1) There is no equivalent replacement to formaldehyde with the same level of efficacy. In the EC proposal, the reasoning for the denial is that there is another approved feed hygiene enhancer (formic acid) and therefore formaldehyde can be substituted. This line of reasoning seems quite unfounded especially given the differences in the efficacy of the two substances with regard to Salmonella kill rate and the fact that formic acid doesn’t protect feed after treatment from re-contamination.
2) EFSA has not raised a feed safety concern in terms of the treated product; usage safety concerns should be dealt with under the appropriate legislation (HSE at work/REACH).
3) If the Commission is to withdraw the option to use formaldehyde then the authorities should be prepared to discuss how to proportionately manage the potential for a higher incidence of Salmonella positives in feed (given the existing restrictive enforcement policies of many EU Member States)
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