents are frequent occurrences. All this accompanied by the hum of
The committee also received evidence that ongoing and persistent sleep
deprivation suffered by those living close to aquaculture activities has caused
mental and physical ill health.
The Tasmanian Aquaculture Reform Alliance, for example, submitted:
Sleep fatigue has consequences also for learning, daytime functioning
resulting in impaired judgement, reduced hand to eye coordination,
concentration and accidents. This is of particular concerns for residents in
the remoter areas of the Huon Valley and Tasman Peninsula who frequently
commute long distances to work.
The Tasmanian Aquaculture Reform Alliance went on to comment that stress
and anxiety has been reported by residents in areas close to aquaculture
Ms De-arne Webb, a Huon resident, outlined her concerns:
...I have been suffering for the last 10 months, I would think,
with severe depression and anxiety that got so bad due to sleep deprivation,
noise, reverberation and light impacting on home and my quality of life and my
sanctuary, which is my house.
Doctors for the Environment Australia (DEA), while noting the concerns
of residents, commented that 'overall, the extent of psychological impacts of
aquaculture activities on residents is poorly understood and requires
addressing as part of a broad investigation of the impacts of the aquaculture
on the health of Tasmanians'.
Evidence was received that concerns about light and noise have been
raised with the relevant companies, local
council and the Environment Protection Authority. However, the Tasmanian
Conservation Trust commented:
Attempts to find a solution to this problem by contact with
Government agencies and the aquaculture company have apparently been
unsuccessful. There is no effective complaints procedure in place that can equitably
address this type of issue.
Ms Christine Materia, Tasmanian Aquaculture Reform Alliance, added:
I think in the past the industry demonstrated that they were
not dealing with the mental health issues around noise in particular. Rather
than changing regulations, I think that it would be more for the industry to
actually develop internal policies and processes for dealing with those types
of issues and responding to the community. There is also a failure of
regulatory bodies such as local councils and the EPA to deal with the issues of
Response from industry
The Tasmanian Salmonid Growers Association (TSGA) responded to evidence
concerning the impact of light and noise on behalf of the industry and stated
The industry does not believe it has caused significant
modification to the natural environment to the extent suggested in the
submission and all companies act within visual and noise guidelines and
The industry is committed to working with the community
through consultation to identify concerns and has a strong track record of
being responsive to those concerns.
All companies within the industry have a responsibility to
respond to comments of mental and physical harm or illness regardless of the
cause. The industry does not accept that assisting residents through these
issues is an admission of responsibility or cause but an integral part of being
a responsible community member and corporate citizen.
In relation to concerns about the Ronja Huon, the TSGA stated:
The Ronja Huon specifically
provides [Huon Aquaculture] with the capacity to move offshore and farming at
these locations would not be possible without its use and the vessel allows the
safe bathing and transport of fish in higher-energy locations.
The 75 metre state of the art vessel is powered by a diesel
electric motor that readily complies with the Environmental Management and
Pollution Control (Miscellaneous Noise Regulation) 2014.
The vessel operates in a designated commercial shipping lane
(up the Huon River) and services marine farming sites in the Huon and D'Entrecasteaux
The Company is of the view that it is using best available
technology and employs best practice environmental management to reduce noise
emissions to the greatest reasonable extent. In addition, the Company has
continued to modify the operation of the vessel as far as possible to limit the
impact on residences.
The TSGA went on to note that 'all companies within the industry have
thorough complaint procedures in relation to noise from operations'. The
companies also conduct noise monitoring by independent agencies and the
regulator in order to ensure all vessels are compliant.
Huon Aquaculture and Tassal specifically addressed comments in relation
to noise from their operations on the Huon River. Huon Aquaculture stated that
all of its vessels are tested for noise emissions and those currently used are
compliant with the relevant noise regulations. In addition, it noted that it
has voluntarily limited towing operations on the Huon River so that all tow
vessels are south of Brabazon Point by 9.00 pm each day, except in
extenuating circumstances. The number of towing movements have also decreased
in this stretch of the river. The reduction in tows has been facilitated by the
use of the Ronja Huon. This boat is also compliant with the relevant
Tassal indicated to the committee that it was responsive to community
complaints and has a culture of 'beyond compliance'. Noise mitigation strategies
include changes to, and replacement of, equipment, limiting towing operations
to late afternoon, and adjusting the stocking strategy for the lease, where
possible, to minimise the noise impact.
The committee also received evidence from Dr Steve Carter, an
environmental engineer who has worked with Tassal on noise mitigation. Dr
Carter commented that Tassal has worked at reducing noise and has 'succeeded in
quieting down their marine and noise marine and land facilities'. Dr Carter
concluded 'Tassal now has more hands-on noise management experience than just about
any other industry in Tasmania'.
Other possible impacts on human health
A number of submitters commented on the potential for the activities of
the aquaculture industry to affect human health through contamination of target
and non-target species. In this regard, DEA pointed to the bioaccumulation and
contamination of the marine environment with polychlorinated biphenyls (PCBs)
and the use of antibiotics.
DEA noted that PCBs are 'persistent, cancer-causing chemicals that continue
to contaminate the environment and the food supply'.
Research from the United States and Canada was cited as demonstrating that PCB
contamination of farmed salmon is significant, being much higher than that
found in wild salmon. The research suggested that the cause of this
contamination is likely a consequence of elevated levels of contamination found
in commercial salmon feed.
Submitters noted that, while studies have been conducted on overseas
aquaculture operations, there are no comparable studies of PCB contamination of
Tasmanian farmed salmon or trout.
Antibiotics are used in aquaculture to treat outbreaks of disease in
farmed fish. For example, in 2014, Huon Aquaculture and Tassal treated an
outbreak of Yersinia at pens in Macquarie Harbour with antibiotics.
The Tasmanian Aquaculture Reform Alliance pointed to the large amounts
of, and different by types of, antibiotics used in fish farming. It stated that
studies indicated that antibiotic residue is present in sediment as well as
other fish species near fish farms.
Submitters stated that there was a danger to human health from the use of
antibiotics both in relation to elevated levels of residue and development of
antibiotic resistant bacteria.
The Tasmanian Conservation Trust argued that the use of antibiotics in
food production should be phased out, particularly given the rise of antibiotic
resistant bacteria and the implications for human health.
The DEA added that overseas studies need to be replicated in Tasmania.
Response from the industry
The fin-fish industry responded to concerns about antibiotic use and possible
PCB contamination on human health from farmed fish. The TSGA noted that 'the
industry continues and is committed to producing salmon which is safe and healthy
for the consumer and believes that adequate monitoring is undertaken to comply
with all food safety regulations'.
In relation to antibiotic use, the TSGA noted that they are never used
prophylactically or for growth promotion. Any salmon that are treated with
antibiotics undertake a lengthy withdrawal period to ensure that all residues
are cleansed from their system. Any group intended for harvest which falls
within a period of twice the stated withdrawal period will undergo flesh
testing for antibiotic residue. This complies with the Australia New Zealand
Food Standards Code for residue levels.
The TSGA went on to note that the industry's use of antibiotics is
strictly monitored, recorded and regulated and has, in fact, fallen
dramatically since 2008–09.
The TSGA commented that the reduction in antibiotic use has been achieved
through a greater focus on improving knowledge and research activities
targeting specific fish health issues.
Tassal provided the following explanation of its use of antibiotics:
Fish are not treated with antibiotics unless they are sick
and a bacterial disease is confirmed. Salmon which are treated with antibiotics
undergo an extended withdrawal period and are tested for antibiotic residues
before harvest. All harvest fish are food safe. Our goal is to continue to
reduce antibiotic use by improving fish husbandry through the Zero Harm for
Fish initiative, and move into preventative approaches for disease management
with the use of vaccines.
We have expected that our antibiotic use will now fluctuate around
this very low level of use.
The TSGA commented that the industry's preferred option was vaccination
and noted that significant investments have been made into the development of
vaccines with some success. However, until vaccines are developed for Tasmanian
conditions, antibiotics are still required.
In addition, the TSGA stated that stock inspections are a routine part
of farming activities and focus on disease monitoring and early detection.
Companies are also actively involved, along with the Tasmanian Government, in
the Tasmanian Salmonid Health Surveillance Program. This program provides
passive and active disease surveillance through regular submission of fish
diagnostic samples and testing for specific disease agents of concern.
The Department of Primary Industries, Parks, Water and Environment
annual report stated that the Tasmanian Salmonid Health Surveillance Program was
revised in 2013–14 by the introduction of company and regional quotas to ensure
samples were submitted consistently during the year and for all production
zones and compartments. It was stated that 'farm companies were provided with
monthly submission statistics and quarterly data based on regional data'.
Reports of antibiotic use are provided by Huon Aquaculture on its Sustainability
Dashboard and by Tassal in its annual Sustainability Report. For example, Huon
Aquaculture reported on the use of antibiotics from 2007.
Tassal's Sustainability Report 2014 also reported the use of antibiotics
to control an outbreak of Yersiniosis in Macquarie Harbour. This resulted in an
increase in antibiotic use in 2013–14 following a decline in previous years.
Tassal stated that:
Fish are currently vaccinated for the disease, but new
research efforts in 2015 will be placed into the development of a more efficacious
vaccination strategy for all of our sites. This will reduce the need for
antibiotics and increase performance and fish welfare.
In relation to the study cited in the DEA's submission concerning antibiotic
residue, the TSGA stated that the study did not include an assessment of
Tasmanian aquaculture and that 'different growing regions face varying
challenges, particularly in regards to antibiotic use'.
The TSGA concluded:
As with any animal production, antibiotics may be required in
fish farming from time to time, but their role and uses are poorly understood
by the general public and easy for critics and observers to interpret in a
The committee also notes that a review was undertaken by the Institute
for Marine and Antarctic Science (IMAS) in 2009 of ecological impact of the
antibiotics and antifoulants used in the Tasmanian salmonid aquaculture
industry. The IMAS provided information on the outcomes of the review:
Current data indicate that water column concentrations of
antibiotics are extremely low and consequently impacts on phytoplankton
communities are likely to be limited. The testing of wild fish with respect to
human health toxicity showed no risk to human health. The review suggested that
although major environmental changes are unlikely to have occurred,
identification of suitable indicator species would be valuable to ensure
ongoing sustainability. It also suggested that where antibiotics are used, a measure
of bioavailability rather than simply a measure of total residue level would be
preferable, and that the effect of local environmental conditions...on
ecotoxicity be assessed.
The review was followed up by a workshop at which government and
industry stakeholders and relevant experts discussed proposed future research.
In relation to PCBs, the TSGA commented that studies have found that
levels of PCBs and dioxins in fish species are low. In addition, the
Commonwealth Department of Agriculture conducts an annual national residue
survey (NRS) that regularly tests farmed salmon to ensure that they are safe
for human consumption. – industry has participated in this for almost a
decade. The TSGA added that 'tests in 2014 confirmed that Tasmanian salmon were
well within acceptable ranges for a wide range of potential contaminants based
on European Union Values and Food Standards Australia New Zealand'.
The TSGA also responded to comments about contamination of commercial
feed, and stated that the Tasmanian salmonid industry does not use feed
manufactured in Canada. One company providing feed to the industry, Skretting
Australia, undertakes testing to ensure quality. In 2014, all results from
Skretting Australia were within the Australian and European limits.
The committee acknowledges the concerns of local residents about the
impact of the fin-fish industry on their wellbeing through disturbances from
light, noise and vibration and understands the frustrations of individual
residents over perceived lack of response to complaints. However, the committee
is of the view that there is an adequate regulatory regime in place to address
these concerns and considers that residents should seek action through the
appropriate regulatory channels.
While having come to this view, the committee nonetheless considers that
the industry must continue to look for ways in which to diminish the impact of
light and noise on local residents particularly through changes to farming
operations and equipment used.
In relation to concerns about possible contamination of Tasmania-farmed
salmon through antibiotics or PCBs, the committee received no evidence that
this is the case. Australia has one of the most strongly regulated agricultural
sectors and it would be highly detrimental to the fin-fish industry should
there be any doubts about the quality of its product. Further, the committee
notes that the industry is funding research to limit the use of antibiotics and
is committed to ensuring the health of fish through appropriate farming
Senator Anne Urquhart
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