There is now overwhelming evidence that PRV poses a risk to wild Pacific salmon, and salmon farming is amplifying those risks. I will review this body of work in my written submission to you, but the take-home message is that salmon farms are a source of infection to wild salmon, and infections are linked to disease, poor health and poor survival.
Despite all this evidence, most of which was gathered by DFO scientists themselves, DFO have largely proceeded as if these findings did not exist, and conclude that farms pose minimal risk. As a consequence, salmon have not received the protection they need.
While Dr. Miller's study was being hidden, DFO managers actively supported other scientists to work with the salmon farming industry to undermine her findings, making claims that PRV does not cause disease. My scientific evaluation is that none of this work rules out the possibility or negates existing evidence that PRV can, and does, cause disease in salmon.
PRV sent from B.C. to Norway has been shown to cause the same patterns of disease that occur on farms in B.C., but DFO continues to ignore this result since the study was conducted in Norway. For some reason, DFO requires disease relationships to be proven within Canada.
Can you imagine if we used similar thresholds in human medicine? The COVID virus would not be classified as a disease agent in Canada, since the only human challenge trial was conducted in the U.K.
DFO's CSAS review found that PRV cannot be the cause of disease because it can be found in healthy fish and without high mortality on farms. This is just like saying that COVID does not cause disease because some infected individuals are asymptomatic. Making such fundamental errors in reasoning makes me very concerned that DFO is not providing evidence-based science in line with their scientific integrity principles.
DFO's science relies on the selection of industry-funded lab studies, which place a high bar in their definition of what constitutes “disease”. Meanwhile, research that does find evidence of harm is ignored or suppressed. This raises questions of whether conflict of interest could have influenced how CSAS reviews were designed, interpreted and reported.
One of Canada's top fishery scientists, Jeffrey Hutchings, posed this question: “Are we interested in preventing disease, or the semantics of whether mortality events meet the right definitions?” This simple question is a powerful statement on how DFO has mismanaged this issue using restrictive definitions and cherry-picking data to fit a narrative. DFO has repeatedly lost in court, because their management of pathogens on farms is deemed unlawful and their decision-making lacks transparency.
The response from DFO officials will be that the CSAS process meets peer review standards. You have heard from previous witnesses some of the problems of the CSAS process. For instance, the panel can be dominated by participants with close ties to the industry. Normally in science, reviewers who have a conflict of interest are often excluded, especially if the conflict is financial. Would you ask a tobacco company to review the science risks concerning lung cancer?
The examples that this committee has heard illustrate how science advice from DFO is not always accurate, reliable, up to date or free from political and commercial interference. The assessment and summary of scientific information to decision-makers need to be free from vested interests. My recommendation is for an independent fisheries science body that would be able to review and weigh evidence, especially in light of conflicts of interest.
Thank you very much for the opportunity to present today.