October 2020 - Ethanol Producer Magazine

OCTOBER 2020

CHARTING A RECOVERY Producers Surveyed On COVID-19 Impact PAGE 16

ALSO

Keeping Lab Tech Between the Lines PAGE 28

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Contents

16 OCTOBER 2020 VOLUME 26

24

AD INDEX

6

PUBLISHER'S NOTE Election Nears, Help Arrives

FEATURES 16 OUTLOOK

Ethanol’s Recovery Readout

By Tom Bryan

7

EVENTS CALENDAR

8

VIEW FROM THE HILL 15 Years of the RFS: A Reason to Celebrate

By Geoff Cooper

10

Producers surveyed on COVID-19 impact

By Lisa Gibson

24

DRIVE Trust Me. I’m From the Government and Here to Help

By Dave VanderGriend

14

BUSINESS BRIEFS

38

MARKETPLACE

PROFILE

Rural Values

The career story of FEW awardee Doug Tiffany

GLOBAL SCENE The UK and Decarbonizing Transport

By Brian Healy

12

28

USDA

ISSUE 10

DEPARTMENTS 4

AEMETIS INC.

By Tom Bryan

28

CONTRIBUTION 32 REGULATION

Tenuous Toxicity Concerns Guidelines for acetaldehyde in sanitizer questioned

By Jim Buchacker and Jim Forshaw

SPOTLIGHT 36 Foundation Analytical Inc. Science Built, Client Driven Contract lab founded on service, technical precision EPM Staff Report

LAB

Between the Lines

Control charts help ethanol plants avoid variability

By Matt Thompson

ON THE COVER Ethanol Producer Magazine: (USPS No. 023-974) October 2020, Vol. 26, Issue 10. Ethanol Producer Magazine is published monthly by BBI International. Principal Office: 308 Second Ave. N., Suite 304, Grand Forks, ND 58203. Periodicals Postage Paid at Grand Forks, North Dakota and additional mailing offices. POSTMASTER: Send address changes to Ethanol Producer Magazine/Subscriptions, 308 Second Ave. N., Suite 304, Grand Forks, North Dakota 58203.

Ethanol Producer Magazine’s survey of ethanol producers yields insight on the health of the industry, which suffered serious damage this spring but is now on a path toward recovery.

PHOTO: ETHANOL PRODUCER MAGAZINE

ETHANOLPRODUCER.COM | 5

Publisher's Note

Election Nears, Help Arrives As we approached press time with this magazine in mid-September, good things were suddenly happening for ethanol. President Trump declared by Tweet that the U.S. federal government should allow E15 to be dispensed in E10 pumps, giving our industry a potential bypass to a real infrastructure challenge. Then, short of a full correction of its years-long abuse of small refinery exemptions (SRE), the U.S. EPA denied the oil industry’s pending “gapyear waivers,” an action our industry was battling hard for. And on top of it all, Brazil announced it would defer its restrictive tariff rate quota for an extra 90 days—well past November—which U.S. producers embraced while highlighting the impermanence of the reprieve.

These developments, while curiously timed, are undeniably positive for our industry and really could accelerate the recovery we are already experiencing. There’s no denying that our industry is a political creature— maybe too much so—but there’s a real fairness in our amplified voice during presidential election years. This time around, ethanol producers have been genuinely mad at the Republican incumbent, and they needed Trump to give them something—anything that looked like real support—before Election Day. And now he has.

In this month’s cover story, “Ethanol’s Recovery Readout,” on page 16, Lisa Gibson reports on the results of our recent survey of ethanol plant general managers and CEOs on the operational impact of COVID-19, their current state, their outlook on recovery and even their views on the upcoming presidential election. It’s fair to say most producers are very dissatisfied with the current administration’s action on SREs, which, over time, has damaged our industry more than the pandemic and the trade war with China combined. Our survey results indicate that most producers are, indeed, on the road to recovery—a majority approaching normal production levels this fall—and a surprising many producing high-end alcohols for sanitizer and other uses. They seem to agree that the industry’s recovery will take several months—a year or more, many said—yet a surprising number of producers are actively evaluating or investing in new technologies to enhance efficiency. Perhaps that shouldn’t have surprised us, but it did.

Even in difficult times, the ethanol industry seeks to improve its already superb quality assurance practices, and that can only be accomplished with accurate lab instruments. In “Between the Lines,” on page 28, Matt Thompson helps us understand the benefits of control charts, statistical tools that help lab managers recognize and correct variability in their operations. Not all ethanol plant labs use control charts, but our sources say they probably should.

In “Rural Values,” on page 24, we profile the career of 2020 International Fuel Ethanol Workshop & Expo Award of Excellence recipient Doug Tiffany, who graciously shares his story with us. The University of Minnesota production economist has contributed to our industry by studying it from the outside, and offering producers, starting years ago, the kind of unconventional ideas they’re now closely examining.

Enjoy the reading.

Tom Bryan President BBI International

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A View From the Hill

15 Years of the RFS: A Reason to Celebrate

Geoff Cooper

President and CEO Renewable Fuels Association 202.289.3835

gcooper@ethanolrfa.org

So much of our industry’s time and effort in recent years has been focused on reacting to crises, defending against misguided attacks, and addressing day-to-day challenges. Whether we are coping with the market impacts of COVID-19, responding to myths and misinformation about ethanol, or fighting to protect the Renewable Fuel Standard, these daily skirmishes sometimes make it too easy to lose sight of the big picture.

When we are so focused on “fighting fires,” we often forget to stop, take a breath, and reflect on the victories and successes that got us to where we are today as an industry.

But Aug. 8 provided us one of those rare opportunities to take a break from the daily grind and look back on one of the most important moments in the history of renewable fuels. In a watershed moment for America’s ethanol industry, President George W. Bush signed into law the first-ever Renewable Fuel Standard on Aug. 8, 2005. Surrounded by the leaders in Congress and the administration who made it possible, Bush astutely outlined the complementary objectives of the policy as he signed the bill: “Using ethanol and biodiesel will leave our air cleaner. And every time we use a home-grown fuel, we're going to be helping our farmers, and at the same time, be less dependent on foreign sources of energy.”

Cleaner air. Boosting the farm economy. Energy security. Those were the laudable goals of the original RFS. Fifteen years later, we can proudly proclaim that the RFS hasn’t just lived up to its ambitious expectations—it has far exceeded them.

As the Renewable Fuels Association outlined in an anniversary report, the RFS has been a smashing success. In addition to decreasing reliance on imported petroleum, this policy has reduced emissions of harmful tailpipe pollutants and greenhouse gases, lowered consumer fuel prices, supported hundreds of thousands of jobs in rural America, and boosted the agricultural economy by adding value to the crops produced by our nation’s farmers. And far from “distorting the free market,” as RFS opponents often claim, the policy has been remarkably effective in stimulating market competition and giving consumers more choices. Simply put, the RFS ensures renewable fuels can gain access to a fuel market that had been monopolized for nearly a century and would otherwise be closed to competition.

Because the RFS has succeeded in replacing petroleum with cleaner renewable fuels, the policy has come under fierce attack from the incumbent fossil fuel industry and its supporters. The oil industry and its allies continue to devise strategies and tactics intended to frustrate the goals of the RFS, undermine and complicate implementation, and mislead the public about the many benefits of renewable fuels. But we have met and overcome those challenges at every turn, and we will continue to protect and defend the RFS from relentless assaults.

While the 15th anniversary of the RFS provides an opportunity to pause for reflection, there’s no time to rest on the policy’s laurels. The RFS isn’t done yet. Indeed, it’s only gotten started. Contrary to the narrative advanced by some critics of the program, the RFS does not “end” or “sunset” in 2022. Congress clearly intended for the RFS to continue driving innovation and growth in renewable fuels production and usage well beyond 2022.

In its next chapter, we believe the RFS will drive accelerated decarbonization of our liquid fuel supply, stimulate increased fuel and engine efficiency, further diversify our fuel mix, expand economic opportunities for the farm sector, and catalyze even lower prices and greater competition at the pump—all because of the enduring policy foundation created 15 years ago.

So, while we must continue to respond to whatever crisis du jour comes at us next, we cannot lose sight of how far we’ve come. Amidst the chaos and confusion of COVID-19, small refinery exemptions, trade wars, and the election, 15 years of the Renewable Fuel Standard is truly something to celebrate.

8 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Global Scene

The UK and Decarbonizing Transport

Brian Healy

Director of Global Ethanol Market Development U.S. Grains Council 202.789.0789

bhealy@grains.org

Consultations about decarbonizing transport are ongoing in the U.K., as the country considers transitioning from its current 5% to 10% ethanol blend rate. A national E10 ethanol policy would make a substantial contribution toward achieving the decarbonization goals by reducing emissions and fully capturing the octane value of ethanol.

The most affordable and impactful change that can be made is to immediately institute a national minimum requirement of a 10% ethanol blend. The U.K. has cited the importance of reducing emissions from the transport sector in response to the International Energy Agency’s 2-degrees-Celsius scenario and Paris Climate Accord. In the U.K., the transport sector is responsible for approximately 20% of national emissions. Perhaps most relevant to the development of the U.K.’s decarbonization plan is the greenhouse gas (GHG) reduction qualities of ethanol when blended into the transportation fuel mix. According to a 2019 U.S. Department of Agriculture study, corn-based ethanol achieves a 39% to 43% reduction in GHG emissions compared to gasoline on an energy equivalent basis, and ethanol’s GHG reduction performance is only improving to achieve GHG reductions of 70% by 2022.

Because of ethanol’s high-octane, low-cost properties, blending E10 can reduce the cost of producing finished gasoline. To lower fuel production costs in the U.K., fuel blenders have learned to take advantage of ethanol’s inexpensive octane properties. They’re maximizing their refining processes to reduce the overall cost of producing gasoline by producing blend stocks for oxygenate blending, or BOBs, specifically designed to be blended with 10% ethanol.

But the Renewable Fuel Transport Obligation consultation language places a 4% cap on crop-derived biofuels, which will decrease to 2% in 2032. Capping crop-based biofuels would severely limit the U.K. government’s ability to meet its potential E10 blending goal. If the U.K. were to proceed with capping the level of crop-based biofuels allowed to meet the RTFO, the potential for ethanol to green the U.K. fuel system would also diminish. The second iteration of the Renewable Energy Directive in the EU, or RED II, also proposed a similar phase out, but the language was struck from the final policy. A deliberate and enforced E10 blending policy is instrumental for achieving meaningful emissions reductions.

The U.K. already has industrial knowledge in ethanol production. But lack of consistent, domestic demand and a sufficient policy have forced ethanol production facilities to close. Through expanded ethanol use, the U.K. has an opportunity to meet its stated decarbonization objectives and support the domestic facilities that have gone offline. The U.K. will be able to build on its established technical knowledge for E5 as it transitions to E10. Making that transition should be a cornerstone of the U.K.’s bioenergy initiatives in decarbonizing transport. E10 will provide significant benefits in the form of lower GHG and air pollutant emissions, energy diversification, and will fully use ethanol’s well-established octane value.

10 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Clearing the Air

Trust Me. I’m from the Government and Here to Help

Dave VanderGriend

President, Urban Air Initiative CEO, ICM Inc. 316.796.0900

davev@icminc.com

Uh, no thanks, and on the count of three let’s all do an eye roll. Those of us in the ethanol industry know not to expect much help from the government. We put a lot of trust in our legislators and federal agencies, with little to show for it.

So who do we trust to take the shackles off and let ethanol and all biofuels compete in the world’s largest gasoline market?

In January of 2017, as President Donald Trump came to Washington, we didn’t know what we didn’t know.

He was an entirely new breed of politician and, in fact, often said he was not a politician. But what we thought we did know was that he was determined to remove regulations that were holding back American business. So that held some excitement and promise as to the art of the possible.

As we looked for new markets and demand for ethanol and the agriculture products that power it, we knew we were a good fit for a new era of regulatory reform. And we laid out a clear path through various comments, early meetings with the U.S. EPA, countless articles and presentations, and even direct communication with the president. Actions that cost nothing but could have tremendous returns. It’s no secret that all of these actions, all of the roadblocks, land at the doorstep of EPA. Yet, almost four years later, none of our issues have been addressed.

Our ethanol and agriculture industries are reeling from EPA’s systematic destruction of the RFS and the failure to open access to the market. No White House can micromanage agency rulemakings, and EPA continues to chip away at ethanol, in many cases by doing nothing. Consider this list of regulatory reforms we presented in comments to EPA nearly four years ago, and have repeatedly presented in the years since. These were deregulatory, free market steps needed to increase demand, all of which have been ignored.

• Allow the Reid vapor pressure waiver to apply to all ethanol blends because vapor pressure actually decreases as volume increases. (While we did get an E15 waiver, we are limited from higher blends.)

• Approve an E30 certification fuel.

• Approve blends up to E30 for distribution through legacy pumps and for use in legacy vehicles.

• Reinstate vehicle mileage credits to encourage auto makers to build ethanol-optimized vehicles.

• Correct the Motor Vehicle Emission Simulator (MOVES) model that currently penalizes ethanol by adulterating the gasoline portion of the test fuels that are currently imbedded in the Clean Air Act. • Enforce the aromatic toxic caps on gasoline.

• Raise the minimum octane requirement for all gasoline.

• Update ethanol’s life cycle analysis as required by law.

So, now who do you trust? Well, I trust you—the ethanol industry—to use common sense and recognize we are at the edge of the cliff. With the future of the RFS uncertain, with overall gasoline demand likely to continue to decrease, and with an EPA that has not been helpful, we need to preserve the liquid fuel market. To get the job done, we are going to have to expand our circle of trust to refiners, environmentalists, and others we may not always agree with.

The ethanol industry has a powerful voice when we speak as one. We need to use that voice, trust ourselves that we have a product that cleans the air, creates jobs and feeds the world. Which brings us back to Congress, people elected to represent us—our views, our values, and our products. We need to demand our legislative representatives reign in EPA and require them to stop penalizing ethanol. It is on us to present a comprehensive plan beyond simply maintaining the RFS and getting E15.

While some may say it is impossible to pass legislation in a dysfunctional Congress, I say we need to try.

Let’s take the pen out of EPA’s hand, work with our partners in the liquid fuel market and bring Congress something it can work with—a plan that embodies the wish list of four years ago and sets our path for the next four years and many more.

12 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

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BUSINESS BRIEFS PEOPLE, PARTNERSHIPS & PROJECTS

Poet partners with FBN on lower-carbon farming Poet has formed a partnership with Farmers Business Network to boost profits for farmers while promoting sustainable agricultural practices.

The partnership will leverage FBN’s GRO Network, which matches farmers who use environmentally friendly practices with buyers who pay a premium for lowcarbon corn. The program measures the

benefits of conservation practices used by farmers on their land. This results in farmlevel carbon-intensity scores that support low-carbon fuels.

“At Poet we know that agriculture is the key to combating climate change, and we want to support farmers who share our mission to be good stewards of the Earth by using environmentally friendly practic-

TM

es,” said Poet Founder and CEO Jeff Broin.

“We are excited about the potential of the GRO Network to promote sustainable agriculture and utilize the resulting low-carbon corn to produce even greener bioethanol and bioproducts.”

ClearFlame wins $1.1 million DOE grant ClearFlame Engine Technologies has been awarded a two-year, $1.1 million Phase II grant from the U.S. Department of Energy’s Small Business Innovation Research program. The funding will support the company’s development of clean engine technology for the heavy-duty truck, offhighway and industrial markets.

The company’s engine technology en-

ables low-carbon fuels such as ethanol to be integrated into existing diesel engine platforms.

“The results we achieved in Phase I of the DOE SBIR program successfully demonstrated the methodology and experimental process for optimizing a diesel-style engine to be more efficient using decarbonized liquid fuels,” said Julie Blumreiter,

chief technology officer and co-founder of ClearFlame. “During Phase II, we’ll focus on additional validation through our collaboration with Argonne National Laboratory and the University of Illinois UrbanaChampaign.”

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14 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Aemetis closes on $35.5 million of EB-5 funding Aemetis Inc. has closed on its $35.5 million Phase I EB-5 Program funded by 71 foreign investors. The EB-5 Program is authorized by the U.S. Immigration and Naturalization Act and designed to provide employment-based visa preferences for immigrant investors who deploy capital into U.S.-based projects that provide jobs for American workers.

Aemetis closed its Phase I EB-5 Program with the issuance of 71 subordinated convertible promissory notes, raising $35.5 million of low-interest investment funds used to create both direct and indirect jobs at its high-grade alcohol and fuel ethanol plant in Keyes, California.

Aemetis Chairman and CEO Eric McAfee said the project exemplifies

sound immigration policy that generates U.S. investment and creates jobs. He said the company has already launched a second phase of EB-5 funding with plans to issue $50 million in additional notes.

Highwater Ethanol invests in USP-grade alcohol production Highwater Ethanol LLC, a 59 MMgy ethanol plant in Lamberton, Minnesota, has filed an 8-K with the U.S. Securities and Exchange Commission announcing an agreement with Nelson Baker Biotech Inc. for the installation of a system to produce 20 MMgy of hydrous USP-grade ethanol, which is used in the sanitizer market.

The filing indicates Highwater and Nelson Baker executed the construction agreement on Aug. 26. The agreement includes design, engineering and construction management. Construction is expected to begin before November and reach

completion in the second fiscal quarter of 2021.

Highwater Ethanol is among many U.S. ethanol plants venturing into high-end alcohol production, according to Ethanol Producer Magazine’s recent survey of U.S. producers (see page 16).

ETHANOLPRODUCER.COM | 15

Outlook

Since the COVID-19 pandemic slammed the ethanol industry in March of this year, almost 30% of producers recently surveyed by Ethanol Producer Magazine have drastically changed daily operations.

Twenty-five percent said the economic downturn seriously affected operations and business. Still, almost 84% of respondents laid off only 1% to 5% of their staff.

EPM emailed a 23-question survey about the impacts of COVID-19 to CEOs and general managers of U.S. ethanol plants. Fortyfour completed the survey, providing a snapshot of experiences across the industry.

Production

Production slowdowns started as early as February for some, and as late as May for others. One producer didn’t slow production, but increased it, while another also maintained but “emptied the tanks” during the downturn.

Less than 10% of respondents lowered production by more than half of their pre-pandemic production volume; the majority—more than a third—lowered by 31% to 50%. Interestingly, 0 to 10% was the

16 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

next most common reduction, at 28%. Results showed 12% lowered production by 11% to 20%; 16% lowered production by 21% to 30%; and 9% reported reductions of more than 50%.

U.S. Energy Information Administration data reports a sharp decrease in production of more than 35% from March to April (1.04 million barrels per day to 672,000).

As of the end of August, almost 32% of survey respondents said production had increased more than 50% since the low point. Twenty percent said production had only increased 0 to 10%; 16% reported an 11% to 20% increase; about 14% reported an increase between 21% and 30%; and 18% said production had increased 31% to 50%.

Daily Operations

While one-fourth of respondents said their operations were seriously affected by the COVID-19 slowdown, just 7% said they were severely affected—the only worse category. The others reported less negative effects. About one in five respondents said operations were somewhat seriously affected; a third of them said operations were moderately affected; and 16% reported no effect at all.

Thirty percent said drastic changes have been required in areas such as safety protocols, schedules and meetings. About 43% reported

Ethanol's Recovery Readout

numerous changes were required; one-fourth reported few changes; and just 2% said the pandemic required no changes to operations.

More than 54% of respondents said they have produced hand sanitizer or other high-end commercial alcohols during the pandemic.

Thirty-two percent said they have not; and 12% said they are considering it. More than 57% of those producing sanitizer or high-end alcohol said they will continue to produce it after the FDA guidance for ethanol in hand sanitizer expires. The remainder said they will not.

Expenses are being reduced in a several ways beyond decreasing production, including reducing hours, paying more attention to feedstock prices, minimizing travel and other expenses, shortening planned shutdowns, overtime reduction, reducing maintenance, freezing capital projects, lowering chemical usage, and negotiating price breaks with vendors. Some respondents also said they are reducing staff.

Those reported reductions have amounted to considerable savings, sometimes up to or more than $100,000 per month, as reported by three respondents. One producer said they’re saving about $34,000 per month, another $10,000 per month, and one facility reported that 90% of its expenses had been eliminated, presumably due to being idle. Many declined to give a dollar amount or percentage.

A survey of ethanol plant CEOs and general managers shows the COVID-19 downturn had a substantial, but not lasting, impact on their operations.

By Lisa Gibson

Staff and Pay

About 84% of CEOs and general managers who took the survey said they only had to layoff or furlough 1% to 5% of employees.

Approximately 10% of respondents said they laid off or furloughed more than 25% of their staff. About 3% reported 6% to 10%, mirroring the 11% to 15% range. No respondents said they laid off or furloughed 16% to 25% of their staff.

Morale has been affected, too. More than one-fifth of respondents said employee morale has been affected somewhat seriously; 47% reported moderate effects; 30% said morale has not been affected at all. Thankfully, no respondents reported severe blows to morale during the pandemic.

About 88% of respondents said no employees have voluntarily resigned over dissatisfaction during the pandemic, while about 12% said they have had voluntary resignations as a result of dissatisfaction.

The resignations included operators, supervisors, receptionists and accountants. All respondents reporting voluntary resignations said they will replace those employees, though some must wait until the plants resume production. About 76% of respondents said they have not frozen hiring, while 24% said they have.

Similarly, about 62% said they have not suspended pay raises or ETHANOLPRODUCER.COM | 17

Outlook

What percentage did you lower production during COVID-19?

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SOURCE: ETHANOL PRODUCER MAGAZINE

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To what degree did your facility alter its daily operations because of COVID-19? (i.e., safety protocols, schedules, meetings, etc.)

SOURCE: ETHANOL PRODUCER MAGAZINE

bonuses. Nineteen percent said they have not decided whether to suspend raises and bonuses; less than 10% said raises and bonuses have been suspended; 2% said bonuses have been suspended; and 7% said raises have been suspended.

Recovery and the Future

The majority of survey respondents 76% reported that fuel market stability and recovery are their main concerns in terms of maintaining normal operations during the pandemic. None said their main concern is coproduct market stability; and 19% said their main concern is personnel health. It is reasonable to assume all respondents have similar concerns about employee health during the pandemic, but simply do not view it as a primary operational threat. Write-in responses included staffing concerns, the political climate, the upcoming election, and U.S. EPA’s lack of cooperation.

Recovery seems to be a ways out, ac-

cording to most respondents. Nearly half of the producers that responded expect it will take more than a year for the ethanol industry to recover. Twenty-nine percent expect full recovery in six to 12 months; 14% in three to six months; about 5% said one to three months; and another 5% said the industry is already recovered, which doesn’t square with the industry’s collective production rate—still 10% below last year—and is presumably a reflection of their own experience.

An astonishing 93% said they are evaluating or investing in new product technologies to enhance operational efficiency. They include high-end alcohol, cogeneration, high-protein coproducts, wind and solar technologies, additives, energy efficiency gains, fiber separation, distillation, centrifuges and carbon reduction.

Respondents are largely dissatisfied with the current administration, saying President Donald Trump has been too pro-

imagination

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ETHANOLPRODUCER.COM | 19

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Have you produced sanitizers or other higher-end commercial or industrial alcohols during the pandemic?

SOURCE: ETHANOL PRODUCER MAGAZINE

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oil, has not matched actions with promises, and has given far too many breaks to big oil.

One respondent said, “Current administration rhetoric, does not match their actions. No reason to think that will improve if they have another four years and no reelection pressure.”

Another wrote, “We need an administration that is going to follow the law and not cave to the oil industry.”

One respondent did say Trump’s support is critical to the ethanol industry. A few others said neither party is friendly to corn or ethanol, and one said politics drive too much.

As for trade, respondents expressed severe concern about China, citing the vitality of exports for U.S. ethanol. “If we don't get international markets opened up it will severely impact American agriculture,” one said. Another responded, “I do not think China was ever realistically going to be a viable source

for ethanol exports. There will always be some global market for DDGS.” Other countries raising trade concerns include Brazil, Canada and Mexico. A few said they have concerns with EU markets, as well.

Moving forward, small refinery exemptions (SREs) prompt intense concern, reported many respondents. Of 29 responses to the question of other policy concerns, 12 centered on SREs. Other responses included trade policy, additional demand loss, E15 or E30 growth, guidelines for USP-grade ethanol, and oil prices.

One respondent likely summed up the mentality of many producers, when they said, “I am concerned about all things these days.

Seems like head wind on everything we do.”

Author: Lisa Gibson Editor, Ethanol Producer Magazine 701.738.4920 lgibson@bbiinternational.com

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How long do you predict it will take the industry to fully recover (reach normal production levels) from the COVID-19 downturn?

SOURCE: ETHANOL PRODUCER MAGAZINE

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PROFILE

RURAL

VALUES The proliďŹ c career of Doug Tiffany, recipient of the 2020 Award of Excellence, is indelibly linked to his connections to agriculture and farmland.

By Tom Bryan

24 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Doug Tiffany sees ethanol differently than some people. He studies it from peripheral positions— not as an insider—and through the candid lenses of economics, science and technology. He views the ethanol industry not just for what it is, but what incremental technology improvement, and intelligent change, might make it. And, though he cares deeply about ethanol, especially the people and communities it supports, Tiffany’s decades-long interest in biofuels is rooted in his devotion to land and resource optimization. The efficient, profitable production of biofuels, he says, raises the value of farmland—and that, to Tiffany, hits home.

Raised on a farm outside of Redwood Falls, Minnesota, a town nestled around the lake of its namesake 100 miles west of the Twin Cities, Tiffany developed an early appreciation of nature, agriculture and the variable worth of land supporting almost everything around him.

His early upbringing was the standard stuff of farm kids—he pitched in, played, performed chores and joined 4H. While seemingly ordinary, those early life experiences, coupled with Tiffany’s aptitude for ag-based studies—economics, biology, animal science, agronomy— planted a seed in him that would, in due time, become his life’s work.

It wouldn’t happen overnight. The career path of the 2020 International Fuel Ethanol Workshop & Expo’s Award of Excellence recipient was relatively circuitous, and years before his career as a production economist at the University of Minnesota began, he would try his hand at other occupations: banking, land appraisal and farming.

None were his calling, but neither was any experience wasted on Tiffany. A consummate student of life, he has always enjoyed learning about the world around him. At the age of 17, Tiffany left high school for a semester as a foreign-exchange student in Malaysia, where he lived with a Chinese family in a small village that had no cars or trucks and could only be reached by boat. The experience broadened Tiffany’s worldview and, perhaps, sparked his latent interest in the patterns of industry and resource utilization. “It was an important event in my life,” he says. “It was my first real experience seeing how people lived in other countries, how they worked and what supported their economy.”

Learning ‘Values’

Tiffany returned from Malaysia a more mature and poised young man. He finished high school and enrolled in the University of Minnesota, completing his undergraduate degree in agricultural economics.

After college, he began training as a farm banker but changed course when the economy “hit the skids” in the mid-1970s. “I decided to go back and get my master’s degree,” he says. “I doubled down on what I had already studied—more science, ag science and the accompanying economics courses. Specifically, I studied land economics, and that was really the start of my professional interest in that field.”

In 1977, Tiffany completed his master’s degree in agricultural eco-

nomics and took a job as a land economist with the Minnesota Department of Revenue. His life as a university faculty member was still 17 years off, but the practical launch of a 40-year career focused on the economics of land, farming, precision ag and bioenergy had begun.

The job gave Tiffany valuable experiences he’d draw upon later in his career as a production economist analyzing ag-based industries: biofuels, biomass power, wind energy economics, production of ammonia fertilizer from wind power, and all manner of rural enterprises.

Tiffany enjoyed working for the state and stayed with it for seven years, evaluating land values across Minnesota. “I had a number of responsibilities, but the one constant was that I was always working around ag resources and focused on understanding those values,” he says. “I saw so many examples of value-added activities that would later be mirrored by ethanol production. When something comes along and supports the use of a crop like that, you see how it positively affects the land base. And when processing technologies improve, demand on the resources also change. I saw that firsthand across the landscape of the state.”

After departing from the Minnesota Department of Revenue in the mid-’80s, Tiffany returned to farming and appraisal work—his fallback professions—before resuming his career as a land economist with Farm Credit Bank of St. Paul, where he provided guidance and training for appraisers in Minnesota, North Dakota, Wisconsin and Michigan.

“Again, it was an experience that deepened my understanding of how the value of land is affected not only by the crops that it can produce, but what can be done with those crops after they leave the farm.”

Tiffany would carry those lessons with him when he landed a position as a research fellow with his alma mater, the University of Minnesota, in 1994. At the U of M, Tiffany discovered his passion for research at the intersection of industry and academia. Within the Department of Applied Economics—where he resided for many years before moving to the Department of Bioproducts and Biosystems Engineering—Tiffany participated in an array of techno-economic and value-added ag analyses, working on projects related to ethanol, biodiesel, biomass, precision ag, phosphorous abatement, livestock, grain shipping patterns, farm-based power, alternative energy and more. He lectured, traveled and taught courses on land appraisal, while also developing land and real estate methodologies, tools and banking products.

Biofuels Beckoning

In the early 2000s, with biofuels production growing swiftly, Tiffany’s work frequently focused on ethanol and biodiesel. His reputation as a pragmatic, solutions-oriented economist was established in the ethanol industry as his work, on numerous occasions, focused on enhancing the profitability of dry-grind ethanol plants and utilizing biomass as a source of process energy. A spreadsheet model that he created and placed online in 2003 became very popular as farmers considered investments in ethanol plants across the Corn Belt.

GRANULAR DETAILS: Over the years, Tiffany has participated in an array of ethanol industry related research, including a project that modeled the extraction of phytate from distillers grains in order to make the coproduct more digestible to animals.

PHOTO: UNIVERSITY OF MINNESOTA

ETHANOLPRODUCER.COM | 25

PROFILE

FIELDWORK: 2020 Award of Excellence winner Doug Tiffany grew up on a farm in south-central Minnesota. Much of his distinguished career has been focused on improving the economics of ag-based industries and rural enterprises.

PHOTO: UNIVERSITY OF MINNESOTA

Tiffany took on notable, sometimes unconventional, concepts related to improving biofuels economics. One high-profile project, sponsored by Xcel Energy and the Agricultural Experiment Station at U of M, developed technical data and economic tools to guide the decisions of ethanol plants considering biomass power. Tiffany and his colleagues examined the potential for ethanol producers to use a combination of corn stover and distillers grains as an energy feedstock for combined heat and power (CHP). “Ethanol plants were facing some high costs for natural gas, and we thought it was time to roll up our sleeves and look for solutions,” he says. “Biomass appeared to be a good option. If we could economically collect that corn residue and use some of the DDGS—not all of it—it could fuel the plant and make them completely independent of any other power source. They wouldn’t have needed any gas or electricity.”

Like other concepts Tiffany would investigate, biomass CHP was unquestionably compelling, but perhaps ahead of its time.

Today, interest in CHP is experiencing a resurgence, as producers seek to lower their carbon intensity ratings. Tiffany says he has never been dissuaded by the fact that novel produc26 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

tion concepts can take years or decades to gain acceptance. “It can be frustrating, but a lot of things are a matter of timing,” he says. That’s one of the things I’ve really come to appreciate. I think the whole CHP opportunity is still largely in front of the ethanol industry. Good ideas are left at the alter sometimes simply because they are too early.”

As Tiffany and his university collaborators promoted the biomass CHP concept throughout the ethanol industry, natural gas prices sank amid the fracking revolution, but that didn’t make the plan obsolete. “At that point we said, ‘What if ethanol plants could actually become peaking plants for the power companies and could, therefore, supply energy to the grid while producing waste heat for the ethanol process—cooking, mash and distillation,’” Tiffany says, explaining that the team envisioned some ethanol plants running on CHP and providing dispatchable reserve power to back up wind farms.

And while the CHP ideas Tiffany proffered all those years ago may not have become commonplace in the U.S., he says the work has had incredible international reach. “Even today, there are people reading our work,” he says. “I get notices every week that the research is being cited, especially by people in developing countries where they are pursuing combined heat and power. They’re following the methodology and looking for ways to utilize heat from power production, whether it’s running an industrial process or heating homes. That’s rewarding to see.”

Tiffany’s research has also focused on ethanol coproducts. About five years ago, Tiffany joined a research project, led by U of M Associate Professor Bo Hu, that modeled the extraction of phytate from distillers grains in order to make DDGS more digestible to animals, thereby leading to less phosphorous leaching in the environment. “It’s another use for a product that’s right at our fingertips, and we could actually produce a lot of it from corn ethanol plants here, instead of extracting phytate from rice hulls in China and Japan,” he says. “But again, it’s an idea that may sit on the shelf until the right combination of things come along. I’ve really learned to be patient.”

Deserving Recognition

Tiffany attributes much of his success to the support of his university colleagues, people like Vern Eidman (retired, professor emeritus, U of M), Vance Morey (retired, U of M) and numerous other university colleagues, grad students and post-doctoral fellows. “I have been fortunate to have so many wonderful, talented people to collaborate with,” he says, reflecting on numerous co-authored papers related to biofuels and biomass energy, some of which received professional acclaim.

Tiffany, for example, was part of a team that won outstanding paper at the Conference of Bioproducts and Biosystems Engineers in 2010, and he received the Green Award the same year for the creation of the Alternative Vehicle Decision Tool, designed to help consumers understand the costs of ownership and operation of various types of cars and trucks: electric, extended-range electric and conventional gas vehicles.

But beyond the accolades, Tiffany says, he is most appreciative of the variety of topics he has been able to work on. “I think too many faculty today get pigeon-holed into writing papers on the same topics for two decades of their life,” he says. “I’ve been lucky to have worked in so many different areas—biofuels, wind energy, bioenergy integration with the power grid, biodiesel use in underground mines, economics of alternative vehicles, ammonia production from wind power and water—there has just been so much variety, and I am pleased with that. Variety has been the spice of life for me in terms of my research.”

Tiffany says his current role within the Department of Bioproducts and Biosystems Engineering is a “great fit” because it allows him to apply his production economics experience to pre-commercial concepts often being cultivated by those with scientific or engineering backgrounds. Being a part of the science and economics of new and changing technology is something he enjoys. “I appreciate the science aspect of it, probably more than most economists,” he says. “In a lot of cases, the people I work with are looking at patents or pushing a technology forward when I come into the picture. I enjoy the process of helping them evaluate the economics of their ideas,

and then finding out if their concept will ing aimed at energy independence and sustainmake the grade and be commercial someday.” able natural resource utilization.

Tiffany is not part of the U of M’s teachSharing Knowledge ing faculty, but rather its research faculty—an While Tiffany has, for over 25 years, important distinction—but opportunities been a university-employed production econ- to lecture and present, nonetheless, give him omist working outside of the biofuels sector joy. Many years ago, he had an opportunity to on the boundary of academia and industry, he speak to cadets at the U.S. Military Academy at appreciates the people he’s met and worked West Point and the U.S. Naval Academy at Anwith in ethanol. “I’ve really enjoyed visiting napolis. It was a genuine honor, he says. “They with the folks at the plants, going back to the were great listeners, and it was one of the hapdays when I would visit frequently with the people over at Chippewa Valley Ethanol Co. in Benson, Minnesota,” he says. “Kelly Davis, Andy Zurn, Bill Lee—they were all very patient helping me understand the ethanol process so I could do my work. Sometimes it was just a couple quick questions—maybe five minutes—but it meant a lot to me.”

Tiffany says the things that impress him most about the ethanol industry, and pull him to it often, are “the great people” and “the pace of innovation.” He says that nowhere is that more noticeable than at the annual International Fuel Ethanol Workshop & Expo.

“Just amazing, the number of new things you would see for the first time at that show— whether it was corn oil extraction or corn fiber-to-ethanol technology,” he says. “Things have happened very fast in ethanol, and it’s been exciting to watch.”

Like millions of Americans, Tiffany is currently working from home. “We all just need to stay safe right now, so we’re finding new ways to innovate, communicate and make things happen,” he says. “It can be a little isolating at times—not being able to bump into a colleague in the hallway and ask them a question—but that’s our reality for a while.”

University employees aren’t traveling during the pandemic, but Tiffany says he is thankful for the many rewarding opportunities he has had over the years to travel internationally, present at conferences, participate on boards and testify in front of government       . committees. For example, he has provided ex(8 8 8) 5 4 9 -1 8 6 9 pert testimony to Minnesota state legislative committees on first- and second-generation biofuels; and he served as a governor appointee on Minnesota's Nextgen Board, which HIBBING, MN | TRACY, MN | provided recommendations and grant fund-

piest days of my career. When I visited both academies, I went to their museums and saw lots of examples of how R&D investments and technology advances changed warfare.

We are witness to similar dramatic transformations in agriculture and the processing of agricultural products.”

Author: Tom Bryan Ethanol Producer Magazine 701.746.8385 tbryan@bbiinternational.com

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ETHANOLPRODUCER.COM | 27

Lab

Between

T H E LINES Control charts, a statistical tool used to monitor complex operations, can help ethanol plants visualize variability and fine-tune their operations.

By Matt Thompson

28 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Andrew Hawkins, director of laboratory In Check Kristi Plack, chief science officer at Bion Analytical, says conservices at Phibro Ethanol Performance Group, likens control charts to a two-lane highway. Drivers trol charts are “a great way to monitor each instrument over time on a winding country or mountain road, he says, know they’re in their lane because they haven’t passed over the double-yellow center line or the white line marking the side of the road.

“The control chart is almost exactly like that,” Hawkins says.

“It’s a statistical derivative or version of that. Where you’ve got the centerline, that’s the double-yellow line, and then you’ve got an upper control limit—which is three sigma—and you’ve got a lower control limit—which is minus three sigma.”

Control charts aren’t new. Hawkins says they were developed in the 1920s but came into wide use after World War II as manufacturing became more complex. They were particularly helpful during the space race, he adds. “NASA had tens of thousands of steps that had to be done, and they had to be done with great accuracy through a process,” he says. “That’s when statistical methods like the control chart where actually more widely adopted. They’re used to kind of visualize your data, which gives you kind of a quick overview of whether something is out of whack, in process or normal.”

While they’re not new, Hawkins says he isn’t sure how widely they’re used within the ethanol industry. But, he adds, there is interest among plant and lab managers about how the tools can help ethanol operations. Following a presentation he gave last fall, Hawkins says many of the questions were about control charts. “People were inquisitive about the tool and how it could help them,” he says.

Hawkins says control charts are useful for processes that are repeated. With 20 results in hand, control charts really become useful, he says. “They’re really a way to visualize process data that you’re doing repeatedly—things that you do every day or every so often,” he says. “It’s a way to visualize the results of a process or a machine and then be able to visually indicate when things are working as they should—or in control—or when you might have an excursion or a process upset, or an instrument upset.”

Knowing those upper and lower limits, and when plant machinery is operating within those limits, allows a plant to fine-tune its operations, Hawkins says. “By leveraging control charts, you can really find when things are in control, or hovering around that centerline where you would expect to be, and whether or not you have really wide limits, or really narrow limits,” he says. The result of that fine-tuning, he explains, is represented by data being closer to the center, or “hugging the centerline” in the road analogy.

to see if you’re seeing any trends.” Repeated deviations from an instrument’s true value would require a deeper look to see where the issue lies, she says.

Hawkins agrees. “[Control charts are] a way to generate trends, and statistically, it’s a way to view the trends of your equipment so you know whether or not your pH meter or your HPLC is functioning,” he says.

Control charts are also useful for visualizing natural variability in lab data, Hawkins says. “There could be a hundred different reasons why, when you run a sample on the HPLC today, it reads 1.05, and when you run it again tomorrow it reads 1.01,” he says. “But the question is are those two numbers within the expected natural variability or do they indicate that the machine wasn’t working yesterday or maybe it isn’t working today. And so, it kind of allows you to appreciate that and put those results in context.”

And while control charts are a statistical tool, which may seem daunting to some, Hawkins says they can be used without understanding the math behind the results. He explains that software programs and templates like those made by the American Society for Quality, and others, don’t require users to derive the equations to use the tool. “You don’t need to know the theory behind the power drill, you just need to know how to work the power drill,” Hawkins says, adding that he doesn’t have a background in statistics but makes regular use of control charts.

Keeping the charts easy to use is important, according to Plack.

“I would make sure that it’s something that’s not burdensome to someone, because we all know what happens there, right? You end up not using them,” she says.

Hawkins agrees. He says it’s possible to generate control charts by hand, but he doesn’t recommend that method. “You can actually learn how to generate them without deriving the equations,” he says, adding that a program called JMP is one option, as is Excel.

“It’s not hard to do in Excel, which everybody has on their computer,” Plack says. “It’s just making one, and then once you have one made, you can tweak it for the next one.”

Fine-Tuning

As plants make more incremental changes to efficiency and operations, control charts can help guide those changes. “I think more and more people are realizing—especially as margins be-

ETHANOLPRODUCER.COM | 29

Lab

come tighter—that you have to dial in your process; you have to have a very well-controlled, predictable process,” Hawkins says.

Plack agrees. “It’s showing variability over time, and you would think the more that you watch that, you could hone it in and so those upper and lower control limits could get tighter and tighter as you get better,” she says. “We calculate our 95 percent confidence interval and update our control limits annually so we can see, historically, how tight those control charts have gotten.

So you’re watching it so much more minutely because you’ve tightened how well you run your instruments and how well your technicians work,” Plack says.

Outside the Lab PHOTO: PHIBRO ETHANOL PERFORMANCE GROUP

TIGHT TECH: Control charts are effective tools for monitoring lab instruments for deviations that cause unwanted operational change and potentially rob ethanol plants of revenue.

PHOTOS: BION ANALYTICAL

30 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

Hawkins’ presentation at the 2020 International Fuel Ethanol Workshop &

Expo in September focused on control charts as a way to make sure lab equipment is functioning properly. But, he adds, control charts can be useful in other areas, too.

“Ethanol laboratories are not the only place where data is collected and analyzed to determine how the process is running,” he says. “That’s also something that’s done in the control room. … It complements doing trends in a DCS, because it’s a way to check your instruments. You can actually use it for the whole process. You could make control charts for the temperature on ferm 2 if you really wanted to.”

Hank Britton, director of optimization and advanced control for OpX Control Inc., agrees that control charts are valuable outside the lab. Briton, whose work with ethanol plants involves programming PID control loops and continuous process control,

says control charts can be used in process control for things like measuring fermenter temperatures. “You could plot temperature at a specific time for multiple batches,” he says. He adds that one of his customers did this as a way to see how fermenters were operating. They plotted fermenter temperatures at 12, 18 and 24 hours for different batches. “[They] looked at snapshots for multiple fermentation batches before I did work and then multiple fermentation batches after I did my work,” he says. “You could plot temperature at specific times for those batches to see an improvement.”

He also says plotting dryer temperature could be helpful. He said a customer recently complained his dryer was not controlling well. “when I looked at the average absolute error, the absolute value of the deviation from the setpoint as a function of time, it

went up from like a 0.22 to a 0.69,” Britton says. “That increase in an average absolute error indicated to me that something changed in the process.”

However, control charts remain most impactful in the lab. And Plack recommends plants use them. “I would highly recommend the use of control charts in the laboratory for all aspects; all tests that they run,” she says. “The big thing is you don’t know what you don’t know. So you really need to watch all of these things because a little bit of a change in an instrument could affect all kinds of operational changes, and then you find out it was because an instrument was not tight enough and that could mean a lot of money to the plant.”

Author: Matt Thompson Freelance Writer mthompson@bbiinternational.com

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ETHANOLPRODUCER.COM | 31

Regulation

SANITIZING STANDARDS: Ethanol producers have been following guidelines for hand sanitizer production, but those standards seem to conflict with previous studies and guidelines.

PHOTO: STOCK

Tenuous Toxicity Concerns FDA guidelines for acetaldehyde content in sanitizers may be questionable given the compound’s relative ubiquity.

By Jim Buchacker and Jim Forshaw Corn is undeniably a bounty from nature. It has not only fed us well, but can also help protect us from one of nature’s deadliest agents: viruses. Ethanol made from corn has become an important weapon against COVID-19 when used as a hand sanitizer. While demand for sanitizer-grade ethanol has soared, fuel-grade ethanol plants witnessed a steep reduction in demand that has now rebounded but is still well below last year’s levels. For much of the industry, the spring downturn resulted in dramatic output reductions, plant idlings and even complete shutdowns. And while relatively few ethanol plants laid off employees, should the situation have persisted longer, the potential for massive job loss was real.

The Food and Drug Administration is charged with drafting health and safety standards, which govern the use of ethanol in sani-

tizers. These standards specify allowable limits of certain impurities in ethanol such as methanol, acetone, acetaldehyde, total acetal compounds, etc.

In March of 2020, the FDA published guidance titled “Temporary Policy for Preparation of Certain Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19) Guidance for Industry.” Unlike some foreign ethanol producers, U.S. producers typically do not experience problems with methanol exceeding specified limits. Rather, the most frequent impurity that plagues U.S. producers is acetaldehyde. But the FDA’s limits on acetaldehyde in ethanol for hand sanitizer present a confusing contradiction with other studies, and even other substances ingested and applied to skin.

CONTRIBUTION: The claims and statements made in this article belong exclusively to the author(s) and do not necessarily reflect the views of Ethanol Producer Magazine or its advertisers. All questions pertaining to this article should be directed to the author(s).

32 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

CURIOUS LIMITS: The allowable content of acetaldehyde ingested in alcohol is actually higher than that allowed in ethanol for hand sanitizer.

PHOTO: STOCK

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Unfortunately, the FDA states in Attachment 1 of its guidance that it has “received data indicating that certain fuel ethanol products contain excessive levels of acetaldehyde, which appears to be a genotoxic carcinogen when in direct contact with tissues.” A corresponding footnote reads: “The toxicology for acetaldehyde differs when ingested as part of an alcoholic beverage (versus applied to skin as with hand sanitizer), in part due to the liver’s metabolism of acetaldehyde.”

The main problem with this statement is that FDA purports to be in possession of said data, but fails to cite that data in its footnote.

Searches of U.S. EPA, International Agency for Research on Cancer, Health Canada, National Toxicology Program, National Institute for Occupational Health, and the European Commission on Public Health’s sites produced no data or references to the “special” carcinogenicity/mutagenicity risk that acetaldehyde poses to human skin.

We are not saying that the data does not exist; however, we were not able to establish its existence.

And while this guidance document is classified as non-binding, it would certainly be nice to see the data that FDA is basing its suspicions on. It should also be noted that this non-binding guidance document could be taken to heart by American juries, who frequently have been found to take a dim view of defendants who do not follow “guidelines,” no matter how unproven they may be.

Parts per Million

Perplexing Footnote

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Dermal Toxicity

To muddy the waters even further, a 1995 study entitled “Could Bacterial Acetaldehyde Production Explain the Deleterious Effect of Alcohol on Skin Diseases” found that certain bacteria commonly found on human skin were capable of producing high levels of acetaldehyde when exposed to ambient levels of ethanol.

Although this study was done in-vitro, the data can be extrapolated ETHANOLPRODUCER.COM | 33

Regulation

The metabolic chain for ethanol is as follows: Ethanol Acetaldehyde Acetaldehyde Dehydrogenase (isoenzymes, polymorphisms) Acetal Co-enzyme A Intermediary Metabolism

to individuals who consume alcohol. These individuals, whose epithelium is bathed in sweat (which according to the authors would contain more than enough ethanol to fuel the production of acetaldehyde in these bacteria), would have a significant amount of acetaldehyde present on the surface of their skin for hours after imbibing alcoholic beverages. This information is not necessarily earth shattering news, but is certainly food for thought.

After an in-depth investigation of the facts surrounding the dermal toxicity and carcinogenicity of acetaldehyde, one glaring deficiency has been identified: Where

are studies that quantify how much acetaldehyde actually binds to skin after application of ethanol or acetaldehyde? It has been reported that hand sanitizer only remains on the skin for a matter of seconds before it evaporates. The boiling point (BP) of ethanol is 173 degrees Fahrenheit at 760 millimeters of mercury (mm/hg), which is the major portion of hand sanitizer. The BP of acetaldehyde is 70 degrees at 760 mm/hg.

With a human skin surface temperature that is 28.6 degrees higher than the BP of acetaldehyde, the question of how much of that volatile compound actually makes its way to epithelium seems to be the $100,000 ques-

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Acetate Co-enzyme A

tion. Unfortunately, it does not appear that anyone has done that study yet.

But it is not a stretch of the imagination to say that if hand sanitizer only remains on the skin for a matter of seconds (not minutes), and acetaldehyde is at least 2.5 times more volatile than ethanol, the amount of acetaldehyde making its way to bare epithelium is going to be miniscule. This, coupled with the extremely low amounts of acetaldehyde present in ethanol, paints a sobering (excuse the pun) picture of how much of this compound actually contacts and remains on the skin. In the absence of real data concerning the migration of acetaldehyde to skin via hand sanitizer formulations, it would be wise to ponder the fact that every toxicologist knows: The dose makes the poison.

In Our Food

The FDA is very likely to rescind, in the near future, the temporary rules that allow for higher levels of acetaldehyde. The result will be a reduction in the availability of ethanol used to make sanitizers to protect the public from COVID-19.

This would certainly make sense if there was a greater reduction in risk to the public than the benefit received, but that is not the case. Acetaldehyde, it turns out, is not only found naturally in many foods such as fruit, but the FDA allows its presence in cosmetics. Acetaldehyde is also present in alcoholic beverages (regulated by the Bureau of Alcohol, Tobacco, Firearms and Explosives, not FDA) and yet, the dermal limits for acetaldehyde exposure are much lower than limits for internal exposure.

To make things even more confusing, the first metabolite created by the body when processing alcohol is, in fact, acetaldehyde.

It seems that EPA said it best in the

following excerpt from Acetaldehyde Hazard Summary, January 2000, â&#x20AC;&#x153;Sources and Potential Exposure:â&#x20AC;? â&#x20AC;&#x153;Acetaldehyde is ubiquitous in the ambient environment. It is an intermediate product of higher plant respiration and formed as a product of incomplete wood combustion in fireplaces and woodstoves, coffee roasting, burning of tobacco, vehicle exhaust fumes, and coal refining and waste processing. Hence, many individuals are exposed to acetaldehyde by breathing ambient air. It should be noted that residential fireplaces and woodstoves are the two highest sources of emissions, followed by various industrial emissions. (1) In Los Angeles, California, levels of acetaldehyde up to 32 parts per billion (ppb) have been measured in the ambient environment. (1) Exposure

What Can We Do To Encourage a Change?

Visit our blog and see what you can do to help protect the public by going to the following address: https://cornvscovid@blogspot.com We urge you to post your thoughts, criticisms, and suggestions for the benefit of all who are concerned about this issue. may also occur in individuals occupationally exposed to acetaldehyde during its manufacture and use. (1,2) In addition, acetaldehyde is formed in the body from the breakdown of ethanol; this would be a source of acetaldehyde among those who consume alcoholic beverages.â&#x20AC;?

How logical is it to allow the FDA to regulate a compound that is not only ubiquitous, but is also permitted by other federal

agencies (ATF) to be consumed internally and in much greater quantities? Protecting ourselves from a virulent pandemic killer should always take precedence over protecting ourselves from a vague, unproven suspicion of dermal toxicity. The benefits clearly outweigh the risks at this moment in time.

Perhaps an exemption request for this acetaldehyde issue might be in order. Written exemptions provide a built-in legal insulation from torts and liabilities arising from ambiguities in vague regulatory rhetoric.

Co-Authors: Jim Buchacker Independent Consultant/Broker Buchacker Consulting 704.492.3267 buchacker1@gmail.com Jim Forshaw Independent Consultant 843.461.0152 jimforshaw@gmail.com

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After a successful career in the food industry, gaining experience in processing, production and distribution, Diane Young left the corporate world in 2009 to launch Foundation Analytical Laboratory Inc. in her hometown of Cherokee, Iowa—the heartland of ethanol country. The bold decision to start her own company was years in the making.

After receiving degrees in agricultural microbiology, animal/dairy science, and a minor in chemistry, Young worked in and managed in-house laboratories, which often utilized contract labs for outside testing. She found herself frustrated with the lack of customer service, as well as quality of data, from outside labs, and decided to do something about it.

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36 | ETHANOL PRODUCER MAGAZINE | OCTOBER 2020

relationships is our lifeblood,” says Young, owner and director of technical services at FAL. More than just a motto, she says the company fosters an environment in which the client truly views FAL as an extension of their own business.

While holding multiple analytical certifications in feed, pet food, environmental and food industries, FAL’s primary focus continues to be on biofuels. The personnel at FAL dedicate themselves to understanding and serving this crucial industry through higher education, an ever-growing ISO 17025:2017 accreditation, and investment in new technologies.

“The biofuel industry is complex and multifaceted,” Young says. “We recognize and embrace the fact that all plants and fleets do not have the same

needs and hot buttons. This business is built upon how I wanted to be treated when I was a customer of a contract lab. Through our love of the ethanol trade, we have developed valued relationships with over 50 percent of the industry and are proud to have them view us as their partners.”

Though FAL is a contract lab, Young says the staff has been on the “other side of the sample.” Members of the FAL team come from the corporate world as well as quality assurance/control teams and labs in production facilities. They embrace the necessity of having accurate, precise, and quality results in a timely manner, and understand that results of analysis are critical to the client’s decision-making process. The continually growing Analytical Team is a group of highly educated farm kids who have come back to their roots—all grew up within 45 miles of Cherokee—with a broader understanding of the industry and the desire to do what it takes to get the job done. The team is always excited to work with clients to develop the best possible plan to meet and exceed all expectations.

FAL is recognized as an industry leader not only in the chemical and microbiological analysis of coproducts, but as an expert in the analysis of mycotoxins by UPLCMSMS. Investments in high-

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Contact Foundation Analytical at info@foundationanalytical. com to explore how the company can assist you in developing the analysis program that best suits your needs.

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