The U.S. Environmental Protection Agency is evaluating formaldehyde under the Federal Fungicide, Insecticide and Rodenticide Act (FIFRA), as part of registration review, a process EPA conducts for all currently registered pesticides every 15 years to ensure that products can carry out their intended function without creating unreasonable adverse effects to human health and the environment.

NCC this week joined American Farm Bureau Federation, American Feed Industry Association, National Pork Producers Council, National Turkey Federation, United Egg Producers, and U.S. Poultry & Egg Association in expressing concerns regarding EPA’s authority to impact the U.S. supply chain and the use of animal agriculture applications of formaldehyde under both
FIFRA Registration Review and the Agency’s ongoing risk evaluation process.

The organizations have communicated to EPA on several occasions during its review process – as well as to the U.S. Department of Agriculture’s Office of Policy and Pest Management – on the important uses of formaldehyde in key agriculture operations. Formaldehyde is utilized as an essential tool for the industry in several areas including, among others:

  • Pathogen control in animal feed production;
  • Sterilization and disinfection in egg hatcheries; and
  • Disinfection for live production operations on poultry farms and swine operations.

Formaldehyde-based products can be used to inactivate highly contagious viruses, such as African swine fever (ASF) and Highly Pathogenic Avian Influenza (HPAI). Credible estimates indicate that an ASF event in the U.S. could result in an economic loss of nearly $50 billion and would be catastrophic to the nation’s swine industry. In addition, the United States is in year three of an ongoing HPAI outbreak in which over 91,000,000 birds have been lost as part of what is now the most significant animal disease outbreak in the country.

Given the critical importance of these uses, the groups highlighted several issues as a starting point for discussions with EPA’s Office of Pesticide Programs and USDA’s Office of Pest Management Policy, including;

  • Data deficiencies;
  • Exposure and risk;
  • Zero reported incidents; and
  • Existing mitigation measures.

The comments can be read in their entirety here.