Guest Post: What Are the Possible Implications of Maleic Hydrazide Prohibition?
Paul Featherstone, procurement director for SugaRich, shares his initial thoughts on the EU decision to prohibit the use of maleic hydrazide (MH) treated potatoes and potato derivatives in the animal feed industry, and its likely negative impact.
A significant change in legislation
The EU legislation authorising the use of maleic hydrazide (MH) to inhibit potato sprout growth was revised and re-approved for use in November 2017. Following the requests for re-authorisation by manufacturers, Article 29(6) of the EC Regulations 1107/2009, was revised and re-issued allowing the use of MH, but with one rather significant caveat which says:
“Member States shall ensure, where appropriate that the label of the treated crops included the indication that the crops were treated with maleic hydrazide and the accompanying instructions to avoid exposure of the livestock.”
As a professional working in the animal feed industry, this condition is cause for alarm in my opinion, as its implications are wide reaching. The new regulation on MH usage means the potatoes themselves, their peelings, any potato products derived from MH treated crops cannot be added to animal feed. This decision affects many areas of potato processing or co-processing, crop trade and potato derived former food stuffs, with MH exposed content.
Possible impact of a blanket ban
The impact of this decision on the UK animal feed sector is huge. The company I represent processes former foodstuffs (such as potato snacks, cakes, cereals) and re-purposes them into high quality animal feed. A high percentage of the former foodstuffs that we process includes potato content, including potato starch.
After discussions with industry colleagues on this new MH usage decision, we estimate that one million tonnes of MH treated potatoes or potato-based products, when removed from the food chain, could negatively impact ancillary feed businesses to the amount of approximately £130m per year. Of course, it won’t just be the UK that’s affected, because this regulation applies EU wide, therefore, the probable impact will be at least ten-fold if you include the EU countries.
There is no disguising that the effect on the UK animal feed industry is massive. Furthermore, if we consider that the UK government has recently unveiled its Waste and Resource Strategy , which tables food waste as a priority, the new decision on MH usage will be a backward step for us. This decision ultimately pushes 10 million tonnes of viable former foodstuffs below the line into the ‘waste’ category, rather than resource, across the EU.
We should move forward with process, not panic
To date, the EU has undertaken a data search on maleic hydrazide. It appears that their decision about MH is possibly flawed purely due to a data gap. This is because of a carcinogenic metabolite of MH – 3-pyridazinone – which the EU thinks might be produced during farm livestock digestion. There is no proof to either confirm or deny this , resulting in the restriction being applied as a ‘blanket provision’ across all re-usable potato content food stuffs. Yet, it is a seemingly disproportionate reaction, as the perceived risk to livestock has not been demonstrated in the initial trials.
The MH manufacturers are undertaking the prescribed trial work to prove or disprove the alleged risk to livestock and work through a detailed risk assessment. However, there is a long wait, as this testing will not be complete until Q4 in 2019. After these results are released, the findings will need to be presented to EFSA (European Food Safety Authority). It could take another 12-18 months for EFSA to respond to the findings.
A great deal of economic damage could be wrought in the animal feed market in that two-year gap, not to mention elevated frustration if it were proved to be an unnecessary ban. However, when all the trials are completed, the EU Commission and associated bodies may be proven correct in their original decision.
There must be proportionate response to unsubstantiated risk
Like our other EU counterparts, the UK regulators are compelled to follow the EU Commission’s mandate on MH. However, the concurrent challenge in the UK/EU animal feed sector, is to galvanise on the issue and approach the EU Commission cohesively. This is how we ensure a complete risk management and chemical analysis investigation is carried out to obtain full and final evidence that this blanket ban is indeed necessary.
So, what are the possible negative impacts of the MH ban in animal feed? We can speculate that landfill usage will dramatically escalate to two years’ worth of material as farmers dispose of MH treated excess crops, that would have otherwise been used as fresh animal feed. Brands may suffer reputational damage. There’s the matter of how to fill the nutritional vacuum left by removing hitherto, viable, re-usable feed materials in the industry. Finally, the possible task of re-building the industry in two years’ time, if the MH decision proves to be ill-conceived and unnecessary.
It is not my intention to give the pessimist’s view, but hopefully be a voice of reason. We should always be risk averse, but our responses to risk should be proportionate to the possible danger, not creating another disaster. In the end, a solution that creates a crisis, has defeated its purpose. We should look to find a reasonable solution using solid measurable data.
SugaRich recovers surplus materials from food manufacturers, food distributors and food retailers and turn them into nutritionally balanced, high performance animal feed ingredients that are environmentally friendly, cost effective and increase productivity.