14 February 2019 – Just over a year ago, the European Commission (EC) issued Regulation (EU) 2018/183 banning the use of formaldehyde as a feed additive. The ban entered into force on 1 March 2018, despite warnings that the decision would make it harder to combat Salmonella occurrence in feed.

Transition periods, which expired during the summer months of 2018, were applied to the existing use of formaldehyde as a preservative in skimmed milk for piglets, or in premixes or finished feed. Only the use of formaldehyde in the decontamination of feed mill environments was unaffected by the law as this was previously regulated under the Biocidal Products Regulation (Regulation (EU) 2012/528).

The ban was heavily contested by some in the industry as the EC’s initial plan was to reauthorise formaldehyde as a feed additive for a 10-year period, due to the long history of its safe use in Europe. However, the EC later proposed to deny its authorisation on the basis on EFSA risk assessments issued in 2014, concluding that there was no health risk for consumers exposed to this substance through the food chain, but warning that its inhalation might cause cancer and called for measures to reduce worker exposure to feed containing formaldehyde.

The formaldehyde controversy also came at a time when Salmonella is being put into the media’s spotlight, especially when the results of a December 2017 European Centre for Disease Prevention and Control (ECDC)/EFSA report found that Salmonella cases in humans since 2014 had increased by 3%, and in laying hens, the prevalence increased from 0.7% to 1.21% over the same period. Meanwhile, the RASFF notification system has identified a more than 50% increase in notifications for Salmonella.

In its denial proposal, the EC stated its intention to transition away from formaldehyde to other solutions. One problem, however, lies in the much-shared opinion that there is no clear scientific evidence to back-up this statement by the EC and that there is no product as effective as formaldehyde, due to its superior residual effect and the fact that it can eliminate Salmonella in contaminated feed.

Now that Regulation (EU) 2018/183 has been in place for a year, Feedinfo News Service invited a few companies involved in alternative to formaldehyde solutions to assess the situation.

Asked how livestock producers have been able to mitigate the Salmonella risk in feed since the enforcement of the ban in March 2018 and what kind of products they have turned to in the absence of formaldehyde, organic acids were quick to be mentioned.

“We have seen an increased demand for our feed hygiene solutions that are organic acid based and have shown to be effective at managing the problem from feed producers,” explained Geert Wielsma, Vice President Business Development for Perstorp Animal Nutrition.

“Effective and safer alternatives for formaldehyde are organic acids,” added Trouw Nutrition. “However, it is vital that companies use an integrated approach, combining feed, farm and health management, which requires specific expertise.”

Anitox, which offers as a synergistic blend of phytochemicals and carboxylic acids as a formaldehyde substitution product, isn’t necessarily in agreement that organic acids are the most appropriate alternative.

“The economics of staying Salmonella-free aren’t easy, particularly for those operating to least-cost formulations. As a result some producers have stopped treating completely, while others have sacrificed residual protection in favour of the very limited protections offered by traditional organic acids,” argued Anitox’s CEO, Dr. Rick Phillips. “Those producers who switched to low cost organic acids and reported no adverse effects in the immediate period after the change are now seeing incident levels rise, forcing them to revisit decisions and look again at the need for a product with real residual efficacy.”

Despite the removal of formaldehyde from the equation, Salmonella-in-feed risk management in the EU is achievable, though not without its challenges, argue the companies.

Heat treatment of feed is one option, but Perstorp Animal Nutrition warned that this does not address the issue of potential recontamination, either in the feed mill itself, or during transport to the end user. Additionally this can increase energy costs for the feed mill.

“By adding a proven feed hygiene solution such as those offered by Perstorp Animal Nutrition you can manage Salmonella with several approaches. Evidence shows that one can choose to add organic acids in combination with heat treatment, but at a lower temperature, which saves on energy costs and reduces the risk of nutrients being destroyed due to excessive heat exposure. If you are unable to heat treat at all then adding a proven feed hygiene solution like Perstorp’s can manage it for you. In both cases the presence of organic acids secures the feed from potential recontamination – an advantage even over formaldehyde,” Geert Wielsma commented.

Trouw Nutrition also highlighted the importance of implementing an integrated approach in feed, farm and health management. The company has a Feed Safety programme which includes the identification of Critical Control Points and is seen to reduce the risk of (re-)contamination during production.

“When applying our Feed Safety programme, the risk of Salmonella-positive cases in raw materials and feed can be reduced to a minimum,” said Mr. Geert van Houte, Global Programme Manager Feed Safety at Trouw Nutrition. “The Feed Safety programme focuses on reduction of microbial risks from the processing of raw materials, throughout the feed production line and storage of final products.”

Meanwhile Anitox’s Dr. Phillips pointed out that the scale of the challenge cannot be underestimated.

“Collaboration is very evident as our industry pulls together to protect itself. We’re seeing substantial investment, not only in new technologies but in the tools required to maximise their efficient use,” he said. “And as an industry we’re close to breakthroughs in diagnostics which will help us pinpoint challenges so precisely that we’ll see a revolution in the way chemical intervention is targeted to tackle pathogen control across the production chain.”

Farmers around Europe took part in an EC public consultation on the formaldehyde issue, where the feedback was overwhelmingly in favour of formaldehyde’s continued use. And although the EC is aware of the consultation, the ban remains in place.

And perhaps with the exception of the SCoPAFF Animal Nutrition meeting in December 2018 where there was a brief discussion on the use of formaldehyde as a processing aid which did not lead to any approval, the EC has not changed its stance with regard to formaldehyde in feed.

“Attempts to challenge the EU on its failure to give due consideration to those opinions have failed,” said Anitox’s Dr. Phillips. “But there is one key point to note here: while the EU’s stance may not have changed as a result of those 90+ supporting voices from organisations across the globe, respondents had a definitive impact on industry and regulator opinions in non-EU territories.”

As some Member States did not have an alternative for formaldehyde yet, many objections were raised at the time of the ban. But the proverbial heat has died down to some extent since then.

“Since the ban was implemented, these objections have greatly decreased and it seems that member states have accepted the ban and have moved to implement alternative solutions,” said Mr. Reinder Sijtsma, Government Relations and Regulatory Affairs Director of Nutreco (Trouw Nutrition’s parent company).

Perstorp Animal Nutrition also highlighted the fact that the market had been anticipating the formaldehyde ban for a few years already and as such people had already been looking at alternatives before it became effective.

“Also in several EU countries the use of formaldehyde was a ‘no-go’ for years already so a lot of organic acid-based additives were in use before the ban,” Perstorp’s Geert Wielsma commented.

But going back to Salmonella occurrence in feed and whether an uptick in contaminations has happened since the ban has been in place, it is still too early to fully measure the impact.

“As the ban on the use of formaldehyde allowed for a withdrawal period, we can only effectively look back to two quarters without formaldehyde use. Subsequently, as the RASFF annual report for 2018 is not yet published, it is too soon to draw conclusions about Salmonella prevalence,” said Trouw Nutrition.

And though the data is not out yet, Dr. Rick Phillips of Anitox has reason to believe that past evidence is an indicator of the figures to come.

“You need to dig into the figures to get the true picture,” he said. “The UK APHA report shows Salmonella isolation from poultry feed was higher in 2017 than in any year since 2013, at just over 3 times levels found in 2016. The latest ECDC report wraps together Salmonella infections in humans acquired inside and outside the EU … Dig deeper and you find that S. Enteriditis – found in the high profile three-year Polish egg outbreak that continues to impact consumers in 14 EU countries – is the most common serovar reported in human cases. Human illness caused by S. Enteriditis has risen consistently from 2012, with the biggest jump in 2016-2017 coinciding with formaldehyde bans in key territories. The number of flocks testing salmonella-positive is increasing too, so the evidence continues to suggest ‘cause and effect.’”