Technical Standards Committee
Transcription
Technical Standards Committee
Technical Standards Committee October, 2012 | Version 5.0 Algae Industry Minimum Descriptive Language: Guidance to Evaluate Life Cycle Inputs and Outputs © 2010-2013 Algae Biomass Organization Algae Biomass Organization | 1 About the Algae Biomass Organization Founded in 2008, the Algae Biomass Organization (ABO) is a non-profit organization whose mission is to promote the development of viable commercial markets for renewable and sustainable products derived from algae. Our membership is comprised of people, companies, and organizations across the value chain. More information about the ABO, including membership, costs, benefits, members and their affiliations, is available at our website: www.algalbiomass.org. The Technical Standards Committee is dedicated to the following functions: • • • • Developing and advocating algal industry standards and best practices Liaising with ABO members, other standards organizations and government Facilitating information flow between industry stakeholders Reviewing ABO technical positions and recommendations For more information, please see: http://www.algalbiomass.org/policy-center/technical-standards/introduction/ Staff Executive Director - Mary Rosenthal General Counsel - Andrew Braff, Wilson Sonsini Goodrich & Rosati Administrative Coordinator - Barb Scheevel Administrative Assistant – Nancy Byrne Website Manager – Riley Dempsey Board of Directors Chair - John Pierce, DLA Piper Vice Chair - Joel Murdock, FedEx Express Secretary - Thomas Byrne, Byrne & Company, Ltd. Mark Allen, Accelergy John Benemann, MicroBio Engineering, Inc. Keith Cooksey, Montana State University - Emeritus Bill Glover, The Boeing Company David Hazlebeck, Global Algae Innovations Qiang Hu, Arizona State University Ira “Ike” Levine, University of Southern Maine Margaret McCormick, Matrix Genetics Greg Mitchell, Scripps Institution of Oceanography Philip Pienkos, National Renewal Energy Labs James Rekoske, UOP/Honeywell Paul Woods, Algenol Tim Zenk, Sapphire Energy Committees Events Committee Chair - Philip Pienkos, National Renewable Energy Laboratory Vice Chair - John Pierce, DLA Piper Member Development Committee Chair - John Benemann, MicroBio Engineering, Inc. Bylaw & Governance Committee Chair - Mark Allen, Accelergy Technical Standards Committee Chair - Jim Sears, A2BE Carbon Capture Co-Chair - Keith Cooksey, Montana State University Director Recruitment Committee Peer Review Commitee Chair - Keith Cooksey, Montana State University Vice Chair - John Benemann, MicroBio Engineering, Inc. Executive Policy Council Co-Chair – Tim Zenk, Sapphire Energy Co-Chair – Gary Hopper, General Atomics Table of Contents About the MDL 5.0 Document Introduction to the Algae Industry The Challenge and ABO’s Green Box Solution Recommended Minimum Descriptive Language for Scaled Algal Operations Appendix A: Measuring Dry Weight and Performing Compositional Analysis of Algal Biomass Appendix B: Basics of Lifecycle and Techno-Economic Analysis Appendix C: Regulation and Permitting of Algae Farm Siting and Operations Appendix D: Framework Issues for Use of Wastewater in Algal Cultivation Appendix E: Regulatory and Process Considerations for Marketing Algal based Food and Feed Appendix F: Requirements for Marketing a Biofuel Appendix G: Quality Attributes and Considerations for Trading Algal Oils ABO 2012 Corporate Members Algae Biomass Organization | 2 Page 3 Page 4 Page 5 Page 6 Page 9 Page 13 Page 14 Page 15 Page 16 Page 18 Page 19 Page 21 About the MDL 5.0 Document This Guidance Document recommends the Minimum Descriptive Language required for characterizing the economic and environmental inputs and outputs of an aquatic biomass operation. Voluntary adoption of uniform descriptive language will accelerate industry growth and unify research. The Minimum Descriptive Language Scope of recommendations within this document are intended to be useful in characterizing a broad range of aquatic production operations. The Algal Biomass Organization (ABO) is primarily focused on the production of eukaryotic algae (both macro and micro) and cyanobacteria (blue-green algae); however, photosynthetic aquatic cultivation of crops such as duckweed and others will also benefit because many of the inputs and outputs will be common to all. The Minimum Descriptive Language in this document will equally serve heterotrophic algal cultivation, algae-bacteria binary systems and multitrophic systems that employ higher organisms to harvest or otherwise enhance value. ABO Technical Standards Committee Authors: Jim Sears - Committee Chair, President and CTO, A2BE Carbon Capture LLC, Director TerraDerm Foundation Dr. Keith Cooksey - Committee Co-Chair, Research Professor, Department of Microbiology, Montana State University - Emeritus, ABO Board Member Pat Ahlm, Assistant Director, Government and Regulatory Affairs at Algenol Biofuels Inc Dr. Rose Ann Cattolico, Professor of Algal Biology, University of Washington Dr. Mark Edwards, Professor, Arizona State University Morrison School of Agribusiness and Resource Management, Vice President at Algae Biosciences Inc Steve Howell, President and founder of MARC-IV, Chairman of the ASTM task force on biodiesel standards Adonis Neblett, Patent Attorney and Shareholder, Fredrikson & Byron Dr. Lieve Laurens, Algal Research Scientist, National Renewable Energy Laboratory Dr. Robert McCormick, Principal Engineer, Fuels Performance, National Renewable Energy Laboratory Dr. Philip Pienkos, Applied Sciences Group Manager, National Renewable Energy Laboratory Dr. Herminia Rodriguez, Professor of Biochemistry and Molecular Biology, University of Seville. Steering Board member, EABA (European Algae Biomass Association) Additional Reviewers: ABO Board of Directors representing: Targeted Growth, A2BE Carbon Capture, Byrne & Company, Ltd., Benemann Associates, Montana State University, Solazyme, Boeing Commercial Airplanes, University of Southern Maine, Scripps Institution of Oceanography, FedEx Express, National Renewable Energy Laboratory, Wilson Sonsini Goodrich & Rosati, Raytheon Company, University of Seville, Mars Symbioscience, ABO Government and Public Relations Committee representing Sapphire Energy, Ron Pate representing Sandia National Labs and James Collett representing Pacific Northwest National Laboratory. Algae Biomass Organization | 3 Introduction to the Algae Industry This new version of the Technical Standards Minimum Descriptive Language is designed to introduce stakeholders and policymakers to the algae industry by providing a framework for evaluating industrial inputs including land, materials, and manpower; outputs including products and waste; and processes and regulations with the industry will interface with the outside world. We call this document the “Minimum Descriptive Language” or “MDL” because it endeavors to outline in the simplest terms possible the minimum amount of information needed to fully describe the environmental, regulatory and financial footprint of any algal operation. The Committee has aimed to create a descriptive mechanism that can equally adapt to algal operations as small as a single pond or as large as an entire regional algae industry that may include algal product refining and distribution. ABO’s MDL approach is equally applicable to heterotrophic sugar based processes, open pond, photobioreactor and even open water production processes as well as the many harvest and conversion technologies being considered across the industry. In the first section of this document we apply an imaginary “Green Box” around the subset of the industry being studied and then outline the input and output categories that enter or exit the green box boundary. Measurements throughout these categories allow for both economic projections (through techno-economic analyses) and sustainability calculations (through life-cycle assessments). These economic and sustainability analyses may have significant similarities, e.g. open pond production of nutraceutical or biofuels, yet may vary greatly in terms of the volume and quality of input streams such as water and nutrients owing to the different regulatory standards set for different product sectors (e.g. food, fuel, or high value chemicals). The importance of energy usage, carbon balance, manpower and other inputs and outputs may also vary widely depending on the product type. As this first section shows, the green box inputs include the carbon, water, energy and nutrient inputs used as well as the land requirements, process consumables and manpower requirements. The green box process outputs include the different classes of algal products as well as the waste emissions including gas, liquid, and solid discharges. Together, the measured inputs and outputs listed on pages 5 through 8 will generically carve out the total economic and environmental footprint of any algal operation. This total footprint information will become increasingly important in the funding, regulatory and sustainability review of a growing algal industry, and will ultimately define the commercial viability of specific production processes. The appendices of the second half of this document are equally important as they describe the product analysis, operational, marketing and regulatory considerations that will be essential to each part of the developing algae industry. Appendix A extensively discusses state-of-the-art methodologies for reliably measuring basic algal characteristics like weight and composition. Algal measurements like these have varied widely in the past, yet are fundamental in assessing the economic performance of a planned algae farm. Appendix B gives a rudimentary understanding of how the complex but essential, life cycle analysis or LCA sustainability calculations are performed in the algae industry. The outcome of LCAs has become increasingly important in qualifying algal biofuel operations for preferred governmental tax programs as well as funding program eligibility. Appendix C then overviews the unique set of regulatory and permitting processes that are applicable to algae farming and product generation operations. Appendix D discusses the specific wastewater usage considerations applicable when considering wastewater as a nutrient and water source for an algae farm. Appendix E discusses the many regulatory hurdles and process steps required to consider algae as a food product or feed source. Appendix F then describes the specific regulatory and standards considerations needed to produce a legally marketable biofuel from algae. Appendix G discusses the complex trading rules and market considerations that will apply when algal oils begin to flow into the commodity markets that are now dominated by vegetable and animal rendered oil sources. A note on “algae” versus “algal”: ABO has adopted the common parlance of using “algae” when describing the industry as the “algae industry” and the ABO organization as the “Algae Biomass Organization”. However, the correct scientific usage applied elsewhere in this document and recommended to users for technical and scientific discussions is as follows: algae is the plural noun referring to a multitude of cells, alga is a single cell and algal is the proper adjectivale form. Algae Biomass Organization | 4 The Challenge the Industry Faces Algal operations will vary in size from small units producing specialty chemicals and nutraceuticals to large farming scale (hundreds to thousands of hectares) for production of food products and biofuels. Accurate assessment of their future economic and environmental footprint will be critical to financing development and performing environmental life cycle analysis. There is no harmonized minimum descriptive language set specifically developed to describe the diverse technologies being proposed for scaled algal farms. The lack of a suitable common language has created confusion in expressing attributes and has become a barrier to deployment of pilot demonstrations. ABO’s Green Box Solution The ABO Technical Standards Committee proposes a set of Minimum Descriptive Language tailored to the needs of our industry that describes the footprint of any algal or similar production operation. This will be established by estimating, characterizing or measuring the magnitude of process inputs and outputs passing through an analytical “Green Box” arranged to surround the total algal operation. This boundary might encompass just an algal farm or fermentation facility with its support infrastructure, or could further include an appropriate portion of a biorefinery or power plant with which the farm is integrated. In this way, the Green Box descriptive method can be adapted to compare the environmental footprint of algal operations having different inner workings yet similar inputs and outputs. The minimum set of descriptive input and output variables needed to characterize the economic and environmental footprint of an operation are shown in the graphic below and are described in more detail through the balance of this document. Above: Minimum Descriptive Language users will describe their operation by freely selecting which operational components to place within their Green Box and describing the whole via collective inputs and outputs. Support of Life Cycle Analysis: The Minimum Descriptive Language will facilitate the conduct of Life Cycle Analysis (LCA) and techno-economic analysis while using a common language across the industry. Guidance on LCA studies may be found in ISO 1404xx series of documents that describe goals, scoping, quality, transparency and requirements for data collection, along with guidelines for the appropriate analysis and presentation of data. The EPA Renewable Fuel Standards (RFS2) guidance provides a template on how to conduct LCAs for biofuels to meet various renewable definitions. Further instruction on composing LCA studies may be found in the EPA report "LIFE CYCLE ASSESSMENT: PRINCIPLES AND PRACTICE" (EPA/600/R-06/060, May 2006). Adoption into Peer-Reviewed Research: The Committee welcomes peer reviewed research of the scope and measurement methodologies best employed within the industry. Prospective authors may consult the "Minimum Information for Biological and Biomedical Investigations" collection of standards at www.mibbi.org for guidance on describing methods and results of research on the biology, biochemistry, or biotechnology of algal biomass production. Process for Incorporating Stakeholder Comment: This Minimum Descriptive Language Guidance Document is designed to meet the evolving needs of the algal industry and its stakeholders. Accordingly, the ABO Technical Standards Committee invites formal stakeholder comment on furthering the scope and specifics of this document. Please email comments to technicalstandards@algalbiomass.org where they will be logged into the Technical Standards Committee database. The Committee will formally reviewcomments prior to March 31, 2011 and recommend improvements to the Guidance Document on a periodic basis. Algae Biomass Organization | 5 Recommended Minimum Descriptive Language for Scaled Algal Operations The ABO Technical Standards Committee recommends that when large scale algal operations are proposed or analyzed, the following set of descriptive metrics are adopted to uniformly characterize these operations. By harmonizing upon a common set of descriptive metrics, the algal industry will accelerate its growth by eliminating confusion in the business and life cycle analysis arena of our industry. By identifying the sources and characteristics of inputs, and the intended fates and characteristics of outputs, we will make the necessary data available that will then allow for later upstream and downstream life cycle and techno-economic analysis. Input Description: Carbon Input – CO2, regardless of source, is typically dissolved in the growth media of photosynthetic algae to accelerate growth although the carbon could come from another chemical source. Heterotrophic and mixotrophic algae obtain carbon from sugars or other organic compounds. Measurement: Quantify in Kg or tons per year the quantity of carbon or CO2 imported across the imaginary Green Box boundary regardless of source and mode of delivery. Source Description: Prospectively, pure CO2 from a pipeline or industrial storage system, dilute CO2 in flue gas, CO2 drawn directly from the atmosphere, chemically bound inorganic carbon in the form of bicarbonate, or sugars and other simple organic compounds, either pure or in mixtures, derived from lignocellulosic biomass. Detail Characteristics: Description of other compounds mixed with the carbon source, including possible heavy metals and other contaminants, micronutrients associated with flue gas (e.g., from coal-fired emitter sources), and input pressure levels if the carbon delivery is in gas or in a liquid form. Input Description: Water Input – Water in fresh, saline and wastewater forms is a basic component of algal growth media. See Appendix D for special wastewater considerations. Fresh water is typically lost through surface evaporation and may be gained from precipitation in open systems and may be lost in closed systems via their cooling apparatus. The concentrations of dissolved salts and other chemicals in cultivation media will increase with evaporation and recycling. Measurement: Input water volume is measured in liters or gallons brought into the Green Box per year. In operations employing “once-through” cooling systems, the downstream consumptive and environmental effects must be taken into account. Source Description: Well, pipeline, river, ocean, lake, surface or groundwater agricultural allotment, wastewater type, precipitation, etc. Detail Characteristics: Total dissolved solids, mineral type, total organic carbon, biological oxygen demand (BOD), major cations and anions, trace metals, bio or industrial contaminants. Input Description: Total Infrastructure Area – Significant amounts of land are typically needed to cultivate algae, process it into products and convey input and output materials (solids, liquids, gasses), power, energy, vehicles, equipment, and other machinery around the algal farm and processing facilities. Total infrastructure should include every necessary operational element that connects together with lifecycle or business analysis within the desired Green Box. These additional components may include operationally associated but off-site industrial elements, crop fields, wind farms, solar farms, and etc. Measurement: Data should include total footprint area in acres or hectares of infrastructure includes ponds, PBRs and fermenters, as well as evaporation ponds, access roads, pipes and other utilities, buildings and appropriate portions of offsite processing or generation facilities that may appropriately be characterized as part of the infrastructure of the overall Green Box analysis. For photosynthetic cultivation, the total direct solar areal capture area of ponds or PBRs should be broken out if a specific photosynthetic productivity is being proposed. Source Description: Infrastructure land under private ownership, leased, government, tribal, reclaimed, conservation reserve program, land use category, etc. Detail Characteristics: Latitude, altitude, climate zone, precipitation, slope, soil type and soil carbon content, indigenous plants and animals, etc. Algae Biomass Organization | 6 Total Energy Input – Algal operations use electricity, fossil fuels, other chemical energy, steam, etc. that are imported into the Green Box. Statements of incident solar radiation data should be based on the National Radiation Solar Database http://rredc.nrel.gov/ solar/old_data/nsrdb/ with stipulation of specific NRSD data set and metrics that are being utilized. In the case where there is embodied energy in organic nutrients for heterotrophic algal production, the nutrient or chemical energy source should be fully characterized in the information from the Carbon Input or Nutrient Input sections to permit future calculations of upstream environmental footprint. KW-hours (kWh), BTUs, or other quantity depending of the type of imported energy should Measurement: be used. These can be related to Joules for determination of overall energy balance. Note that if the algal operation is a net electricity or other energy type producer (beyond that energy embodied in the direct and indirect algal products) then the Total Energy Input can be adjusted or made negative to reflect this net non-algal energy export. Electricity sourced from fossil coal/gas, biopower or biomass co-generation, biogas, wind Source Description: and solar generation or direct use of fossil resources as in gasification, etc. Transportation for energy input includes reference to transmission lines, pipelines, truck or rail and distance traveled. Detail Characteristics: State input voltage level, phase, and frequency for electricity as well as the characteristics needed for both fossil and renewable energy footprint calculation. Input Description: Input Description: Total Nutrient Input – Algae, like plants, require macronutrients like nitrogen, phosphorous and potassium as well as a host of micronutrients specific to the species. Carbon has its own separate category in this Descriptive Language. Measurement: Kilograms or tons of each individual nutrient and its chemical delivery form should be reported; for example, NH4NO3 for nitrogen or H3PO4 for phosphorus. Source Description: Factory, mine, wastewater, agricultural waste or other recycled sources shold be noted and specify the nutrient transportation distance for LCA accounting Detail Characteristics: Provide fossil fuel-based manufacturing details, mined, renewable source, etc. Input Description: Total Consumables Input – The parts or facilities that must be replaced in one year of operation. All subcategories that amount to 10% or more of the total consumable’s monetary value or input mass should be broken out individually). Measurement: Include dollar value, description and weight in Kg or tons of each generalized industrial component in a form allowing upstream lifecycle impact assessment. Source Description: General identification of source, transportation distance and information is needed to calculate upstream footprint in future analysis. Detail Characteristics: Cite ability to be recycled, toxic disposal load, imported vs. domestic sourcing. Input Description: Total Required Labor – Algal operations will need laborers, technicians, engineers and other special classes of labor. Measurement: Provide full time equivalents of each labor classification type, even if labor has seasonal variability so as to allow for economic impact assessments. Source Description: Cite if workers are regionally housed commuters, on-site housing, locally recruited labor vs. imported labor, their training site locations, and worker demographics. Detail Characteristics: Describe labor type, education type and source of required specialized education. Output Description: Algal Constituent Products* – Extractable oil, total lipids, protein, carbohydrate, whole algae, diatomaceous material, chitin, any direct constituent of organism are identified. Measurement: Provide productivity in kilograms or tons at a specified level of dryness; the composition of some products is expected to include ash unless specified ash-free. Fate or Destination: Specific use in fuel, food, durable goods, nutraceutical, agriculture, industrial chemical, etc. Detail Characteristics: Detail specific algal type, harvesting method, level of biological and chemical purity. *See Appendix A: Measuring/estimating algal dry weight and constituents like oil using small samples. Algae Biomass Organization | 7 Output Description: Indirect Algal Products – Ethanol, extracellular oils, oxygen, hydrogen, hydrocarbons, remediation services, shrimp, fish, etc. produced by organism. Measurement: Kilograms, tons, gallons or liters of products at specified dryness, quality or purity level that is exported from Green Box. Fate or Destination: Refining into fuel, human food or nutraceuticals, animal feed compounding, durable goods agricultural applications, industrial chemicals produced. Detail Characteristics: Species if appropriate, level of biological and chemical purity, applicable standards or specifications are to be documented. Un-captured Gas Emissions** – CO2, NOx, CO, H2S, H2, O2, water vapor, volatile hydrocarbons, etc. that are emitted from any part of the infrastructure. Solid materials and biologic airborne emissions are accounted for under solid waste. Report PPM or PPB for regulatory or permitted limits and kilograms or tons of individual gas Measurement: components emitted from whole operation on annual basis. Fate or Destination: After emission to ambient air, what is the dispersion, deposition or chemical conversion that takes place with respect to environmental/atmospheric conditions? Detail Characteristics: For example: Describe whether gas emissions expelled are components from a Green Box Input gas stream or are newly created by processes within the Green Box. Output Description: Output Description: Liquid Waste Output*** – Water or other liquids containing levels of one or more pollutants: Saline/salts, nutrient, biologics, toxics, heat, suspended solids, sediment, microorganisms, BOD, TDS, trace metals or other contaminant-containing liquid. May also include spent solvents from extraction processes. Measurement: Provide PPM or PPB for regulatory or permitted limits as well as liquid liters or gallons discharged or otherwise conveyed from algal production facility. Fate or Destination: For water, point source and non-point source discharge to surface water, ground water, reinjection, water treatment, or conveyed/transported for recovery of useful constituents or disposal. For liquids such as organic solvents, appropriate industrial disposal, storage, or treatment, e.g. purification and recycling outside the Green Box. Detail Characteristics: Composition and concentration of chemical, biological and other constituents, toxicity, and algal production process variations should be reported. Output Description: Solid Waste Output**** – Retired parts from Total Consumables input, sludge, viable biologics, airborne dust of organic or non-organic composition, etc. Measurement: Note kilograms or tons whether stockpiled on site, buried on-site or moved offsite. In the case of viable biologics, note species, genetic modifications, the dispersion mechanism i.e. liquid or solid discharge, part of shipped product, airborne, etc., dispersion density, human/ plant/animal health risks, and viability/risk of organism spreading to natural systems or other commercial aquaculture or agriculture systems residing outside the Green Box. Fate or Destination: Use of landfill, burning, burial, chemical neutralization, storage, airborne or water dispersal and downstream effects. Detail Characteristics: Provide chemical and biological composition, off gassing, toxicity, seasonal variations. **See Appendix B: Total Lifecycle Gaseous, Liquid, and Solid Waste Outputs ***See Appendix C: Government Environmental Programs for Regulation and Control of unCaptured Gas, Liquid, and Solid Outputs from Algae Operations ****See Appendix D: Framework Issues for Use of Wastewater in Algae Cultivation Algae Biomass Organization | 8 Appendix Appendix A: Measuring Dry Weight and Performing Compositional Analysis of Algal Biomass Uniform methodologies are required to assess the large variety of metrics within the growing algal industry. One of the most pressing and fundamental areas of standardization is in the measurement of algae productivity and compositional analysis. How can we measure the quantity of algae in a sample and the type and quantity of constituents that give it market value? These analytical determinations underpin the measurement of growth rates and value creation , yet uniform measurement of these fundamental attributes has been elusive. The Committee discusses the challenges of measurement and provides links to current literature in the areas of analytical chemistry for compositional analysis of algae. In this Appendix A, the Committee also recommends best measurement practices based upon its review of existing methods while soliciting continuous improvements to these methods from the community on an ongoing basis. Figure 1: In 2011 three prominent laboratories (Lab.1, Lab.2 and Lab.3) took an identical dried algal sample and analyzed this using prevailing laboratory methods (gravimetric lipids, colorimetric protein and carbohydrate measurements), one of the laboratories carried out the more advanced respective reference method (amino acids, monosaccharides and fatty acids for protein, carbohydrates and lipid respectively) shown as a red dotted line. More information and procedure details can be found in reference [1]. The results showed surprising measurement variability among labs and inaccuracies of prevailing methods relative to reference procedures and have led to a push for unification of analysis methodologies. The following 2012 MDL recommendations are based on the outcomes of these findings. The composition of biomass forms a crucial point in an algal biofuels production process or operation, and, as demonstrated by this technical standards document, there is a conscious effort ongoing to suggest standard analytical methods so researchers and industry members in the field are able to compare processes and track individual components. The experience of researchers in the ligno-cellulosic biofuels industry could be used as a basis for generating similar standards in algal biomass characterization. For an algal biofuels process, it is important to be able to determine the biomass productivity and algal constituent products and close the material balance of all components during every step of the operation or process. The main constituents that make up algal biomass are lipids, proteins, carbohydrates and ash (including diatomaceous material). We provide here suggestions on standardization of the protocols for quantification of lipids, proteins and carbohydrates. 1. Dry weight measurements, comparison of methods for determining productivity At the basis of any production process lays productivity and composition measurements, which are dependent on robust dry weight and cell number calculations. One has to keep in mind that methods for determining algal dry weight can be affected by the presence of significant quantities of contaminating microorganisms in the growth medium. Additionally, note that one is Algae Biomass Organization | 9 typically trying to assess the equivalent dry weight of algae in a small sample of liquid medium in order to indirectly assess the weight of biomass in a huge volume of that medium. For this reason, accurate measurement of sample volume and representative sampling is essential. Dry weight can be assessed by “primary measurements” in which the desired component is separated and directly weighed or by “indirect measurements” such as cell counting or fluorescence, where the measured quantity is calibrated to actual mass and used as an analog. Indirect measurements can be extremely useful because of their typical speed and sensitivity when calibrated and so both are discussed. The Technical Standards Committee is looking for relatively easy and inexpensive ways to perform primary measurement methods that work across a variety of algae and aquatic biomass and a subset of methods are described here with their respective advantages and disadvantages: Filtration: Filter a specific volume of growth media through a pre-weighed Whatman GF/F style ultrafine binder free glass fiber filter. Dry and re-weigh filter on a precision balance. Repeat drying and weighing until equal dry weights are obtained. Advantages: Primary direct measurement and an easy and inexpensive test of total non-volatile mass. Disadvantages: High precision balance necessary. Vacuum or pressure filtration equipment needs to be operated at low pressure. Filtration can easily disrupt very soft-bodied cells causing significant loss of material through the filter media. Unless sample and filter are fresh water rinsed before drying, salts from the media may become included as part of the measurement. A core assumption of a drying based methodology is that volatile components may be lost and unaccounted for after drying. Centrifugation: Spin a volume of culture in a pre-weighed centrifuge tube. Remove supernatant. Dry and weigh pellet plus tube. Advantages: Primary Measurement. Easy measurement of heavier-than-media cells and particles. Disadvantages: Centrifuge and significantly high-resolution balance can be expensive and small pellet size can severely compromise accuracy of the results. Core assumption that all components to be measured are heavier than media may influence result if lightweight components are poured off. Turbidity: Measure with several instrument types (e.g., spectrophotometer, turbidimeter) at selected wavelengths. Note that one must compare turbidity measurements at several cell densities with a direct mass measurement method to determine the turbidity to weight relationship for each algal species. Advantages: Good for small volume samples. Fast measurement and low cost sensor technology make this method useful for continuous monitoring of growth dynamics. Disadvantages: Indirect Measurement. Algae change pigment density during different growth cycle phases and in response to nutrient changes. Presence of contaminating organisms or suspended solids can influence turbidity results. Presence of extracellular components could significantly alter results. Cell Count: Count cells with hemocytometer, coulter counter, or flow cytometer. Note the need to use a primary measurement method to calibrate cell count to weight for each alga species. Advantages: Accurate when calibration method is accurate. Very small sample sizes are acceptable. Hemocytometers and microscopes are relatively inexpensive. Disadvantages: Indirect Measurement. This can be time intensive if done manually. Coulter Counter and flow cytometer are easier but expensive and rely upon calibration with direct measurement method. Cell counting, especially with a coulter counter or flow cytometer, may be limited by cell size and complicated by large size distribution or by filamentous or a multicellular or colonial morphology. Organic Carbon Content: A variety of C analyzers are available to measure total organic carbon in aqueous samples. Solid phase CHN analyzers will measure total carbon on a dried GF/F filter or a dried pellet. Need to use primary method to calibrate to cell weight for each algal species. Advantages: Accurate even for small sample size if calibration is accurate. Disadvantages: Indirect Measurement, expensive equipment and C/N ratio changes with time of day and growth conditions. 2. Compositional Analysis of Algal Biomass, Lipids, Carbohydrates and Protein Characterization of algal biomass consists of the accurate measurement of the lipids, proteins and carbohydrates. The degree to which these are characterized primarily depends on the information required and different methods provide different kinds of information. 2.1 Algal lipids vs. extractable oils vs. fuel fraction Lipids are traditionally measured as a gravimetric solvent extraction yield. However, different procedures and types of solvents have resulted in inconsistent lipid yields [2,3]. The completeness of extraction and composition depends on the biology of the Algae Biomass Organization | 10 alga and the physiological conditions experienced by the organism as well as the compatibility of the solvent polarity with the lipid molecule polarity and extraction conditions used. Inevitably, the extractable oil fraction will contain non-fuel components (e.g. chlorophyll, pigments, proteins, and soluble carbohydrates). Thus it may be necessary to assess the fuel fraction of these isolated oils (i.e. fatty acid content of extracted lipids) by transesterification followed by quantification of the fatty acid methyl esters (FAMEs). Due to the large number of variables, it is difficult to standardize an extraction-based lipid quantification procedure. However, if the relative composition of intact lipids is required, e.g. polar versus neutral lipid content, an extraction process may be the only way to isolate lipids from the rest of the biomass. As an alternative to extraction, there is a growing emphasis on quantification of lipids through a direct (or in situ) transesterification of whole algal biomass. The process consists of either a two-step basic followed by acid hydrolysis of the biomass [4,7] or a single step acid catalysis [5,6] followed by a transmethylation of the fatty acids and quantification of the FAMEs by gas chromatography (GC). These procedures have been demonstrated to be robust across species and their efficacy is less dependent on the parameters listed above that influence an extraction process. One disadvantage is that no information on the origin of the lipids is available, e.g. relative level of neutral versus polar lipids and analytical instrumentation (GC) is needed. Several reports in the literature and in the AOAC official methods are suggesting in situ transesterification as the lipid quantification procedure of choice for algal biomass [4-6]. The applications of the respective methods are varied; reference [5] was established as a sub-microscale procedure for very small quantities (< 1mg) of algae and allows for single cell calculations by extrapolation to culture volumes. The methods detailed in references [4,6] were developed for larger amounts of freeze dried biomass (>10 mg) while still allowing for relatively high-throughput analyses (100-500 samples per week). The AOAC official method [7] was established as a method for the fatty acid determination in encapsulated fish oils, but has been used extensively on algae and formed the basis of the work shown in reference [4]. A study of increasing biomass quantities on the precision of the total FAME content measured using a modified reference [4] method indicated that higher precision could be achieved by increasing the biomass, presumably by eliminating weighing inaccuracies. The relative standard deviation of replicate measurements dropped significantly at biomass quantities of over 10 mg (unpublished data). In addition to the procedures listed above, there has been a push to accelerate the quantification of lipids. Researchers want to tailor the analysis to the screening of thousands of individual strains in bioprospecting or metabolic engineering projects. These high-throughput methodologies are based on hydrophobic (lipophilic), fluorescent dyes, such as Nile Red [8] and BODIPY [9, 10]. As the dyes are absorbed by the lipids the sample fluorescence intensity increases proportionally and this principle has been used extensively in the screening for higher lipid producing cells among thousands of candidates. An alternative technology that is gaining popularity is infrared (IR) spectroscopy coupled with chemometrics to identify high lipid producing strains from a population [11]. One advantage of IR technology over the hydrophobic dyes is that the IR-based quantification is not dependent on the permeability of the cell walls to the dyes that has been reported to affect the fluorescence signal from lipids. 2.2 Algal carbohydrate measurements Total carbohydrate content can be measured via a rapid colorimetric phenol sulfuric acid method [12]. However, this method is notoriously variable and not all sugars exhibit a similar colorimetric response and thus some carbohydrates could cause an over- or underestimation if a calibration is performed based on one neutral monosaccharide [1,12]. Alternative carbohydrate quantification procedures involve sequential hydrolysis of carbohydrate polymers in algae and identification and quantification of the monomers via liquid (HPLC) or gas chromatography (GC, as alditol acetates) [13]. Because of the use of chromatography, these hydrolysis procedures are likely to be more accurate and will also provide a relative monosaccharide composition of the algae. There are reports in the literature, but a comprehensive comparison and test of robustness across strains is currently lacking. As a subset of carbohydrates, starch measurement is among the routine compositional analysis methods. The method of biomass preparation and enzyme assay kit highly affects the measurement [1]. A protocol that has been demonstrated to give accurate and precise starch determination on a variety of strains is detailed in reference [14]. 2.3 Algal protein measurements Protein percentage can be quantified using two common procedures; colorimetric [15] and a nitrogen ratio calculation based Algae Biomass Organization | 11 on measuring elemental nitrogen and applying an algae-specific nitrogen-to-protein conversion factor [16]. More recently, a fluorometric measurement procedure of algal protein is being developed and offers the advantages of requiring a minute amount of biomass, excellent specificity, compatibility with a wide suite of reagents and a high throughput potential. The colorimetric and fluorometric procedures can be susceptible to interferences from non-protein cellular components as well as extraction buffer constituents, and are highly dependent on the protein standard used for calibrating the absorbance/fluorescence values. The measurements are also dependent on efficacy of cell fractionation (solubilization of cellular proteins). Improvements have been Table 1: Overview of the components routinely analyzed in algal biomass, the recommended reference methodologies and instrumentation needed are listed[1] made by inclusion of NaOH digestion of algal biomass and proteins, where the colorimetric protein determination corresponds with the measured amino acid content. Calculating protein content using a nitrogen-to-protein conversion factor has proven to be a more robust representation for whole biomass protein measurement. Measuring elemental nitrogen is based on hightemperature combustion and is much less susceptible to interferences. An algal biomass-specific conversion factor was calculated from the typical amino acid composition of 12 species of algae grown under different conditions [16]. An overall average ratio factor of 4.78 grams of algal protein to detected grams of elemental nitrogen has been used successfully for algal protein quantification. However, variation in the non-protein nitrogenous compounds between different strains and growth conditions of algae will affect the applicability of the averaged conversion factor. Amino acid composition of algae is perhaps the most accurate protein determination and official AOAC standard procedures have been published for the quantification of acid hydrolyzed amino acid determination [17]. [1] Laurens, LML, Dempster, T, Jones, HDT, Wolfrum, E, Van Wychen, S, McAllister, J, Arrowsmith, S, Parchert, KJ, and Gloe, LM (2012) Anal. Chem., 84(4): 1879 [2] Guckert, JB and Cooksey, KE, (1990). J Phycol 26: 72-79; [3] Bigogno C, Khozin-Goldberg I, Cohen Z (2002) Phytochem. 60:135–143 [4] Griffiths MJ, van Hille RP, Harrison ST (2010) Lipids. 45(11):1053-60 [5] Bigelow, NW, Hardin, WR, Barker, JP, Ryken, SA, MacRae, AC, Cattolico, RA, (2011) J. Am. Oil Chem. Soc. 88:1329-1338 [6] Laurens, LML, Quinn, M, Van Wychen, S, Templeton, DT, Wolfrum, E (2012) Anal. Bioanal. Chem., 403(1):167-78 [7] Association of Official Analytical Chemists (AOAC). Official Fatty Acid determination method 991.39, 1995 [8] Cooksey KE, Guckert JB, Williams, SA, Callis, PR ( 1987) J. Micro. methods 6: 333-345 [9] Cooper, M, Hardin, W, Peterson, T, and Cattolico, RA (2010). J. Biosci. and Bioeng. 109:198-201 [10] Govender, T, Ramanna, L and Bux, F (2012) Biores. Techn. 114:507-511 [11] Laurens, LML, Wolfrum, EJ (2011) Bioenerg. Res. 4: 22-35 [12] Dubois, M, Gilles, KA, Hamilton, JK, Rebers, PA, and Smith, F (1956) Anal. Chem. 28(3)350-356 [13] Templeton, D. W.; Scarlata, C. J.; Sluiter, J. B.; Wolfrum, EJ (2010) J. Agric. Food Chem. 58, 9054-9062. [14] Megazyme. www.megazyme.com/downloads/en/data/K-TSTA. pdf, Megazyme International: Bray, County Wicklow, Ireland, 2011. [15] Lowry, OH, Rosbrough, NJ, Farr, AL, and Randall, RJ. (1951) J. Biol. Chem. 193: 265 [16] Lourenço, SO, Barbarino, E, Lavin, PL, Marquez, UML, Aidar, E (2004) Eur. J. Phyc., 39(1) 17-32 [17] Association of Official Analytical Chemists (AOAC). Official Amino Acid determination method 994.12, 1997 [18] MacDougall, KM, McNichol, J, McGinn, PJ, O’Leary, SJ, Melanson, JE(2011) Anal. Bioanal. Chem., 401(8):2609-16 Algae Biomass Organization | 12 Appendix B: Basics of Lifecycle and Techno-Economic Analysis Lifecycle Assessment (LCA) and Techno-Economic Analysis (TEA) are used to assess the total environmental, energy and financial footprint of a manufacturing process. With respect to algae, the manufacturing process commonly being analyzed will include the steps of building an algal farm, powering and provisioning the mass production of algae on that farm, converting or using algae to produce products like food or fuel, delivering those products to market, and the use of the product as, for example, a fuel that is burned with release of CO2 and other pollutants. Each step has its own LCA footprint and an overall LCA process will clearly define what processes are within its boundary or scope of analysis. An LCA process would minimally involve determining the energy, carbon and water balance associated with producing a unit of product such as a gallon of fuel. For example, the amount of energy embodied in an algae based fuel compared to the fossil or alternative energy required to manufacture it. In addition, it could evaluate total carbon emissions or use of water resources compared to other fuels. It could also factor in the waste products, air emissions, raw materials and manpower inputs that are also part of a complete LCA analysis. An LCA analysis may assist in determining eligibility for government incentive programs, evaluating the environmental impact of farm operations, projecting economic performance or performing a Resource Assessment (RA). The latter, RA is used to calculate the total amount of fuel or other product able to be manufactured using a specific process given the amount of input resources available within a specific area, or inform the TEA and LCA analyses of the need to bring resources to the cultivation facility from remote locations. In all cases, the importance of uniform approaches to these analyses is increasing as the algae industry seeks to rapidly develop, finance, and build out its operations. LCA and TEA analysis tends to be complex, not only because of the many inputs, outputs and inter-linkages that are involved, but also because algal product manufacturing processes vary widely and continue to be developed. The standardized GREET LCA analysis tool developed by Argonne National Laboratories has been adapted to over 100 feedstock-to-fuel pathways yet continues to require adaptation to accommodate the diversity of algal based fuels “Life Cycle Analysis of Algae-Based Fuels with the GREET Model”.[1] Argonne, NREL and the Pacific Northwest National Labs convened a workshop to assist with harmonizing the analyses of algal oil based fuels. Their June 2012 report “Renewable Diesel from Algal Lipids: An Integrated Baseline for Cost, Emissions, and Resource Potential from a Harmonized Model”[2] provides an excellent overview of the LCA and TEA for lipid based biodiesel. In addition, fuels from algae can also be derived from non-lipid pathways including the collection of ethanol, hydrogen, isobutyraldehyde, oils and other chemicals exuded by algae in-situ. These can be extracted from algal fluids or photobioreactor headspaces and then converted into fuel and other high value industrial commodities. In one example, Georgia Institute of Technology and Algenol Biofuels published “Life Cycle Energy and Greenhouse Gas Emissions for an Ethanol Production Process Based on Blue-Green Algae” [3] detailing an LCA based on producing ethanol from blue-green algae in a closed loop process that does not require harvesting of algae or extraction of oil. ABO’s Green Box Approach is designed to provide a useful framework for generating input data for LCA/TEA analysis that anticipates both these existing, and future, pathways for the algae-based production of food, fuel and high value chemicals. By aiming to describe in a comprehensive fashion the many inputs and outputs that occur in algal operations and identifying the methodologies required to measure these data, the ABO Technical Standards Committee is supporting the algal industry and its need to perform harmonized LCA and TEA assessments as both evolve. This document discloses that during algal production and processing operations, gaseous, liquid, and solid emissions can include indirect and direct greenhouse gases emissions (CO2, NOx, water vapor, etc.) associated with the production of input energy and materials as well as their consumption during operations, water vapor from evaporative loss, effluent waters with entrained organic and inorganic materials not otherwise suitable for recycled use within the operation, solid biomass residue fractions not included in algal constituent products or indirect products, and solid inorganic, organic, and biologic particulates that can become airborne emissions or suspended in liquid effluents. A typical total lifecycle analysis will also consider the total impact of construction, operation and decommissioning. Gaseous emissions and liquid and solid discharges from commercial algal production operations, from a life cycle analysis perspective, include those incurred during facilities construction prior to the initiation of operations during the operating life of the facility and after operations cease and the facility is decommissioned. Emissions during site preparation and facilities infrastructure construction will include dust from construction and vehicle traffic, direct and indirect CO2 emissions from fuel combustion for power generation and operation of vehicles and construction equipment. Additional CO2, water, and other solid, liquid, and gaseous emissions would be embedded in the production of building materials, equipment, fuels, and other consumables (e.g., fertilizers and chemicals) used in facilities construction and algal production and processing operations. Similar emissions of dust and CO2 will be embodied in the decommissioning and possible restoration of facilities sites to original condition. [1] Life Cycle Analysis of Algae-Based Fuels with the GREET Model http://www.istc.illinois.edu/about/SeminarPresentations/20111102.pdf [2] Renewable Diesel from Algal Lipids: An Integrated Baseline for Cost, Emissions, and Resource Potential from a Harmonized Model http://www.nrel.gov/docs/fy12osti/55431.pdf [3] Life Cycle Energy and Greenhouse Gas Emissions for an Ethanol Production Process Based on Blue-Green Algae http://pubs.acs.org/doi/pdf/10.1021/es1007577 Algae Biomass Organization | 13 Appendix C: Regulation and Permitting of Algae Farm Siting and Operations Most countries have an established body of environmental laws and regulations to which algal production operations will be subject. Such programs typically regulate at some level one or more of the following: gaseous emission or air pollutants, water pollution or discharges to water, solid and hazardous waste handling and disposal, facility siting and permitting, and handling of toxic substances. Additionally, some countries have regulatory requirements that relate to micro-organisms and algae, with respect to their production, importation, genetic modification, or processing for both R&D and commercial activities, as well as their release to the environment. State and local regulatory authorities will also likely have additional regulations that will need to be addressed on a nuanced state-by-state basis. Algal production operations will need to be mindful of the potentially applicable regulatory requirements of the jurisdictions in which they are sited and obtain the appropriate government issued permits, licenses and other authorizations. As part of the process of obtaining permits, some jurisdictions may require decisions regarding siting and operation of a facility be subject to a public review process in order to identify the potential impact of the facility on the environment and to determine what must be done to avoid or mitigate any significant environmental impacts. A highly generalized view of typical major steps in the permitting process is presented in Figure 1 to this Appendix C. By accepting government issued permits or licenses, owners and operators of algal production operations are also accepting the responsibility to comply with permit conditions, limitations and statutory and regulatory requirements. In some jurisdictions, the consequences of non-compliance may include administrative remedies, civil court remedies, and criminal remedies, e.g., modification of permit conditions, permit revocation, fines and imprisonment. A fairly comprehensive list of U.S. environmental laws administered by the U.S. Environmental Protection Agency can be found at http://www.epa.gov/lawsregs/laws/ with links to the listed laws. The primary federal regulations for protection of the environment are in the Title 40 Code of Federal Regulations (CFR); however, there are also state and local regulatory requirements to be considered. For genetically enhanced algae, the Coordinated Framework for the Regulation of Biotechnology will be a guiding document. One of the steps in the generalized permitting process is identifying the applicable regulatory programs and responsible regulatory agencies. Figure 2 to this Appendix C provides a tabular representation of some of the agencies, regulatory programs and guidelines (identified by acronyms) that may be relevant to algal farm operations in the U.S. It should be understood that parallel regulatory programs and guidelines will be applicable in most countries. The ABO believes that its members will conduct algal production operations responsibly and in compliance with the requirements of the nation or jurisdiction in which their facilities are sited. Algae Biomass Organization | 14 Appendix D: Framework Issues for Use of Wastewater in Algal Cultivation Municipal and agricultural wastewater may be rich in nitrogen and phosphorus which are primary nutrient requirements for algal cultivation. Some industrial wastewater sources also contain these constituents. Discharge of these, and other, pollutants in the United States is governed by USEPA through the National Pollutant Discharge Elimination System (NPDES) permit process. Most States have a permit process authorized under NPDES. Generally speaking, these pollutants in a treated permitted discharge are low in concentration relative to algal cultivation interests. By design, these pollutants are to be removed to low levels in a treatment plant before discharge. In order to maximize the nutrient value of these otherwise pollutants, the wastewater or digester supernatant must be intercepted up stream in the treatment plant prior to traditional treatment and discharge. If wastewater is diverted to algal cultivation prior to full treatment to NPDES permit requirements, it is highly likely that such water after use in algal cultivation could only be released under a NPDES permit. Either the water would have to be routed back to the permitted treatment plant for discharge under that NPDES permit, or the algal cultivation facility would have to operate under a NPDES permit. The NPDES permit system has been in place for 40 years with many precedents, rulings, and some revisions that are well understood by practicing public and private sector professionals in this field. The ABO and the Technical Standards Committee welcome the participation of professionals in more fully understanding the implications of employing wastewater nutrients in the cultivation of algae and the implications of the NPDES permit process. Algae Biomass Organization | 15 Appendix E: Regulatory and Process Considerations for Marketing Algal based Food and Feed Algae offer the opportunity to market new foods that will provide substantial sustainability and nutrition advantages for consumers, producers and the environment. Terrestrial plants evolved from algae 500 million years ago and most of the dietary compounds found in modern foods can be found in algae. For example, algal biomass contains edible oils, proteins, carbohydrates, pigments, antioxidants and other useful dietary ingredients or additives. The sustainability and nutrient density motivates producers to cultivate algae for food, food additives and as an animal feed component. Growth and Harvesting of Algae for the Food Chain. Algal growth operations designed for the food chain must pass a number of regulatory requirements that are designed to assure consumer safety. Product specifications must be set based on knowledge of the algae biomass and constituent compounds to assure safety. For example, the FDA requires a GRAS assessment (Generally Regarded as Safe) for species that have already entered the food supply.[1] GRAS requires taxonomic classification of the algal species and scientific research articles on the algae and chemical composition, especially the targeted biomass fractions. GRAS documentation includes all production procedures, chemistry, and specifications, which include detailed information of the manufacturing/production, chemical composition, finished product purity (both chemical and microbiological), and stability testing (both chemical and microbiological). European sales also require analysis for specific chemicals that may cause allergies, which have been associated with food. Food grade specifications can be found in the current Food Chemicals Codex, (FCC), which include a minimum for any major chemical constituent targeted.[2] For example, ash, moisture, and heavy metal specifications must be below 1 ppm. Documentation requires information on historical and present human and animal food usage of the organism or any extract, including any available consumption levels or known human and/or animal exposures. Producers need to specify intended food uses, which may be selected from the FDA list.[3] Safety Information includes pertinent scientific information, including review articles on the safety and toxicity associated with human consumption of the algae or extract and closely related materials. Documentation should include credible information on known adverse effects associated with ingestion of algae or extract, or closely related materials and any available independent safety or toxicology assessments. Algal species new to the human food supply chain must undergo additional laboratory tests and, in some cases, dietary tests with animals, before approval. In April 2012, the FDA published new guidelines on safety assessment of food nanomaterials. Some microalgae cell and cell fragment sizes may qualify them as a nano-scale material.[4] The USDA, FDA and EPA all have regulatory authority over food production. Regulators want to know about possible toxins and contaminants such as insect parts, fertilizers, pesticides and solvents. The FDA also requires GMP, (Good Manufacturing Practices), which is an extensive checklist for all products entering human foods.[5] The FDA has stricter standards for human pharmaceuticals, cGMP (Current Good Manufacturing Practices).[6] Health claims for nutritional products may require cGMP certification. Animal and veterinary pharmaceuticals must meet FDA requirements similar to cGMP.[7] Sales to large food or feed companies may require ISO 9000. The ISO 9000[8] certification is time consuming and expensive but may be necessary for international sales. Claims such as organic production require an additional set of constraints provided by the NOSB, (National Organic Standards Board).[9] Compliance with organic standards is the responsibility of the USDA and NOSB.[10] OSHA regulates worker safety, which includes facilities, training, clothing and accident documentation. Environmental regulations for algal food and feeds are similar to biofuels production.[11] [1]http://www.fda.gov/Food/FoodIngredientsPackaging/ucm064228.htm [2]http://www.usp.org/food-ingredients [3]http://www.fda.gov/Food/FoodIngredientsPackaging/GenerallyRecognizedasSafeGRAS/ucm083022.htm [4]http://www.ift.org/food-technology/past-issues/2012/august/columns/perspective.aspx [5]http://www.fda.gov/food/guidancecomplianceregulatoryinformation/currentgoodmanufacturingpracticescgmps/ucm110877.htm [6]http://www.fda.gov/drugs/developmentapprovalprocess/manufacturing/ucm169105.htm [7]http://www.fda.gov/AnimalVeterinary/default.htm [8] ISO 9000 quality management - ISO www.iso.org/iso/iso_9000 [9]http://www.ams.usda.gov [10]http://www.usda.gov/wps/portal/usda/usdahome?navid=ORGANIC_CERTIFICATIO [11]www.osha.gov/law-regs.html Algae Biomass Organization | 16 Earthrise Nutritionals provides a detailed overview of algae nutritional safety issues, available through Earthrise University.[1] Algae pet and animal feeds and feed supplements need AAFCO (Association of American Feed Control Officials) certification.[2] Corporate buyers must comply with AAFCO, which is a different set of regulations than FDA for food. Additionally, companies like Ralston Purina and Mars Biosciences have strict QC requirements for all ingredients. Pet and animal feed companies cannot risk a recall due to an ingredient safety scare. States also impose regulations, inspection and license fees on pet, specialty pet, and animal foods, which are summarized by AAFCO.[3] Algal Food Processing. Similar requirements to the above hold for processing algae to make food and feed products. GRAS certification requires processing steps to be diagrammed and documented. GMP also must be documented, including cleanliness and contaminant processes and levels. Once approved, the FDA requires notification if a significant change has been made to the growth or manufacturing process. Testing. Food safety and security regulations require constant culture monitoring and documentation for the possible presence of toxins, bacteria, heavy metals, chemical residuals and other contaminants. GMP requires records from each batch of food quality control tests. Labeling. Food labeling regulations including nutritional facts and ingredients on packaged products are specified in the 2009 Food Labeling Guide and a series of Guidance for Industry reports available from the FDA home page.[4] Labels that make health claims create additional FDA documentation requirements for proof. Dietary supplements may be stand-alone or ingredients in functional foods or animal feeds. Dietary supplement labeling must comply with these 2007 FDA Regulations, FDA 21 CFR Part 111.[5] Foods and feeds made from algae or algae components can be a commodity, e.g. algal flour, a specialty product, e.g. algae energy drink or a power bar, or functional food, e.g. texturized algae meat product with omega-3 fatty acids. States also have the authority to regulate food quality and consumer protection. Several states are debating the use of genetically modified algae in food products. New York state Attorney General Eric Schneiderman issued subpoenas in August 2012 for 5-Hour Energy and Monster drinks that promise healthy bursts of energy. [1] www.earthrise.com/safety.html [2] http://www.aafco.org [3] http://www.aafco.org/Portals/0/AAFCO/state_regulatory_requirement_summary_2011-2012.pdf [4] http://www.fda.gov/food/labelingnutrition/default.htm [5] http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?cfrpart=111 Algae Biomass Organization | 17 Algae have been often relegated to health food stores in the past yet are expected to become staple components of major food manufacturers and retailers. The challenge confronting algae for food producers is compliance with well-established but potentially complex regulations. Several nutraceutical companies have successfully navigated the regulations including Earthrise Nutraceuticals, Cyanotech, Parry Nutraceuticals and Martek, now part of DSM. Solazyme-Roquette Nutritionals have achieved GRAS status for commercializing a suite of microalgae-derived food ingredients.[1] Transactions of Food Products. Buyers will require testing and documentation of nutritional elements and shelf life. Buyers want to know if any active ingredient oxidized or was in any way diminished during growth or processing. Special handling requirements such as stable temperature range need to be communicated by the seller. For regulatory authority during R&D and commercial production, please see the table in Appendix C. Appendix F: Requirements for Marketing a Biofuel The production of marketable bio-based fuels from algae is an important and exciting aspect of the algal industry. New refinery technologies are being developed to construct these fuels from algal biomass, extracted oils and volatiles like alcohol that are generated by algae. However, new fuels must meet a complex set of regulatory and commercial requirements before they can be marketed. These include environmental regulations, safety and infrastructure compatibility, and engine compatibility. In the United States the Clean Air Act prohibits sale of gasoline or diesel fuel that is not “substantially similar” to conventional fuel. In general these fuels are hydrocarbons meeting their respective ASTM standards, however EPA has ruled that aliphatic alcohols and ethers can be blended at up to 2.7 wt% oxygen and meet this requirement. Other materials must demonstrate that they will not cause or contribute to the degradation of vehicle emission control systems and can apply for a waiver of the substantially similar requirement. A second EPA requirement is fuel registration, which for biomass-derived materials regardless of composition will require a health effects literature search and detailed engine emissions speciation study. EPA also regulates underground storage tanks to protect ground water and requires that these tanks must be compatible with the materials stored in them. Compatibility can be demonstrated by third party testing (such as Underwriters Laboratories, UL) or by the manufacturer of the tank providing warranty coverage for use with the new fuel. Above ground equipment such as fuel dispensers, hoses and nozzles is required to have a third party listing as being compatible with the fuel being handled by both the Occupational, Safety, and Health Administration and typically also by local fire marshals. Third party testing normally requires that the fuel have an ASTM standard to serve as the basis for UL to develop a test fluid, and that manufacturers be willing to submit their equipment for testing and potential listing by UL. The fuels market is a commodity market. Products from different manufacturers are fungible, interchangeable as long as they meet a common ASTM standard. ASTM standards are developed by consensus of ASTM members (anyone can join ASTM). Members include fuel producers and distributors, engine and car makers, state fuel regulators, and other interested parties. ASTM standards are typically focused ensuring on safety in distribution and handling, as well as fuel-engine compatibility. ASTM standards may also be used to describe fuels for purposes of meeting EPA fuel registration requirements. Individual states are responsible for regulating fuel quality as part of consumer protection laws, and a majority of states use ASTM standards for this purpose. Producers of a hydrocarbon or fatty acid methyl ester biofuel may be able to demonstrate that it meets existing ASTM standards. While meeting all of these requirements requires a major effort, there have been a number of new fuels approved by EPA recently. [1] http://solazyme.com/nutrition Algae Biomass Organization | 18 In particular Dynamic Fuels,[1] Solazyme,[2] and KiOR[3] have successfully registered renewable hydrocarbon fuels. Gevo has received EPA registration for its isobutanol product[4] while competitor Butamax anticipates approval in 2014.[5] The ASTM Petroleum Products Committee is actively working to develop a fuel butanol standard. And finally, in June 2012 EPA accepted registration of 15% ethanol-gasoline blends.[6] Appendix G: Quality Attributes and Considerations for Trading Algal Oils Algal oils have the potential to be marketed and sold into both existing markets for oils and fats—such as cooking oils or feedstocks for biodiesel—as well as newly emerging markets such as aviation fuels, biocrudes, bioplastics, and biopolymers. Most of these applications utilize the oil in its entirety but there is also interest in high value applications for specialty oils or for specialty oil components, such as Omega 3 or Omega 6 fatty acids used in nutraceuticals. Trading rules and important quality attributes of existing oils and fats are well established. They are based on a combination of key attributes common to naturally occurring triglycerides (oils/fats) or important characteristics of the use of the oil/fat. The algal industry will need to provide characteristics of algal oil allowing it to be easily compared to existing oils/fats. This will facilitate its acceptance into both existing and emerging markets as well as simplify buyer/seller agreements, hedging, and other aspects important to the buying/selling of oils and fats. While it is premature at this time to develop specific standards or trading rules of algal oils, those for existing oils/fats can serve as a useful guide for the attributes and specific values of algal oils that will be demanded by customers. Traditional oils and fats are generally broken down first by whether they are edible or inedible, by their source (soybean, corn, beef, pork, sunflower, used cooking oil, etc.), and then by various industry terms which generally describe their quality (crude, refined, refined and bleached) or their end use (technical grade, feed grade, etc.). Various trade groups publish trading standards, guidelines, or quality standards for oils and fats.[7],[8],[9],[10] A summary of the most common quality characteristics, testing methodologies, and values are incorporated into the table below. Different end users or customers may want additional information (i.e. more specific fatty acid profile for high value nutraceuticals), but the attributes and values below provide some good targets for the types of information that will need to be provided in order for the algal oil industry to continue to grow. [1] http://www.globenewswire.com/newsroom/news.html?d=237679 [2] http://www.algaeindustrymagazine.com/solazyme-receives-fuel-registration/?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+AlgaeIndustryMagazine+%28Alg ae+Industry+Magazine%29 [3] http://investor.kior.com/releasedetail.cfm?ReleaseID=694743 [4] http://eponline.com/articles/2010/11/13/gevos-isobutanol-secures-epa-registration-for-use-as-fuel-additive.aspx [5] Kris, Bill “Can biobutanol provide ethanol producers new paths towards diversification?” Ethanol Producer Magazine, March 2012. [6] http://www.agweb.com/article/epa_gives_final_approval_to_e15_ethanol_blend/ [7] National Oilseed Processors Association, Trading Rules for the Purchase and Sale of Soybean Oil, www.nopa.org [8] AOCS (American Oil Chemist Society), Ck 1-07 Analytical Guidelines for Assessing Feedstock to Ensure Biodiesel Quality, www.aocs.org [9] National Renderers Association, Pocket Information Manual: A Buyers Guide to Rendered Products, www.renderers.org [10] National Institute of Oilseed Products, Trading Rules (covers vegetable oils other than soybean oil), www.niop.org Algae Biomass Organization | 19 Document Revision: This Minimum Descriptive Language document will be periodically revised based on ongoing stakeholder input. 5 MDL Information for Stakeholder Comments: To comment on this document or recommend improvements, please send suggestions to Barb Scheevel, Administrative Coordinator, via e-mail at bscheevel@algalbiomass.org. For futher information on this document and the ABO’s Technical Standards Committee, please contact Jim Sears, Chair of the Technical Standards Committee and President and Chief Technology Officer of A2BE Carbon Capture LLC, via e-mail at jimsears@algaeatwork.com or via phone at 303-587-1733. Algae Biomass Organization | 20 Members | 2012 Platinum Gold Corporate AMEC Applied Chemical Technology Aurora Algae Australian Trade Commission Battelle Pacific Northwest Division CBO Financial, Inc. Church & Dwight Colorado Lining International Combined Power Cooperative ECO2Capture Electric Power Research Institute FedEx Express Fluid Imaging Technologies, Inc. Fredrikson & Byron, P.A. GF Piping Systems GreenField Ethanol, Inc HDS International Corp International Air Transport Association IGV Institut fuer Getreideverarbeitung GmbH Keller And Heckman Llp Kent BioEnergy Corporation Kimberly-Clark Corporation Life Technologies Matrix Genetics MicroBio Engineering, Inc MTU Aero Engines GmbH National Alliance for Advanced Biofuels and Bio-Products Neste Oil Corporation Ohio Industry Development Committee OpenAlgae OriginOil, Inc POS Bio-Sciences Saudi Basic Industries Corporation SFN BioSystems Inc. Siemens Industry, Inc. Solix Biofuels, Inc. Solution Recovery Services Stoel Rives, LLP Synthetic Genomics Texas AgriLife Research The Linde Group Waste Management Inc. World Water Works, Inc. Supporting Organizations Biotechnology Industry Organization National Biodiesel Board Phycological Society of America Algae Biomass Organization | 21
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