A transnational industry requires a transnational supply chain.  But the rapid expansion in fish farming has taken its toll on the natural environment and fish feed based on natural ingredients is increasingly scarce.  It ‘normally takes about four kilos of wild fish to grow one kilo of farmed salmon. In this way, instead of relieving pressure on the marine environment, fish farming is actually contributing to the overfishing crisis that plagues the world’s fisheries.’¹  Thus the fish farming industry has been looking for alternatives.  Among the alternatives tested are substitutes like palm oil, one of the least nutritionally beneficial foods in the human diet. So although much play is made of the salmon being ‘Scottish’ for marketing purposes, the food that the fish receive is unlikely to originate in the local ecosystem or to have its distinctive qualities. Or so it might have seemed until the appearance of a paper in Science that sparked the crisis in the Scottish industry.

On January 9 2004 Science, perhaps the most prestigious scientific journal in the world, published a study reporting that farmed salmon contained amounts of toxic chemicals known as Polychlorinated Biphenyls (PCBs) as well as other chemicals exceeding the recommended levels advised by the US Environmental Protection Agency (EPA).  According to the EPA, ‘Studies in humans provide supportive evidence for potential carcinogenic and non-carcinogenic effects of PCBs’.²

The following analysis is not simply about industry strategy or science communication.  It is not just a study of media coverage of salmon.  It is an account of how scientific research which does not fit the interests of industry can be neutralised.  It is a story that involves scientists, corporations, front groups, PR firms, ministers, civil servants and journalists.  It shows that the public get a dangerously distorted view of science from the media.  But this is relatively trivial compared with the main conclusion which is that vested interests operating together in a corporate/state two step are able to manage science and silence critics - even where these emanate from the most prestigious scientific journals in the world.  The interests of the industry prevailed in this case by means of misinformation, manipulation and subterfuge. The implication of this for theories of democracy and governance that emphasise popular consent is that consent is not always essential for the reproduction of power.³

For those concerned with the amplification of risk in public discourse, this story serves as a critical test case. It undermines arguments suggesting the problem of risk is one of public irrationality or activist misdeeds.  The corporations are amongst the promoters of this view because it serves their own interests, but it is also the view of a swathe of academic opinion.

Following the publication in Science, the industry, in a major PR effort, led journalists, policy makers and some sections of the public to believe that we were, in fact, victims of an orchestrated attack by environmentalists.  This was designed, they implied, to destroy livelihoods and undermine healthy eating advice for ideological reasons.  Brian Simpson, the head of the industry lobby group, Scottish Quality Salmon and the former UK Minister Brian Wilson, referred to the scientific study as ‘junk science’ and ‘pseudo-science’, respectively.⁴  These judgements were largely accepted by the media, even though they were wrong. This chapter tells the story of how the industry turned the story round and neutralised the issue.

The Original Study

The study on which the Science paper was based was undertaken at the Institute for Health and the Environment at the State University of New York, Albany, funded by the Pew Charitable Trust.  The study, entitled ‘Global Assessment of Organic Contaminants in Farmed Salmon’ tested for levels of ‘organochlorine contaminants in Farmed Atlantic salmon from eight major producing regions in the Northern and Southern hemispheres’.  For comparison, ‘samples of five wild species of Pacific salmon were obtained from different geographic regions. The analysis examined fourteen contaminants, focusing ‘additional analysis’ on ‘PCBs, dioxins, toxaphene, and dieldrin’ which ‘were consistently and significantly more concentrated in the farmed salmon as a group than in the wild salmon’.⁵

Poly Chlorinated Biphenyls (PCBs) are components popularly used in electrical manufacturing until 1977 when the US Congress prohibited their use due to high levels of toxicity.⁶  Dioxins are produced as a waste product of the production of some chemicals and on incineration of organic waste in the presence of chlorine. Toxaphene and Dieldrin are pesticides banned in the US in 1986 and 1990 respectively. PCBs (as a result of disposal methods) and dioxins and the pesticides (for obvious reasons) have found their way into the food chain.  Along with other organochlorine contaminants, they accumulate progressively in organisms over time meaning that those at the top of the food chain, humans, are exposed to the highest levels.

The authors stated clearly that ‘Individual contaminant concentrations in farmed and wild salmon do not exceed U.S. Food and Drug Administration (FDA) action or tolerance levels for PCBs and dieldrin. However, FDA action and tolerance levels are not strictly health-based, do not address the health risks of concurrent exposure to more than one contaminant, and do not provide guidance for acceptable levels of toxaphene and dioxins in fish tissue.’⁷ A key reason the authors used the EPA guidelines were that they were developed to understand multiple contaminant intake rather than intake of a single contaminant.

The results showed that farmed salmon contained levels of PCBs significantly higher than that of wild salmon with Scottish farmed salmon displaying the highest levels in the  sample.  The authors recommended: ‘The combined concentrations of PCBs, toxaphene, and dieldrin trigger stringent consumption advice for farmed salmon purchased from wholesalers and for store-bought farmed fillets. This advice is much more restrictive than consumption advice triggered by contaminants in the tissues of wild salmon.’ With reference to the EPA’s standards, they argued that safe consumption of the most toxic salmon (purchased in Frankfurt and farmed in the Faroe Islands and Scotland) should not exceed more than one half-portion of salmon per month.
The risks of other non-cancer ill effects (such as ‘adverse neurobehavioral and immune effects and endocrine disruption’⁸) were not factored into the advice because there are no recognised risk levels adopted by official agencies.  This is a crucial point in relation to the most important finding of the researchers.  Although they examined the concentrations of 14 contaminants they undertook additional analysis on four (including dioxins).  But the researchers only provided consumption advice based on risk levels for three of the contaminants (PCBs, dieldrin, toxaphene excluding dioxins).  The key reason for this was, as the researchers told us, ‘because of the international disagreement around dioxin risk assessment’.⁹  In particular, there is a disagreement on risk assessment between the EPA and other bodies such as the FDA and WHO. This became a key point on which the study was (wrongly) attacked.

Spinning the Story

Within a week of publication, the study was effectively neutralised as a threat to the industry.  To illustrate this we can examine coverage in The Scotsman, one of the two main ‘quality’ papers in Scotland. On the 9th of January the headline was: ‘Eating farm salmon "raises risk of cancer"‘.¹⁰   The following day the story was already being questioned: ‘Chemicals in fish are well known’.¹¹   Subsequent headlines became increasingly sceptical: ‘Salmon is safe says US food expert’,¹²  ‘Green campaigners fund salmon study’,¹³  ‘Salmon scare report was flawed and biased’¹⁴  and finally, ‘Claims of unsafe fish run contrary to the facts, say scientists’.¹⁵

The arguments against the study highlighted the alleged agenda of the foundation which funded the research and claimed that the authors had not used the most appropriate standards for measuring contaminants.  

Attack the Methods

The first major line of attack was simply to ignore the data and attack the standards against which the data had been evaluated.  But in a stunning series of errors the UK government and salmon industry responses fundamentally misinterpreted the science and criticised the paper on grounds which were simply scientifically irrelevant. Scottish Quality Salmon claimed that the authors ‘seem to have misapplied an already suspect risk model developed by the US Environmental Protection Agency’.¹⁶  The director of the UK government’s Food Standards Agency raised the EPA model explicitly.  Sir John Krebs wrote a letter to the Guardian arguing that ‘The EPA ...  bases its risk assessment on out-of-date science from 1991. The WHO takes into account the mechanism by which dioxins cause cancer. It concluded in 2001, using independent experts, that so long as dioxins were kept below thresholds, there would be no adverse effect upon health.’¹⁷   In a statement at the time the FSA elaborated on this claiming the EPA approach ‘has been evolving since 1991, but has not been finalised’.¹⁸

There is indeed an EPA process in progress since April 1991, but it is not the standard used by the authors of the paper.  It is however, useful to examine the extent to which the process beginning in 1991 supports the case made by the FSA. .  The report ‘Exposure and Human Health Reassessment of 2,3,7,8- Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds’ was revised in 1994 and on subsequent occasions, with the most recent draft being published in December 2003.¹⁹

According to the FSA, Krebs view was based on a report produced by the UK government Committee on Toxicity.  This 2001 report was published under the title COT statement on Dioxins and PCBs.²⁰   This report does not, however, seem to support the view that the EPA process is based on dated or flawed science.  The COT report did take a different view on the EPA approach, but not on the basis that it was outdated.

The COT report notes that ‘The EPA provided an excellent comprehensive review of the literature on developmental and reproductive toxicity, and although some new studies had emerged since it was written these did not have a major impact.’²¹   So, on two counts (the fact that the process was regularly revised and that the most recent version was some two years more up to date than the FSA’s own science) Krebs statement that the process was based on ‘out of date science’ is simply wrong. In fact the EPA process was more up to date (December 2003) than the FSA’s own preferred report (2001).

But more incredibly the FSA approach was not the standard used in the paper in Science.  Rather, the consumption advice was based on a different EPA process which assessed a different set of contaminants (PCBs as a whole, toxaphene and dieldrin). Given in note 25 of the paper this is: U.S. EPA, Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 2: Risk Assessment and Fish Consumption Limits (U.S. EPA, Washington, DC, ed. 3, 2000).²²   The Science article said nothing whatever about dioxins in relation to consumption.  The researchers specifically excluded dioxins from their conclusions because of the varying regulatory standards.  The FSA approach was, therefore, entirely mistaken.

Most critics of the study preferred to ignore the existence of the EPA altogether and claim that the findings were well within health and safety limits.  John Webster sometimes described by SQS as their ‘scientific adviser’, ‘stressed that the PCB and dioxin levels found in Scottish salmon were significantly lower than the thresholds set by international watchdogs such as the European Union, the Food Standards Agency (FSA) or even the US FDA.’²³  This is almost true but entirely irrelevant.  It is the level of dioxins and ‘dioxin like PCBs’ that were lower than the WHO and EU standards. This is quite different to PCBs as a whole.  In fact, neither the WHO nor the EU has established standards for consumption levels of PCBs as a whole or for toxaphene and Dieldrin.  So the SQS approach was entirely irrelevant too.

The erroneous response of the FSA and the salmon industry set the tone for other official agencies in the UK, which explicitly rested on the FSA as lead advisor.  Thereafter all official agencies presented a united front downplaying the risk as being inside WHO, EU and FDA guidelines.  This was simply false.  At best this approach was irresponsible, incompetent and scientifically illiterate.  At worst, a calculated deception.  

Targeting Hidden Agendas and activist ‘spin’

The second line of attack was to criticise the Pew Charitable Trust which funded the research, for having a hidden agenda.  It was characterised in the New York Times as an organisation ‘with…deep pockets and aggressive political advocacy, Pew is not only the most important new player, but the most controversial on the environmental scene.’²⁴   This kind of coverage was encouraged by the aquaculture industry which described Pew as ‘having taken a position against salmon farming’.²⁵   Pew was a ‘research body with an anti-pollution agenda’ in the Observer as if that was as bad as being ‘pro-pollution’.²⁶    Later, Scottish Quality Salmon described the Pew Trust in a press release as ‘the aggressively anti-industry US environmental group’.²⁷   The trust funded the research in the same way that other trusts fund scientific research. ‘"It is based on sound science and the results are undeniable", said George Lucier, former director of the US Department of Health’s national toxicological programme and author of more than 200 studies on toxic chemicals’.²⁸  In fact the critics largely accepted the science.  Instead they attempted to smear the funding agency.  The role played by the Trust, ‘was spelled out in the study, and highlighted by Science magazine,... Any suggestion that Pew interfered has been denied by all involved.’²⁹ 

‘Science’s editor-in-chief Donald Kennedy dismissed the allegations’, reported the Sunday Herald. ‘He said that the authors were all respected members of academic institutions. "Pew funded the study but left the authors free to publish their results without review," ... adding that Science’s peer-review process "is among the most rigorous in the scientific community"’³⁰

We can conclude that the science on which the paper was based was rigorous and indeed correct, as was acknowledged even by its critics.  An argument about which set of standards should be used is clearly possible, but the standards were not dreamt up by environmental activists but by US government officials and scientists.  The Pew Charitable Trust funds scientific research on environmental pollution.  But it is clear that its interests in researching pollution did not shape the conduct of the science.

This analysis has concentrated on the substance of the allegations against the study, showing that the concerns reported in the media were groundless, but not precisely how they gained circulation.  Was this a conspiracy of interest by the salmon farming industry or a result of news judgements which favour controversy over routine reporting? The industry and official bodies like the FSA had their own views on the study (highlighted above).  But a range of academic scientists were also quoted as critics. What was their role?  Were they badly briefed?  Was it a case of legitimate - if mistaken - dispute in the field of science?  Or was there another reason for the inaccurate and mistaken information given out by a range of scientists?

This is the first part of a three part article. Parts two and three will follow on Spinwatch. The full article can be found in Thinker, Faker, Spinner, Spy

NOTES

1.  Benn, J. ‘Norway - the rising tide of fish farming’ People and Planet, Posted: 19 November 2003 http://www.peopleandplanet.net/doc.php?id=2085

2. U.S Environmental Protection Agency ‘Health Effects of PCBs’  (8 September 2004) http://www.epa.gov/opptintr/pcb/effects.html

3. In other words, the use of the concept of hegemony (in the sense of persuasion and consent as opposed to its original sense of leadership and force) to explain the reproduction of power relations is less than adequate.  See D. Miller ‘Media Power and Class Power’ in L. Panitch and C. Leys (eds) Socialist Register 2002, for a discussion.

4.  Cited in Perry, D. ‘Call for cash offer to Scots fish farms’, Press and Journal, 7 September 2004, p.10; Simpson cited in Harris, G., ‘Scots farmed salmon leaps back on menu’ The Times, 29 October 2004. http://www.timesonline.co.uk/article/0,,2-1334836,00.html

5.  Ronald A. Hites, Jeffery A. Foran, David O. Carpenter, M. Coreen Hamilton, Barbara A. Knuth, Steven J. Schwager, ‘Global Assessment of Organic Contaminants in Farmed Salmon’ Science 9 January 2004: Vol. 303. no. 5655, p. 227.

6.  US Environmental Protection Agency, ‘Polychlorinated Biphenyls’  (8 September 2004) http://www.epa.gov/opptintr/pcb/

7. Hites et al, p. 228

8.  Hites et al Ibid.

9.  Jeffery Foran, personal correspondence by email 30 March 2006.

10.  Reynolds, J. ‘Eating farm salmon raises risk of cancer’, The Scotsman, 9 January 2004  http://news.scotsman.com/topics.cfm?tid=1080&id=27102004

11.  Reynolds, J. ‘Chemicals in fish are well known’ The Scotsman, 10 January 2004 http://business.scotsman.com/agriculture.cfm?id=31392004

12.  MacLeod, M.  ‘Salmon is safe says US food expert’, Scotland on Sunday, 11 January 2004 http://scotlandonsunday.scotsman.com/index.cfm?id=34952004

 
13.  McConville, B. & Reynolds, J.  ‘Green campaigners fund salmon study’, The Scotsman, 16 January 2004 http://thescotsman.scotsman.com/scotland.cfm?id=55262004

14.  Reynolds, J.  ‘Salmon scare report was flawed and biased’, The Scotsman, 16 January 2004 http://news.scotsman.com/print.cfm?id=55252004

15.  Bell, G. & Tocher D.  ‘Claims of unsafe fish run contrary to the facts, say scientists’, The Scotsman 16 January 2004  http://thescotsman.scotsman.com/scotland.cfm?id=54782004&20040927201412

16.  ‘Contaminants in the Environment’, Scottish Quality Salmon   http://www.scottishsalmon.co.uk/environment/contaminants.asp

17.  Krebs, J. Chairman, Food Standards Agency, ‘Health balance over farmed salmon’
The Guardian Monday January 12, 2004 http://www.guardian.co.uk/fish/story/0,,1121021,00.html

18.  Statement released under the Freedom of Information Act and described by the FSA as ‘temporarily placed on our website’ in January 2004.

19.  Latest versions available from http://www.epa.gov/ncea/pdfs/dioxin/nas-review/

20.   Fish consumption: benefits and risks part 8, Annexe 5: COT statement on dioxins and PCBs (pdf file 276kb) http://www.food.gov.uk/multimedia/pdfs/fishreport200408.pdf

21.  Ibid., p. 19.
22.  available at http://www.epa.gov/ost/fishadvice/volume2/index.html

23.  http://www.scottishsalmon.co.uk/mediacentre/releases/2004/080104.asp. Yet Webster is hardly independent of SQS as he is billed as working for ‘Scottish Quality Salmon’ on the SQS website and is listed as being contactable through the SQS switchboard. See for example, http://www.scottishsalmon.co.uk/media/releases/170904.html

24. McConville, B. & Reynolds, J.,  ibid
  25.http://www.farmfreshsalmon.org/images/PDFS/Farmed%20Salmon,%20PCBs,

%20Activist,%20and%20the%20Media.pdf

26.  ‘Handle with care’ The Observer, 15 February 2004, Observer Food Monthly  http://observer.guardian.co.uk/foodmonthly/story/0,,1145624,00.html

27.   Scottish Quality Salmon statement re publication of American PBDE research, http://www.scottishsalmon.co.uk/media/releases/100804.html

28.  Edwards, R. ‘Scientists back toxic salmon study’, Sunday Herald, 18 January 2004. http://www.sundayherald.com/39358

29. Ibid.

30. Ibid.