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Technical Report United States Department of Agriculture Agricultural Marketing Service | National Organic Program Document Cover Sheet https://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned Document Type: ☐ National List Petition or Petition Update A petition is a request to amend the USDA National Organic Program’s National List of Allowed and Prohibited Substances (National List). Any person may submit a petition to have a substance evaluated by the National Organic Standards Board (7 CFR 205.607(a)). Guidelines for submitting a petition are available in the NOP Handbook as NOP 3011, National List Petition Guidelines. Petitions are posted for the public on the NOP website for Petitioned Substances. ☒ Technical Report A technical report is developed in response to a petition to amend the National List. Reports are also developed to assist in the review of substances that are already on the National List. Technical reports are completed by third-party contractors and are available to the public on the NOP website for Petitioned Substances. Contractor names and dates completed are available in the report. Lignins Crops 1 Identification of Petitioned Substance 2 3 Chemical Names: CAS Numbers: 4 Soda lignin; Sodium lignin; Sodium carbonate 8068-05-1 Alkali lignin, alkali soluble lignin, kraft 5 lignin; Kraft lignin; Lignin sulfonate lignin, soda lignin 6 9005-53-2 Lignin 7 Other Names: 8062-15-5 Lignin sulfonate 8 Alkali lignin; Alkaline lignin; Sulfur-free lignin; 8061-51-6 Sodium lignin sulfonate 9 Sulfur-free anionic sodium carbonate lignin 8061-54-9 Magnesium lignin sulfonate 10 8061-53-8 Ammonium lignin sulfonate 11 Trade Names: 8061-52-7 Calcium lignin sulfonate 12 Polybind 300 13 Other Codes: N/A 14 15 16 Summary of Petitioned Use 17 18 Sodium carbonate lignin has been petitioned for use in organic crop production through addition to the National 19 List at 205.601(j)(4) of “lignins” as a dust suppressant. Lignin sulfonate, another type of lignin, is currently listed 20 at 205.601(j)(4) for use as a chelating agent and dust suppressant. 21 22 23 Characterization of Petitioned Substance 24 25 This report focuses primarily on alkali lignins, including sodium carbonate lignin. Supplemental 26 information on other lignin derivatives from the kraft (sulfonated), sulfite, and organosolv processes is also 27 included but is not the primary focus of this report. Lignins that are chemically modified subsequent to or 28 beyond the pulping and its associated extraction steps are outside of the scope of this report. Table 1 29 provides a summary of the lignin derivatives covered in this report. 30 31 Table 1. Lignin derivatives addressed in this report Lignin type Soda lignin Organosolv lignin Kraft lignin Lignin sulfonate Alkali lignin; Alkali lignin; Lignin sulfonate; Alternate or Alkaline lignin; Alkaline lignin; Acetosolv lignin; Salts of additional Sodium lignin; Alkaline sulfite Organocell lignin lignosulfonic name(s) Sodium carbonate lignin; acid lignin Lignin sulfonate Source process Soda pulping Organosolv pulping Kraft pulping Sulfite pulping Extent of Sulfonated end sulfonation No No Yes product depends on process 32 33 Composition of the Substance: 34 Native lignins found in plant cell walls are amorphous, complex biopolymers (Peretti, Barton and Teixeira 35 Mendonca 2016). They are made up of phenylpropane units (C6–C3), known as monolignols. These monolignols 36 are p-coumaryl, coniferyl, and sinapyl alcohols. The main difference between these different phenylpropane ___________________________________ April 10, 2020 Technical Evaluation Report Page 1 of 19 Compiled by Nexight Group for the USDA National Organic Program Technical Evaluation Report Lignins Crops 37 derivatives is the number of methoxyl groups attached to the phenolic unit (Peretti, Barton and Teixeira 38 Mendonca 2016) (see Figure 1). There are other, less abundant lignin monomers of different phenylpropane units 39 and some carbohydrate moieties. In native lignin biosynthesis, all of these components combine in various ways 40 to form three-dimensional, cross-linked polymers that do not have one regular, ordered macromolecule. Thus, 41 lignins are physically and chemically heterogeneous, lacking a defined primary structure (Calvo-Flores, et al. 42 2015; Košíková and Gregorová 2005; Karak 2016; Du, et al. 2013; Peretti, Barton and Teixeira Mendonca 2016; 43 Garcia-Valls and Hatton 2003). 44 45 Figure 1. Building blocks of lignin. (Du, et al. 2013). The subindices H, G, and S indicate the alcohol 46 moiety of each monolignol: p-hydroxyphenyl, guaiacyl, and syringyl, respectively. 47 48 49 50 Industrial processes such as paper pulping and bioethanol production separate different components of 51 plant biomass and produce lignins as a byproduct, which may then be commercialized. These lignin 52 byproducts differ from native lignin in size and structure (Ahvazi and Ngo 2018) depending on the method 53 of extraction used (Agrawal, Kaushik and Biswas 2014). The chemical structure of these lignin polymers 54 includes significant quantities of three important functional groups: phenolic hydroxyl groups, aliphatic 55 hydroxyl groups, and carboxylic acid groups (Ahvazi and Ngo 2018). The types and quantities of these 56 functional groups in any lignin byproduct depend largely on the pulping process used to extract the 57 byproduct. These extracted lignins also differ in size of polymeric fragments depending on the methods 58 used to recover them from the pulping black liquor (i.e., the extraction liquid resulting from the pulping 59 process) (Ahvazi and Ngo 2018). 60 61 The petitioned material results from a paper pulping process that uses sodium carbonate and sodium 62 hydroxide to extract lignin. In contrast, lignin sulfonates are produced using a sulfite chemical pulping 63 process, where sulfur dioxide is used to extract lignin under pressure. A 2011 technical report on lignin 64 sulfonate includes detailed information on this particular type of lignin (USDA NOP 2011). The petitioner 65 of the present substance states that its composition is made up of lignin fragments, carbohydrates from the 66 breakdown of hemicellulose, and residual sodium carbonate. The lignin in this mixture is in varying states 67 of degradation and complexation with cellulose and hemicellulose (Legnochem 2019). Soda lignin has little 68 to no sulfur and a low quantity of hemicellulose but can contain high amounts of silicate and nitrogen 69 depending on the extraction procedure used (Espinoza-Acosta et. al. 2016). Lignins from soda ash pulping 70 have also been observed to have higher sodium ion content than other lignins (Vivekanandhan, Misra and 71 Mohanty 2015). One report on sulfur-free lignin suggested that these lignin derivatives contain more lignin 72 with macromolecular size (about 50–75 percent) and structure akin to native lignin than those in lignin 73 sulfonates (Liu, et al. 2020). The sulfur-free lignin used in the study was a byproduct of ethanol production 74 and contained 91.2 percent lignin, 0.12 percent residual cellulose/hemicellulose, and 0.67 percent ash (Liu, 75 et al. 2020). The sodium content of an alkali kraft lignin precipitated from the pulping black liquor using 76 carbon dioxide was reported to be 10 kg, or 1 percent, of sodium per ton of lignin (Stigsson and Lindstrom 77 2007). 78 79 Because the methods used to delignify plant matter influence the structure and size of the final lignin 80 byproduct, lignins are typically characterized by their extraction process (Serrano, et al. 2012). For example, April 10, 2020 Page 2 of 19 Technical Evaluation Report Lignins Crops 81 soda lignins are derived from cooking plant matter in sodium hydroxide. Organosolv lignins are obtained 82 from the use of organic solvents used in the organosolv process. Kraft lignins are derived from the kraft 83 process, and lignin sulfonates result principally from the sulfite pulping process. However, there are some 84 areas of discrepancy in how lignins are reported in the literature, with inconsistent use of terms. For 85 example, some reports refer to alkali or alkaline lignins as those resulting from the soda or soda ash process 86 and as being distinct from kraft lignins (Marin, et al. 2017; Calvo-Flores, et al. 2015). Conversely, the kraft 87 process uses the alkaline materials sodium hydroxide and sodium sulfide, and Colins (2019) lists alkali 88 pulping as also being known as kraft pulping. Ahvazi and Ngo (2018) refer to “alkaline kraft extraction.” 89 Another report refers to the kraft process as the “alkaline sulfite method” (Khristova, et al. 2002). In some 90 reports the term “alkali lignin” is not defined in terms of specific processing chemicals (Agrawal, Kaushik 91 and Biswas 2014). No studies reviewed for this report expressly referred to lignin sulfonates as alkali 92 lignins, though lignin sulfonates are also produced under strong alkali conditions. See Table 1 for alternate 93 names associated with the various pulping processes and Table 3 for process details. 94 95 Inconsistent terminology also appears in the literature when the sulfur content of lignin products is 96 discussed. Numerous reports identify “sulfur-free lignin,” which may be derived from wood prehydrolysis 97 (Košíková and Gregorová 2005), bioethanol production (Liu, et al. 2020), organosolv, soda (Collins 2019), or 98 soda ash processes. Calvo-Flores et al. (2015) identify sulfur-free lignin as that obtained from soda, 99 organosolv, and ionic liquid processes. Other lignins are acknowledged to contain sulfur, such as lignin 100 sulfonates. Espinoza-Acosta et al. (2016) group kraft lignins with lignin sulfonates as sulfur-containing. 101 However, Agrawal et al. (2014) note the availability of a commercial sulfur-free kraft lignin. 102 103 Ahvazi and Ngo (2018) measured the sulfur content of various lignins, which differs primarily based on 104 extraction method. They found that samples of soda lignin from wheat straw and organosolv lignin from 105 hardwood both had <0.50 percent sulfur, while another soda lignin from wheat straw had a sulfur content 106 of 1.19 percent.
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