# • •••• • 

# •

• • • • 

# • • • 

# lmP.er • um renewab l e s

November 2, 2012

The Honorable Gina McCarthy 

# .... ... .

. 

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Assistant Administrator for Air and Radiation United States Environmental Protection Agency Ariel Rios Building 1ih and Pennsylvania Avenue

, NW Washington

, DC 20460

Dear Assistant Administrator McCarth y : Fuels,LLC Integrating biofuels



## We are writing concerning EPA's conditional approval of Palm Fatty Acid Distillates (PF ADs)

as a biogenic waste oil. It 

## is our position that this designation is inappropriate under the EPA ' s published rules for the Renewable Fuel Standard Program (RFS2)

, and we remain concerned that stakeholders were not provided an opportunity to comment on this significant determination. We appreciated the opportunity to discuss tl\is issue with EPA staff on October 9
, 2012

, at a meeting hosted by the Department of Agriculture

. At that time

, we agreed to provide the additional data contained in this letter

, which we hope will be useful to you and your staff.

The EPA has a pending final rule that would qualify esterification as an eligible production
process for processing eligible free fatty acids

, waste oils/fats/greases and other eligible feedstocks under the RFS2 program. It 

## was not public knowledge at the time this rule was published for comment in January 2012 that on September 16

, 2011

, EPA had provided a private
response letter ruling conditionally qualifying " Palm sludge oil

, Palm free fatty acids, and Palm oil recovered from bleaching earth (hereafter collectively call palm waste) as Non-cellulosic portions of separated food waste

... ," which are categorically considered a biogenic waste oil and therefore an eligible " waste " feedstock under the RFS2 (EPA PSO Letter
, 9/16/11 ). This EPA
response letter determination was not available in any form for public comment , nor would it have been clear even to industr y participants from the letter that PF ADs would be encompassed within the determination. Only recently was industry informed that through this response letter

, the EPA had " concluded that palm fatt y acid distillate (PF AD) qualifies under the existing RFS2
program as a waste product from the production of food ." That interpretation was provided via a

memo from EPA staff (Argyropoulo s 6 / 18/2012). In fact

, there has not been a mention of PF ADs in an y EPA published rulemaking that would have brought this possible classification to the attention of the renewable fuel s industry or the non-governmental organization communit y, and provided the possibility for public comment.

## As a result of the response letter ruling and the pending final rule on esterifcation

, the US biodiesel industry estimates that between 400 million and one billion gallons of PF AD-based biodiesel could be imported into US markets from palm sources in Malaysia and Indonesia

, the
two countries which currently account for almost 90 percent of the world's palm production

. We are basing these projected volumes on the current production of palm oil for 2011-12, which is 7

. 3 billion gallons for Indonesia and 5

. 2 billion gallons for Malaysia

, from which 5-11 percent is separated as fatty acid distillate depending on the processing equipment. Given this potential massive volume

, and the fact that PF AD is sourced from the same palm crops and industrial
process as palm oil itself

, there is a need for more detailed analysis and an opportunity for notice and public comment.

As stated above

, we believe the response letter determination that was interpreted to qualify PF ADs as a waste oil was in error , and appears to have been made on incomplete data about the

uses of PF ADs and its current value as a feedstock. To support that position, a discussion of established EPA waste oil definitions

, the basis of the response letter determination itself, and the
current uses and market position of PF ADs follows.

In the March 26

, 2010 rule implementing the RFS2 program , EPA stated that "EPA will consider these [waste] feedstocks to be ' wastes ' if they are used as feedstock to produce fuel, but would otherwise 

## normally be discarded or used for another secondary purpose because they are

no longer suitable for their original intended use. They may be unsuitable for their original intended use either because they are themselves waste from that original use (e.g. table scraps) or because of contamination

, spoila g e or other unintentional acts ." (Federal Register

, March 26

, 2010

, p. 14794). EPA elaborates further on the alternative secondary purpose concept , stating that " (f)or example

, contaminated v egetable oil might be burned in a boiler. " (Federal Register

, March 26

, 2010

, p. 14794).

A June 18

, 2012 EPA staff memo (Argyropoulos 6 / 18/2012) describes the basis upon which the EPA made its waste determination v ia the response letter: " While PF AD has some existing uses such as a supplemental energy source for boiler fuel

, we conclude that these other uses are generally considered low value uses and removal of PF ADs from such alternative uses will not substantially impact these other uses

.... Therefore we concluded that PF AD in the circumstances which were presented to the EPA is consistent with the description of a waste as included in the final RFS2 rulemaking

.... " The memo went on to say that " EPA reserves the right to reassess this determination at a later date should circumstances change. "

While this biogenic waste oil qualification is appropriate for many waste products

, we believe it is inappropriate for PF ADs. PF ADs are a co-product of palm oil production

, and PF ADs as a feedstock itself has a wide range of current commercial uses , and significant market value

. PF ADs are used in the soap industry

, for animal feed

, and as a raw material for oleo chemical industries. PF ADs also contain squalene

, vitamin E
, and phytosterols

, all of which have significant value for the nutraceutical and cosmetic industries. As early as 2009

, representatives from the industry were describing the breadth of PFADs ' market uses and potential. An 

## earl y 2010 article by Ab Gapor Md Top
, a senior research fellow with the Malaysian Palm Oil Board

, states : " The palm oil refining industry has a valuable byproduct known as palm fatty acid distillate (PF AD)

... PF AD has been traditionally and widely used as an ingredient in the animal food industry

.... PF AD is used for the manufacture of laundry and toilet soaps. Fatty acids o f

## PF ADs could also be esterified and us e d as a feedstock for oleo chemicals and biofuels." (Lipid Technology

, January 2010

, Vol. 22

, No

. 1).

A simple on-line search of industry promotional materials, presented by the marketers themselves

, describes the breadth of uses for which PFAD is currently sold. " We provide the best quality palm fatty acid distillate that is appreciated for its certain special properties and is in huge demand all across the world for the manufacture of soaps and shampoos ." (Pankti Associates

, Ahmedabad

, Gujarat). " Ambuja palm fatty acid distillate is demanded by small scale
soap industries for manufacture of laundry and toilet soaps. Ambuja PF AD is widely used for making oleo chemicals-fatty alcohols. " (Gujarat Ambuja Exports Ltd.) Among the many uses listed are: for animal feed as a source of calcium and fat

, for heavy duty lubricants; for liquid
soaps , for mould release agents and lubricants

, for cosmetics

, food emulsifiers

, foam stabilizers and water repellants.

The market for PF ADs has grown significantly in recent years , and so has its value in the marketplace. Through September

, the 2012 e x port price of Malaysian PFADs has averaged $844 per metric tonne compared to $1010 per metric tonne of palm oil. With PF ADs trading at nearly 85% of the price of palm oil throughout 20.12

, PF ADs can hardly be considered a lowvalue waste product. For your reference

, we have attached data published by the Malaysian Palm Board showing the average monthl y sales price in 2012 for palm oil and other palm products.

Despite the fact that PF ADs have traded for much of this year at only a slight discount to palm oil

, a 2012 average trading price of $844 per metric tonne , PF ADs nonetheless have a significant price advantage over the major e x isting eligible feedstocks such as soybean oil and rapeseed oil (canola)

, which have averaged $1171.17 and $1251.27 per metric tonne respectively during 2012
to date

. Accordingly

, PF ADs ha v e an even higher economic value as a feedstock for biodiesel production for the US market than the other already high value uses of PF ADs. As a result

, the bulk of the volume of produced PF ADs is likely to be utilized as a feedstock for biodiesel

, especially if PFADs qualify as biodiesel feedstock and are entitled to RINs. This added economic return in the palm oil process could be an additional incentive for more palm oil production

, with serious negative impacts from additional land use and greenhouse gas (GHG) emlSSlOnS.

Biodiesel produced from PF ADs does not yet qualify under the RFS2. However
, PF AD eligibility as a " waste " oil

, when coupled with the anticipated approval of esterification as an eligible production process under the RFS2

, will result in the production of between 400 million
to 1 billion gallons of eligible biodie s el

, much of it bound for US markets. Further

, the European Union is in the process of adopting n e w rules that will restrict the sale of palm-based biofuels to EU member nations

, making the US market even more attractive.

In the Notice of Data Availabilit y, is s ued on Januar y 27

, 2012

, the EPA determined that palm oil failed to qualify as a feedstock under the RFS2 because of its poor GHG emission avoidance ratings of 17% for biodiesel and 11% for renewable diesel. When a feedstock is declared a waste product

, published regulations indicate that EPA assumes it to have a qualifying GHG avoidance rating

, relying on EPA ' s GHG emissions avoidance analysis of yellow grease, which was done prior to the March 2010 rule. Howe v er , in calculating those GHG impact numbers for that rule

,



# 3

## EPA only used energy consumption numbers for commercial biodiesel plants in the US

, whereas PF ADs would be processed overseas at plants whose energy usage was not evaluated. Land use impacts and the transport of the finished product to the United States are also not considered with respect to PF ADs

, nor is the fact that palm oil failed to qualify under the RFS2 because of its
poor GHG avoidance numbers.

For the reasons we have stated above

, and based on our review of the published rules on the RFS2 program , we again respectfully submit that PF ADs do not qualify for designation as a

" waste " oil. PF ADs are neither a product that would " normally be discarded" 

## nor are they a product that is "used for another secondary purpose because they are no longer suitable for their original intended use. " 

## The June 2012 staff memo (Argyropoulos 6 / 18/2012) addressing PF ADs as a waste indicated that the " EPA reserves the right to reassess this determination at a later date should circumstances change

. " Having now had the opportunity to investigate the full market chain

, we firmly believe that the full breadth of market data presented above clearly demonstrates that the earlier assumptions made about the market uses and value of PF AD by EPA were underestimated and undervalued. Accordingly

, we believe the EPA has the right and obligation to reverse that determination

, and we strongly urge you to do so. Additionally

, until the EPA has reversed this " waste " designation

, we encourage the EPA not to qualify PF ADbased biodiesel, using the esterification process , as an eligible fuel for biodiesel under the RFS2.

We appreciate EPA ' s careful consideration ofthis issue. Please contact us or Bob Van Heuvelen of Van Heuvelen Strategies at 202-534-4920

, if we can provide any additional information or comment to assist the EPA in finding a solution to this issue.

Sincerely

,

John Plaza CEO

, Imperium Renewables Jonathan Phillips COO

, Renewable Biofuels Martin D. Beirne

, III CEO, Green Earth Fuels of Houston..**~· -··** **\** .. ) : ,:

.. ... ! .)'"_



## .. i**-- ~** **~** "t"**~-..~** 

### UNI T ED S TA TES E NVIRON ENTAL PROTECT I ON AG EN CY
WA S H ING T ON

, D

. C 2 046 0



## Sent Via Email

- September 16

, 2011

Dear Sirs : r r-! C:. •

. t·

... . -
.. •· •• t

· .- ·,\ [ ;

. \:



## This letter is in response to your June 13

, 2011 letter requesting the Environmental Protection Agency provide an interpretation of the application of our RFS2 regulations as they pertain to Palm Sludge Oil (PSO)

.

After review of the documents you provided and consultation with our technical team and our office of General Council, we have made the following detennination :

The EPA will regard Palm sludge oil recovered from palm oil mill effluent. Palm free fatty acids, and Palm oil recovered from bleaching earth (hereafter collectively called palm waste) as "Non-cellulosic portions of separated food waste'' so long as such wastes meet the following conditions:

1. The palm waste would be 

## permanently**discard~d** 

## ifnot used to 

## make biofuel, or if not discarded, they would be 

## used to 

## make some non-biofuel product whose revenue or cost savings represents a very small fraction of the revenue that would have been generated from the sale of the production of the primary product palm oil.

2

. The palm waste is from palm that was originally intended to be 

## used in food production or derived from post consumer food

Since palm wastes are categorized as " Non

- cellulosic portions of separated food waste" 

# they are also by definition be 

## included under the category of "Biogenic waste oils/fats/greases" and therefore are eligible for generating a 04 

## or OS 

## RIN under our current regulations.

:::.a.·

. ••• .:.

.. -:':.,..,...,

..**:~.** · -:

-- .. . .. . ...... .**..,~** ..**~** 9 " \ ' RP Cy(fed ,' R et :fCi a oll: · =· · ·:r•-· : : •

. . •..• ,.. ' .•U c**5~eiJ ~**  ...**~** · · · · l:O:

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.....

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... t. · , ·r·**: >.•~:** **·**

## However, please be reminded all applicable regulatory requirements must be 

## met as applied to your companies and facilities specific circumstances

, including registration, recordkeeping and reporting.

Sincerely,

# Paf~s!!::t-- Senior Policy Advisor Office of Transportation and Air Quality

### From: Paul Argyropoulos [mailto:Argyropoulos.Paul@epamail.epa.gov] 

## Sent: Monday, June 18, 2012 7:03 AM 

### To: Sandra Dunphy 

### Subject: Re: PSO

Hope this helps

.

Based on information received

, EPA can regard Palm Sludge Oil (PSO) recovered from palm oil mill effluent

, Palm free fatty acids

, and Palm oil recovered from bleaching earth (hereafter collectively called palm waste) as "Non-cellulosic portions of separated food waste" so long as such wastes meet the following conditions : 1

. The palm waste would be permanently discarded if not used to make biofuel

, or if not discarded

, they would be used to make some non

- biofuel product whose revenue or cost savings represents a very small fraction of the revenue that would have been generated from the sale of the production of the primary product palm oil. 2

. The palm waste is from palm that was originally intended to be used in food production or derived from post consumer food Since palm wastes are categorized as "Non

- cellulosic portions of separated food waste" they are also by definition included under the category of "Biogenic waste oils/fats/greases" and therefore

are eligible for generating a D4 or D5 RIN under our current regulations

, provided all conditions of the pathway requirements are met (i.e

. approved process)

. Please be reminded all applicable regulatory requirements must be met as applied to your companies and facilities specific circumstances

, including registration

, recordkeeping and reporting.

Applying our general interpretation of the RFS2 regulations -we concluded that palm fatty acid distillate (PFAD) qualifies under the existing RFS2 program as a waste product from the production of food

. Our determination is that PFAD is a by-product in the production of palm oil and do not represent a primary product and are not the purpose for growing palms or extracting and purifying palm oil. While PFAD has

some existing uses such as a supplemental energy source for boiler fuel

, we conclude that these other

uses are generally considered low value uses and removal of PFADs from such alternative uses will not substantially impact these other uses (e

. g

. , decreasing the amount of PFAD used as boiler fuel will not substantially impact the availability of feedstock used for boiler fuel)

. Therefore we concluded that PFAD in the circumstances which were presented to EPA

, is consistent with the description of a waste as included in the final RFS2 ru l emaking

, assuming the material also meets the definition of renewable biomass and any and all other applicable compliance requirements established by rule

. EPA reserves the right to reassess this determination at a later date should circumstances change

. Thanks

, Paul

Paul N

. Argyropoulos Senior Policy Advisor Office of Transportation & Air Quality US Environmental Protection Agency Office Phone : 1-202-564-1123 Mobile : 202

- 577-9354 Email : argyropoulos

. paul@epa

. gov Website : www

. epa

. gov/otagPageIofI,..MalaysianPalmOilBoard(MPOB)..::iI:1tMONTHLYPALMOILPRICES,2012ILOCALPRICESOFPALMOILPRODUCTS(RM!TONNE)---·ISepProductsJanFebMarAprMayJunJulOctFB1"OER(Ex·Milll34.4433.4235.7537.8334.2331.5q32.2-11-----1-·-3,291003,493.003,197.002,961503,033.002,811.002,729.00tPO(leiDeld)P.M'sla3,188.503,116.00--..PO(LeiDeld}M'sla3,182.503,108.503,278.003,480.503,188.502,955.503,031.502,805.502,719.50PK(Ex·Mfll)1,957.501,863.002,023.501,975.001,828.501,712.001,696.501.501.001,386.50----CPKO(leiOeld)4.151.003,936.504,161.0(4,292.503,716.003,435.003,351.002,956.502,800.00RBDPalmOil(leiDeldl3.314503,298.503,430.5(3,606.003,408.003,046.503,127.002,974.502,927.50_..PalmOlein(leiDeld)3,384.503,289.003.438.0(3,601.503,411.003,081.003,158.503,004.002,932.50ReDPalmStearin(leiDeldl3,012.002,938.503,073.003,448.503,265.002.913.002,746.002,725.50--PalmKernelExpeller(leiDeld)259.50278.00313.00404.50379.00366.50482.50500.00520.00EXPORTPRICESOFPALMOIL(USSFOB/TONNE)ProductsJanFebMarAprMayJunJulAugSepOctRBDPalmOil1,045.501,060.501,115.501.161.501,048.50957.50991.00937.50932.50RBDPalmOlein1,062.001,080.501,130.001,166.501,080.50966.50997.00953.50953.50RBDPalmStearin949.5(]959.001.011.501,135.5(]1,044.00928.00940.50872.50865.00PalmFattyAcidDistillate791.0(]786.50831.50987.001.015.50879.00837.00774.50788.50RBDPalmKernelOil1,428.001,358.001,481.501,511.001,388.001,165.501,171.501,014.50959.50RBDPalmKernelOlein1,223.5(]1.237.001,327.501,350.0(]NT1,026.501.100.00917.50910.00;taoPalmKernelStearin1,786.501,790.001,776.501,843.501,575.001.518.001,552.501,394.501,213.00PalmExpeller92.50100.50113.00144.0(]138.00124.50155.00172.50177.00-kr<>bh_oilsfats04http://econ.mpob.gO\.m)lupk/monthl)fbhmonthl)_12.htmNovDecJan·Sep201233.63-1-----f---3,037.503,049.001,677.00·-r--..-.•3,598.5C3,264.5C3,338.5(]--3,012.001---·-395.50NovDecJan·Sep20121,010.001.048.50953.00844.501.295.001,195.501,549.50134.50Jan-Dec201136.283,218.503,219.002,206.00--4,611.003,440.003,544.503,117.00384.50Jan-Dec20111,117.001,147.501,019.00813.501,627.501,498.001,939.00128.50y)10/9/2012Lipid Technology January 2010, Vol. 22

, No

. 1 11

DOI1 0

. 1 002/lite

. 200900070


# Feature


# Production and utilization of palm fatty acid distillate (PFAD)

Ab Gapor Md Top

Dr. Ab Gapor Md Top is senior research fellow at the Malaysian Palm Oil Board (MPOB), N o. 6
, Persiaran lnstitusi

, Bandar Baru Bangi

, 43000 Kajang, Selangor, Malaysia ; tel : 603-8769-4454 ; fax: 603-8926

- 2971; e-mai l : gapor@ mpob .g ov

. m y



### Summary

PFAD (palm fatty acid distillate) is a by-produ c t of phy s i ca l refining of cr ud e palm oil produ c t s and is co mposed of fr ee fatty a c ids (81. 7%), glycerides (14.4 %), squalene (0 .8%), vitamin E (0.5%), s terols (0.4%) and other substances (2.2%). PFAD is used in the anima/f ee d and laundry so ap industries as well as a raw mat e rial for th e o/eochemica/s industry. Vitamin E, squalene and phytostero/s are value-added products

. which co uld be extracted from PFAD and are of potential value for th e nutraceuti c a/ and cosmetic industries.



### Introduction

As the second largest producer of palm oil in the world, Malaysia contributed 41 % of the total palm oil produced in the world in 2008. The palm oil industry plays an important role in the Malaysian economy in terms of employment and foreign exchange earnings. In 2008, Malaysia produced 17

. 73 million

tonnes of crude palm oil and exported 2.34 million tonnes of crude palm oil and 13

. 08 million tonnes of processed palm oil products with a total export value ofUSD 14.04 billion (1)

. Most of th e crude palm oil produced in Malaysia is processed and refined before export and palm fatty acid distillate (PFAD) is a by

product generated during the physical refining proce ss.



### Production of PFAD

Palm oil is a commodity product used mainly in food applications as processed palm oil. Crude palm oil is refined as such or after fractionation into crude olein and crude stearin. The palm oil processing industry started in Malaysia in the ea rly 1970s and this well-developed process currently involves the processes of refining and fractionation. alone or in combination. Physical refining is more widely practiced than alkali refinin g. The processes involved in physical refining ar e phosphoric acid treatment , bleaching earth treatment, deacidification and d e odorization. The purpose of deacidificaion is to remove free fatty acids, and the purpose of deodorization is to remov e the odor of the oil. Both are carried out by steam distillation under high

vacuum. The distilled fatty acid is known as palm fatty acid distillate

, a highly odoriferous product which also contains some glycerol esters along with minor components of th e feedstocks. It is a light brown solid at room temperatur e m e lting to a brown liquid on heating

. Unlike th e s tatistics for c rud e palm oil and processed palm oil products (1), no official production data on PFAD seem to be available but its es timated availability is given in Table 1 based on the assumption of 4 % free acid in crude palm oil. PFAD is exported as such or as hydrogenat e d palm fatty acid distillate (HPFAD) ; the volume and value are given in Table 2. PO RAM 's specifications for PFAD are given in Ta ble 3. The average monthly export price ofPFAD in 2008 was 501 (range 302-



### © 2010 WILEY -VC H Verlag GmbH & Co. KGaA

, Weinheim Table 1

. Total production (tonnes) of crude palm oil (CPO) and PFAD in Malaysia

Year CPO Production Estimated PFAD Production

1980 2

, 573,173 102

, 927 1990 6
, 094,622 243,785 2000 10,842,095 433,684 2005 14

, 961

, 654 598

, 466 2006 15 ,88 0

, 786 635

, 231 2007 15

, 823,745 632

, 950 2008 17

, 734,441 709

, 378

Table 2

. Export volume and va l ue of palm fatty acid distillate (PFAD) and of hydrogenated palm fatty acid distillate (HPFAD)

Year PFAD HPFAD

Volume Value Value Volume Value (tonnes) (RM (USD (tonnes) (RM Million) Million) Million)

2001 426,538 278.4 81.6 1

, 837 1

. 9 2005 574,629 676 198

. 0 224 0

. 9 2006 591

, 893 748.6 219

. 3 932 2 2007 514,835 905 265

. 1 2,325 5

. 7 2008 652,419 1,280

. 70 375

. 2 1,967 4

. 8

Table 3. PORAM• Standard Specifications for PFAD

Free Fatty Acid (as palmitic) Moisture and impurities Saponifiable matter

• Palm Oil Refiners Association of Malaysia 70 % min 1%max 95%min Value (USD Million)

0.6 0

. 3 0.6 1.7 1

. 4

730) (FOB USD(fonne) (1). This compares with average values for crude palm oil at USD 812.36 (local delivered) and export prices ofRBD palm oil and RBD palm olein at 806 (range 478

- 1326) and 922 (range 517

- 1325) (FOB USD(fonne) respectively

. For 2009 Uanuary

- Nov e mber), the average of monthly export prices of PFAD was 429

. 50 (range 327

. 50

- 560.50) (FOB USD(fonne) (1) This
compares with average valu es for crude palm oil at USD 649

. 92 (local delivered) and export prices ofRBD palm oil and RBD palm olein at 662 (range 574 -8 19

. 50) and 690

. 50 (range 600 -8 31.50) (FOB USD(fonne) respectively

.12 January 2010, Vol. 22, No

. 1 Lipid Technology

Ta bl e 4. Physical and chemical properties of PFAD in Malaysia

Survey by Hamirin (1983) Survey by Bonnie & Mohtar (2009)

Titre ( 0 C) Iodine value (1,11 OOg) Free fatty acid(%) (as palmitic acid) Moisture content(%) Unsaponifiable matter(%} Saponification value (mg KOH/g sample) Mass per volume (kg 1

· ')

Fatty acid composition (wt%) 12 : 0 14 : 0 16 : 0 18:0 18 : 1 18:2 18 : 3

NA: not available

Tab l e 5. Typical composition (%wt} of PFAD

Free fatty acids Glycerides VitaminE Squalene Sterols Others



### Characteristics of PFAD 81.7 14.4 0

. 5 0.8 0.4 2.2 Range (n=162)

40

. 7-49

. 0 51.2-57.4 72

. 3-89.4 0

. 05-0

. 15

1.5-3

. 4 190.7-203

. 5 NA

0.1-0

. 3 0

. 9-1.5 42.9-51.5 4

. 1

- 4.9 32.8-39

. 8 8

. 6-11

. 3 0

. 2-0

. 6

Surveys on the characteristics and properties of palm fatty acid distillates (PFAD) from local refineries have been conducted by Hamirin (2) and by Bonnie & Mohtar (3) and the results are given in Table 4

. The ffa content complied with PORAM specifications with palmitic acid and oleic acid as the major fatty acids in PFAD

. A typical composition ofPFAD containing information on free fatty acids and on glyc e ride and non-glyceride components is given in Table 5.



### Utilization of PFAD in animal fee ds and l a undry

s oaps

PFAD has been traditionally and widely used as an ingredient in the animal feed industry (4) both as the free acid and as the calcium soap. The latter is composed of long-chain fatty acids which are reacted with calcium oxide or hydroxide to form a calcium salt or soap product, known in the industry as " CaPFAD ". This product is relatively inert in the fir s t digestive compart·
ment (rumen) of ruminants (e

. g

. cows) but is broken down to fatty acids in the abomasum, or true stomach

. The fatty acids are then absorbed from the small intestine and utilized by the cow for milk fat production or as an energy source. Th e advantages ofPFAD as a feed fat are , among others

, PFAD is probably one of the cheapest and most reliable sources of feed fat and is a source of essential fatty acid (EFA) as PFAD contain s about 10 % of linoleic acid (18 : 2)

. PFAD is also less pron e to rancidity than some other fats

, because of the low level of linolenic acid (18 : 3) and high level of vitamin E which acts as an antioxid a nt. On hydrog enation, PFAD is converted to hydrogenated PFAD (HPFAD) which is also used in the animal feed industry

. In certain coun-



### © 2010 WILEY-VCH Verlag GmbH & Co

. KGaA, Weinheim Mean

46

. 3 55.3 83.3 0.08 2

. 5 198 NA

0

. 2 1

. 2 47.1 4.5 36.6 9

. 6 0.47 Range (n=NA)

46.0-48

. 3 46.3-57

. 6

80-90 0.03-0

. 24 U-2

. 3 200.3-249.4 0

. 8640- 0

. 8880

NA NA 43

. 0-49

. 1 NA 36.3-37

. 2 NA NA Mean

46.7 54.8 NA 0.104 1.56 210.0 0

. 8725

tries, PFAD is used for the manufacture of laund!Y and toilet

soa s. Fatty acids of PFAD could also be esterified and the roduct used as a feedstock for oleochemicals industry and biofuel.



### Utilisation of PFAD as source of vitamin E , squalene and phytosterols

There is an increasing interest in nutraceuticals and in the func

tional food industry, which promotes food-derived phytochem

icals as their active ingredients

. There is a growing body of evidence that vitamin E (tocopherols and tocotrienols) are important for their antioxidant activities in foods and biological systems. Palm vitamin E is a tocotrienol-rich product

, where the ratio of tocotrienols to tocopherols is about seven to three

. In the last decade

, tocotrienols have been shown to be superior to tocopherol in their beneficial effects in cell and animal studies devot e d to hypocholesterolemic, anti-cancer (e

. g. breast, pros· tate) and neuron protection activities

.

The major components of palm phytosterols are beta-sitosterol

, campesterol and stigmasterol. Several studies have demonstrated that consumption of phytosterols reduces cholesterol absorption and lowers both total serum and LDL cholesterol levels in animals and humans

. The use of phytosterol and it s hydrogenated forms (phytostanols) as such or as esters in functional foods as a cholesterol-lowering agent is now well-accepted by consumers (5). One spread in the market uses stanol ester , a hydrogenated sterol sourced from wood pulp, as its cholesterollowering agent

. Phytosterols have also been shown to have anti·

cancer properties

.

The major sources of squalene are from shark liver oil and from the olive oil industry

. Squalene is a natural emollient and finds wide utilizations in the cosmetic industry as squalene or as fully hydrogenated squalane

. Other areas of squalene utilizations are in health food and pharmaceutical industries

. However, because of concern on sustainability and availability o

s ualene from the traditional sources a new source such as PFAD is desirable.

It is desirable to isolate useful phytochemicals from PFAD and
to deliver them in concentrated and pure forms to the relevant industries for the benefit of consumers. Extraction of the high

www

. lipid-technology

. comLipid Technology

value compounds, vitamin E
, squalene and hytosterols from PFAD would represent a value-addition strategy to PFAD in itself and ultimately to the palm oil industry

. Based on the estimated production of PFAD in Table 1 and the representative contents of vitamin E, squalene and phytostero l s as in Table 5

, potential availability of these compounds in 2008 were 3547, 5675 and
2838 tonnes respectively. MPOB has attempted the isolation and purification of the useful bioactive materials from PFAD for sometime and is currently at different stages of progress for the three groups of compounds. I n the case ofvitamin E, significant
progress was made at the pilot p l ant level (6)

. Subsequently

, the technology was taken to commercial scale production, and products containing palm vitamin E have been available in the market for more than five years

.



### Conclusions

Th e palm oil refining industry has a valuable by-product known

as palm fatty acid distillate PFAD

. I t is composed mainly of free fatty acids with smaller amounts of glycerol esters and nonglyceride components (vitamin E. squalene and phytosterols)

. By virtue of its high saponifiab l e fraction (free fatty acids and gly

cerides)

, PFAD has been traditionally used as a competitive raw material for the manufacture of animals feeds and laundry
soaps

. But PFAD is relatively rich in useful phytochemicals i.e

., vitamin E. squalene and phytosterols and the recovery of these



### © 2 0 10 W IL E Y

- V C H V er l ag G mbH & Co. K Ga A

, W einheim J anuary 201 0

, V ol. 22, No

. 1 13

compounds have been attempted. Vitamin E from PFAD (known

as palm vitamin E) is rich in tocotrienols and has been on the market for a few years , whereas squa l ene and phytosterols are still at the deve l opment stage.



### References

1. Malaysian Oil Palm Statistics 2008, Malaysian Palm Oil

Board

, February 2009, ISSN 1511-743X; MPOB website (econ

. mpob.gov

. my)

2

. Hamirin K. (1983) Survey on characteristics of Malaysian palm fatty acid distillate (pfad) and palm acid oil (soapstock)

. PORIM Report PO (59) 83 General. Palm Oil Research Institute of Malaysia

. 3. Bonnie T

. Y

. and Mohtar Y

. (2009) Characteristics and properties of fatty acid**distill~te** from palm oil. PIPOC 2009 Int

. Palm Oil Congress

- Ol e o&Spec. Chern

. Conf, 309-312.

4

. Thiagarajan T

. (1990) PFAD for feed

, Palm Oil Development, 13, 4

- 7

. 5

. Plat 

## J

. et a!. (2000) Therape u tic potential of plant sterols and stanols, Curr

. Opin

. Lipidol., 11 : 571-576.

6. Sundram K. and Ab Gapor Md Top (1992) Vitamin E from palm oil : Its extraction and n u tritional properties, Lipid Technology

, 4,137-141.

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. l i p i d

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# Gujarat Ambuja Exports Ltd.

Ambuja Palm Fatty Acid Distillate(PFAD) !Q"J

··········· · ····· · ········· · ·· · ······ · ···· ·· · · · · · · · · ·························· · ······················ · ················ .................................... . (\\,.1



### > INTRODUCTION
I Al'l"buja palm fatty acid distillate is obtained from the crude palm oil by physical refining with live steam at

very high temperature and at reduced pressure.
II The distillate is a chemical unit occurring naturally either single or col'l"bined and consisting strongly linked

carbon and hydrogen atoms in a chain like structure. At the end of the chain is a reactive acid group composed of carbon, hydrogen and oxygen. This acid group permits reaction with alkali, alcohol etc. and is known as reactive group

.

1 Al'l"buja palm fatty acid distillate is demanded by small-scale soap industries for manufacture of laundry and

toilet soaps.

II Al'l"buja PFAD is widely used for making oleo chemicalsa Fatty Alcohols Produced by hydrogenation of fatty acids.

b Metallic soaps
Calcium Soap

Lithium Soap

Potassium Soap

Other Metallic Soap Fatty Acid Esters Fatty Acid Ethoxy lates

Fatty Arrines By treating with metallic hydroxides:-

For animal feed as a source of calcium and fat

For heavy duty lubricants.

For liquid soaps.
For mould release agents and lubricants

. For mould release agents and lubricants. by esterification of fatty acids for use in cosmetics. by esterification of fatty acids for wide usage of food emulsifiers.
by treatment with arrines for use as foam stabilizers and water repella nts.

Ambuja PFAD Typical Specification
Parameters Specifications

40 o C Min. Trt:re

FFA % as Palmitic Acid
MIV


## s.v

USM 85 Min.
1% Max.
190-205
1.5-3.4%

Custorrized specification can also be achieved

Packi n g Available- Loose in the form of serri solid and can be transported through bulk road tankers.

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