Friday, November 4, 2011

Testing for ISA: Dr. Marty Responds

Dr. Gary Marty responded to my email below in a very detailed and technical response. I appreciate Dr. Marty's time in responding to my queries. I hope Dr. Marty will forgive me for doubting the efficacy and, for lack of better phrase, scientific sincerity in the testing regime for ISA in farmed salmon in recent years.

That is, I have no doubt that salmon farmers are very concerned for their own stocks and any outbreaks of ISA, for which I'm sure they test religiously. What I do not believe is that if any salmon farm tested positive for ISA that the public would have been alerted, or any testing done to see the effects on wild fish.

As the DFO Minister admitted in response to a 2005 petition to the Auditor General (by David Suzuki Fdn, the Georgia Strait Alliance et al) regarding the federal failure to test for diseases in salmon farms:

"The aquaculture industry is one of the fastest growing food production activities in the world. In Canada, aquaculture is a relatively new industry that has expanded rapidly over the last two decades. The Government of Canada recognizes the significant benefits to society associated with aquaculture and has made sustainable aquaculture development a key federal priority."
Which has unfortunately, in practice, meant that we're chasing the money and damn the consequences. Salmon farming is a $653 million dollar industry in Canada annually, and this buys some significant lobbying assistance.

The onus is very much on those employed by government—whether bureaucrats or scientists— to blow the whistle when they know they are being used in bad faith to stall or delay precautionary action that would prevent a catastrophe.

Dear Tyee,

By law, the UPEI finding that 3 Pacific salmon samples were positive by PCR for ISAV is under investigation by CFIA. It is unethical for any medical professional to comment on their investigation while it is ongoing. However, I can provide some general information about how medical professionals scrutinize PCR test results.

Imagine that the Animal Health Centre tested some sticklebacks for infectious pancreatic necrosis virus (IPNV) using the same PCR test that we used on samples from 4,726 farm salmon over the past 8 years; imagine that 3 of 60 tests came back positive. All tests on the farm salmon were negative, so we have a high degree of confidence that our farms are free of IPNV and they are not the source of IPNV.

The next question is whether the results in the stickleback are true positives or false positives. PCR tests detect only a very small segment of the entire virus genome; they do not detect the entire genome. We need to be sure that the small piece of DNA/RNA detected by the PCR test really is the virus as opposed to some other material that also contains the same small piece of DNA/RNA; this is especially important when dealing with a new species (e.g., stickleback) in which the PCR test has not been validated. Also, PCR tests are highly sensitive, and contamination might occur from a source other than the original sample.

Immediately, our veterinary virologist would question the results because IPNV is not known to be in BC, and sticklebacks are not known to be susceptible to IPNV. False positive results are relatively common, and we have several options for validating our findings. At a minimum, our virologist would probably do the following:

1) determine the size of the amplified PCR product (is it the size that it is supposed to be?);
2) sequence the nucleic acid in the PCR product (does the sequence match IPNV?).

Until these basic things have been confirmed, we would not report a positive test result.

We would also try to culture the virus on cell lines known to support the growth of IPNV. We do this because PCR tests can detect DNA/RNA sequences that are not complete viruses. Virus culture can take several weeks.

A separate question is whether the fish have the disease, Infectious Pancreatic Necrosis. Fish can often harbour a virus with no signs of disease. I would want to know if the stickleback had "classic lesions" of IPN. If histopathology was not included as part of our diagnostic process, we would be unable to conclude whether a PCR test result was associated with the disease IPN.

These are some of the standard procedures that we use in our laboratory to avoid reporting false test results.


Gary Marty
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Tuesday, November 1, 2011

Dear Dr. Marty, Part II

Here is Dr. Marty's response to my letter:

Dear fellow wild salmon advocates,
I fully support the investigation by CFIA to determine the significance of the PCR results reported by Dr. Kibenge's laboratory. Once we have those results, then we can decide on the best course of action.
Gary Marty

What wild salmon advocate Dr. Marty does not say is why such an investigation is necessary, how long it will take or what potential costs such a delay might have. I predict that if the CFIA has their way, they will find their investigation results "inconclusive" and that they "warrant further study" before any decisions are made— and no decisions that affect the corporate bottom line will be made.

As a fisheries biologist friend of mine said after reading Dr. Marty's email this evening:

"Marty's answer is so lame, I can't even believe it. Next we're going to hear ISA came from sticklebacks! Delay, distract, deny all over again."

Here is my reply to Dr. Marty:

Dear Dr. Marty,
Thank you for your response.
With respect, when there are repeated indications from a research lab of Dr. Kibenge's caliber—the OIE Reference Laboratory for ISA at the Atlantic Veterinary College— that we are seeing multiple infections across salmon species, wouldn't part of determining the "significance" of such findings be immediate testing of all salmon farms?
AS SFU's Rick Routledge said, "The potential impact of ISA cannot be taken lightly. There must be an immediate response to assess the extent of the outbreak, determine its source, and to eliminate all controllable sources of the virus."
In the public interest, a top-priority regime of tissue collection, testing and any necessary quarantine/culling must be imposed immediately and with complete transparency.
Tyee Bridge

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Monday, October 31, 2011

Dear Dr. Marty, Part I

Below is the text of an email I sent yesterday to Dr. Gary Marty, a fish pathologist for the BC Ministry of Agriculture and Lands.

Dear Dr. Marty,
Prior to 2008, when those who did not work for the Federal Reserve Board—advocacy groups & concerned citizens— questioned high-level policymakers about the wisdom and dangers of collateralized debt obligations (CDOs) and other dodgy financial instruments, they were often brushed aside with condescension: something along the lines of, "These matters are too complicated for you to understand."

We know where that led.

Similarly, recourse to the exacting procedures of scientific method, as pointed out by Davidson, Freudenberg and Gramling (see attached paper)* cannot be used as a tactic to delay precautionary action.

With your background you could lead the call for precautionary measures, which are clearly warranted with salmon farms, and could help prevent further catastrophes for wild salmon. You have a duty to the public as well as to those who pay your bills. I hope that you will act as a leader on this matter and recommend appropriate precautions, which must include immediate, intrusive, non-voluntary testing of random samples from all farms on BC's coast by a recognized third-party lab such as that of Dr. Kibenge, and prompt closure of any farms evidencing known salmon pathogens such as ISA.

I second Mr. Doumenc's questions below, and look forward to your response.

Tyee Bridge

*Click here for the SCAMs paper.
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Now that ISA (Infectious Salmon Anemia) has been found in Pacific sockeye and coho, and could only have arrived here via salmon farms, the federal government is in cut-and-cover mode.

Here's a letter from wild salmon campaigner Ivan Doumenc to a provincial researcher, Gary Marty (pictured at right), that is essential reading.

"Today, obviously, your comments convey a very different message – that the regulatory agencies in charge of protecting us against animal disease pandemics were asleep at the wheel, sloppy, complacent, dismissive, negligent, or worse."

Well said, Ivan.

Fish Pathologist
Animal Health Centre
BC Ministry of Agriculture & Lands
CC: the public

October 31, 2011

Dear Dr. Marty,

I am a member of the general public living in Vancouver. Over the past couple years I have become increasingly involved in the conservation of wild salmon. But who I am is not very relevant.
On August 31, 2011, while you were on the witness stand at the Cohen Commission, you made a rather stunning comment: “CFIA [the Canadian Food Inspection Agency] actually discourages us to test for international foreign animal diseases. They prefer that they be called.”

Let me provide some context.

You were being cross-examined by Mr. Spiegelman, counsel for Canada, and the topic was a report that Dr. Alexandra Morton wrote to CFIA inquiring about some possible cases of infectious salmon anemia (ISA) that she had found in the Commission's disclosure database.

Those suspected cases of ISA, it appears, turned out to be false alarms since CFIA responded to Dr. Morton’s query on May 16, 2011 by stating that “All cases were evaluated as NO RISK for ISA”.
But then, Mr. Spiegelman asked you some follow-up questions about how you – as a fish pathologist for the Province of B.C. – dealt with the risk of ISA, and what was your level of confidence that B.C. was protected from that disease.

And you stated:

“Throughout the audit program, we test between 600 and 800 fish every year, since 2003, with a highly sensitive and specific PCR test, and those have been all negative. And so that gives me a great deal of confidence that we don't have ISAV in British Columbia.

So in several of these cases, it's not routine, when you have that level of confidence, it's not routine to always test for it when it's not known to occur, especially when you always have this active audit program going on. In fact, CFIA actually discourages us to test for international foreign animal diseases. They prefer that they be called.

So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system.”

Your comments, I take it, were intended to convey the reassuring message that the risk of ISA in British Columbia was so low that CFIA considered systematic testing to be somewhat redundant and unnecessary.
What a difference six weeks can make! Today, obviously, your comments convey a very different message – that the regulatory agencies in charge of protecting us against animal disease pandemics were at sleep at the wheel, sloppy, complacent, dismissive, negligent, or worse.

I have four specific questions for you and would appreciate a detailed and prompt response on your part, given that time is of the essence in this matter.

1. Does CFIA actually discourage veterinarians with the B.C. Ministry of Agriculture from conducting tests on foreign animal diseases such as ISA? Is a phone call really the preferred means of communication that this agency encourages, rather than rigorous and formal laboratory tests? How did/does that policy on the part of CFIA specifically impact your work as a veterinarian?

2. When you said that “when you have that level of confidence, it's not routine to always test for [ISA] when it's not known to occur”, did you mean to say that you did not test potential cases of ISA systematically, or did you mean to say that you did perform those tests systematically in spite of CFIA encouraging you not to do that?

3. I assume that your “level of confidence” has been significantly downgraded by recent developments and that you now consider the disease situation in B.C. to be anything but “routine”. (Unless you would want to take the position that the two separate ISA tests performed by the OIE laboratory in Prince Edward Island are both faulty – in which case I will definitely want to hear your comments about that as well.) How do you intend to change/upgrade your own protocols and procedures to respond to the unfolding ISA crisis, now that you are no longer in “high confidence” territory?

4. Your comment “So the fish health, because there weren't requirements from CFIA before January, we sort of have a grandfather-type system” is unclear to me. I would appreciate if could elaborate on that.

Please provide any relevant documentation and/or explanations to support your answers.

In case you would want to dismiss my questions as being yet another overreaction from an uninformed member of the public, I would like to conclude by quoting from a letter by Dale Kelley, executive director of the Alaska Trollers Association, which was published in the Vancouver Sun this morning.

Her comments, I hope, will help convey to you the extreme level of urgency that the outside world places in this matter, as well as the potential dire consequences that inaction on the part of government – which you as a lead scientist represent – could involve:

“As the representative of Alaska fishermen who rely exclusively on the health of wild fish, I am appalled by the near-silence of the Canadian agencies responsible to protect them. I've reserved comment in hopes that they would send some signal to the public, and West Coast fishermen in particular, that Canada is proactively engaged with a "fish first" attitude.

On Friday Oct. 21 - more than a week after ISA was detected in B.C. salmon - Canadian officials issued a press release devoid of any sense of urgency. They announced they will run more tests, wait several weeks for results, and only then, if additional testing reveals ISA, stakeholders will be convened to, "identify and take appropriate next steps." Really?!”

Yours very truly,

Ivan Doumenc
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