Download PDF
April 23, 2015

Oil Price Information Network Features Richard E. Engler, Ph.D., in “TSCA Nomenclature May Be Barri


The Oil Price Information Network (OPIS) spoke with BRAG's Richard E. Engler, Ph.D., Senior Policy Advisor with B&C, regarding the application of the Toxic Substances Control Act (TSCA) to oils made from algae feedstocks and other non-traditional bio-materials. The resulting article, "TSCA Nomenclature May Be Barrier for Advanced Biofuels," from the OPIS Ethanol & Biodiesel Newsletter is excerpted below, and reprinted in full at the link with permission from OPIS.

Any number of complications could trip up the commercial use of an advanced biofuel, but one that should attract attention is the requirement that all fuels be listed on Toxic Substances Control Act (TSCA) Inventory of Chemical Substances.
This requirement has the potential to raise reporting requirements that could be a barrier to sales of oils made from algae feedstocks, as well as other non- traditional biomaterials, said Richard Engler, Ph.D., with Bergeson & Campbell, PC.
"TSCA is based on identification of what you are making. So if you have a single, defined molecule, like ethanol, it's simple," he told OPIS in a follow- up to his presentation at last month's Advanced Bioeconomy Leadership Conference.
Ethanol is a Class 1 chemical on the TSCA list. Its identity does not depend on how it is made. And since one ethanol is chemically the same as another, Engler explained that a new producer of ethanol can use the existing TSCA Inventory registration.
But most hydrocarbon-based and bio-based fuels are Class 2 chemicals, which are identified differently, Engler said. Class 2 compounds are defined as having unknown or variable composition, complex reaction products, and biological materials.

The article goes on to explain how Class 2 compounds are named, where there is flexibility in naming plant, animal, and marine sourced oils and where there is not, and solutions for which the advanced biofuels industry should petition EPA.