Third party review of the fish health audit and surveillance program
This report provides findings and recommendations of an independent review of the Fish Health Audit and Surveillance Program (FHASP). The review was commissioned by the Department of Fisheries and Oceans (DFO) as part of a process of ongoing improvement.
The review focussed on addressing three key questions:
- Are the objectives of the FHASP clear and consistent with broad policy goals and epidemiological principles of disease surveillance?
- What are the strengths and weaknesses of the FHASP?
- How could the design, implementation and outputs of the program (including reporting) be improved?
The review was based on a formal framework for evaluation of animal health surveillance systems. It included a desk-top review of relevant documents and extensive discussion with people from government and the salmon aquaculture industry.
The FHASP is highly relevant within the biological, societal and political context of salmon aquaculture in British Columbia (B.C.). DFO has a mandate to protect wild fish and there is a high level of public interest in the well-being of wild fish and the environment—it is reasonable (and widely expected) that the government continues to play a strong role in regulating aquaculture in the coastal waters of B.C.
The design of the FHASP has changed little since its inception as a provincial program in 2002. It became a program of the national government in 2010 and it contributes to DFO's goals of protecting the health of wild fish, preventing and controlling diseases in farmed salmon, and enhancing transparency in the government's regulation of marine aquaculture.
At the program level, the FHASP is intended to provide surveillance information to support decisions and policies. It also monitors industry compliance with health-related elements of the conditions of licence and health management plans (HMPs) under which the salmon farms operate.
Operationally, the FHASP covers all active salmon farms operating in the coastal waters of B.C. Program activities include standard-setting (for example, through technical review of HMPs and associated standard operating procedures), active surveillance, monitoring of compliance, and analysis of program-generated and industry-reported surveillance data. The program conducts analyses and produces reports to inform government decision-makers and a range of stakeholders including the public.
The program has many strengths. It is directed and operated by dedicated and highly proficient personnel who collectively hold a wealth of scientific and corporate knowledge. The passive surveillance component of the program (based on industry reporting in accordance with HMPs and conditions of licence) has complete coverage of farmed salmon at marine sites. Active surveillance includes thorough necropsy and detailed laboratory investigation, complementing the surveillance conducted by industry. Frequent farm audits provide scrutiny of industry practices and demonstrate the government's commitment to regulatory oversight. In combination, data generated by industry and by the FHASP have great potential to inform government decision makers, and industry and public stakeholders, about the health status of farmed salmon.
This review found that improvement in some areas is required if the program is to fully realise its potential benefits. Key weaknesses that currently limit the positive impact of the program include:
- A lack of clear goals and objectives—this makes it harder to communicate, allocate resources efficiently and monitor the performance of the program
- Inefficient data management systems and a lack of analytical capacity
- A lack of timely provision of information in a form tailored to the needs of various groups
- Relatively little use of the large amount of surveillance data generated by the salmon aquaculture companies.
Building on existing strengths and the findings of this review, there are two broad approaches that may be taken to improve the FHASP. The first builds on the design and fundamental elements of the current program. This approach would consider implementation of 18 recommendations arising from this review: these are summarised in Section 7 of this report. Implementation of these recommendations is likely to be straightforward and would result in incremental (but nonetheless substantial) improvements in efficiency, effectiveness and impact.
An alternative approach is to take more fulsome advantage of the surveillance data routinely collected by industry. The surveillance system for farmed salmon in the coastal waters of B.C. consists of two components: government-led surveillance under the FHASP, and industry-led surveillance conducted both for commercial reasons (to prevent or reduce the effects of disease on production) and to comply with conditions of licences and HMPs. If the farms are monitoring fish health and investigating disease events as they are meant to, then industry surveillance is likely to out-perform government-led surveillance in every surveillance objective.
The alternative approach is based on a shift in the role of DFO and a greater sharing of industry data for the benefit of all concerned. With this approach, surveillance is conducted by industry and DFO's roles would be to:
- set standards and monitor compliance (i.e. audit) to ensure that industry surveillance meets international standards, is reliable and meets DFO's requirements
- support industry in adopting and maintaining the means to conduct effective surveillance
- collate, analyse, verify and report on industry surveillance data to meet DFO's existing (or slightly refined) surveillance objectives
- undertake targeted surveillance activities to generate additional data, if required, to achieve specific surveillance objectives.
Adoption of this approach would necessitate a reallocation of program resources and substantial changes to policies and practices around data-sharing. However, this approach has the potential to better meet the surveillance and information needs of government, industry and the public.
Email: AquacultureEngagement.XPAC@dfo-mpo.gc.ca for a full copy of the report.
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