AFIA Continues to Encourage Science-based EPA Review of Formaldehyde

Written by: Gary Huddleston   |   July 9, 2024

formaldehyde, EPA, Regulations, Sound Science

Formaldehyde has recently been a hot topic for the American Feed Industry Association, as the Environmental Protection Agency is looking to ban all industrial uses of this chemical. As we have written about before on this blog, formaldehyde plays a critical role in controlling pathogens in animal feed, and we have been working tirelessly to ensure the EPA’s process is both transparent and rooted in science, given its future implications for other reviews of chemical products.  

The EPA's proposed stringent regulations on formaldehyde could set a precedent for how the agency reviews other chemicals in the future. This approach could lead to increased scrutiny and regulatory burdens on industries, like feed manufacturing, that rely on various chemicals and potentially impact their production processes and economic viability.  

This signals a shift toward more precautionary measures in chemical regulation, rather than scientific-based measures. We believe the EPA has not used the best science in its risk assessments over the past several years and is inflating the risks to workers with little regard to the safety mechanisms (e.g., personal protective gear, mechanical applicators) that industry has in place to safeguard employees. 

Recently, we took this message to the EPA Science Advisory Committee on Chemicals (SACC), which conducted a peer review of the 2024 Draft Risk Evaluation for Formaldehyde, stressing the need for a science-based review to avoid unreasonable risk determinations that could lead to unachievable workplace standards and compromised food safety. We reminded the agency and the SACC that the Toxic Substances Control Act (TSCA) mandates that it should consider the economic, health and environmental impacts of its regulations.  

Further, we pointed out that section 6(g) of TSCA allows the EPA to grant exemptions for chemicals that have no feasible alternatives and are critical for specific uses:  

Since few alternatives to formaldehyde exist, we believe that the EPA should not reduce tools in our industry’s toolbox and that the SACC should consider the public health consequences if formaldehyde-containing feed additives are no longer available to the production of animal food and the safety of our food supply. 

The EPA's proposed low exposure limits lack justification and could effectively halt formaldehyde production. This flawed process threatens our industry, as removing this tool could have significant animal and public food safety economics along with economic repercussions, affecting food prices and availability for consumers. 

With that said, we continue to support the Sound Science for Farmers Act of 2024 (S.3719), which aims to ensure that agricultural policies and regulations are based on the best available scientific evidence. By promoting transparency and accountability in the regulatory process, this bill would ensure that decisions impacting the agricultural community are grounded in robust scientific research. 

The AFIA will continue to encourage accountability from the EPA as it evaluates the risks of formaldehyde. We cannot discount the historical safety record of formaldehyde used in feed and its indispensable role in pathogen control and emerging disease prevention. By understanding and appreciating the multifaceted benefits of formaldehyde in animal feed, stakeholders can better advocate for regulations that protect public health and the agricultural economy for years to come.