On August 28, 2017, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), was quoted by the Bloomberg BNA Daily Environment Reportdiscussing Toxic Substance Control Act (TSCA) regulatory concerns for carbon fiber with a lignin.
Since the lignin-PAN carbon fiber under development does not yet involve the use of carbon nanofibers, Washington State University's Ahring said the product will not require clearance under [TSCA].
But some worry that the enthusiasm supporting the rapid commercialization of biobased chemicals has gotten out in front of potential regulatory questions.
“It is entirely possible a carbon fiber with a lignin may require notification under TSCA,” said Lynn Bergeson, a managing partner with the Washington, DC-based law firm Bergeson & Campbell, which advises chemical companies about regulatory compliance.
“There are currently three types of lignin listed on the TSCA Inventory,” Bergeson said. “The details of the material will dictate its TSCA status. Anything made from different forms of lignin are not fungible for regulatory purposes.”