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PFI Standards Program News

At the final meeting of the 2014-2015 PFI Board of Directors, the PFI Board approved a series of changes to the PFI Standards Program. Some of the changes to the program simply update language in the program manuals to make it clearer and more concise. More substantive changes include:

  • A clarification that the program is not a weights and measures program
  • Reduced sampling frequency for manufacturers who demonstrate and maintain compliance with the program and who commit to setting up more rigid on-site testing and monitoring protocols
  • Conformance criteria reduced from 95% to 90%
  • The inclusion of Annex A.1 in the QA/QC handbook outlining the rules of using the PFI Quality Mark
  • A modified range for acceptable bulk density to 40-48 lbs. per cubic foot 

The Co-Chairs of PFI’s Standards Committee, Chris Wiberg of Timber Products Inspection and Bob Sourek of Bear Mountain Forest Products, talked to us about the changes, what they mean for current and potential enrollees to the program, and how the updated program compares to other graded fuel programs. 

Why were these changes necessary? 
When PFI started this program in 2010, it was brand new – and we’ve learned a lot since then. We now have a better idea what works and what doesn’t. As we implemented the program, we started keeping a list of things we needed to do to improve the program. I’d say that 80% of these changes included clarifications, addressing typos, and various changes to the language in the program documents to make them more easily understood. The rest of the revisions are more substantive changes, the biggest of which is the reduction of sampling frequency. In several instances it was clear that sampling at a frequency of 1 sample per 1,000 tons of production was more than was necessary. Producers demonstrating a high level of compliance tend to have robust on-site QA/QC practices and do not need to be tested as frequently. 

How will these changes affect current program enrollees?
Most significantly, producers that qualify for the reduced sampling frequency will see a considerable reduction in the program costs due to having to test fewer samples. This can be up to an 80% reduction in testing costs.  

Another component that is different for producers is how bag weight is being monitored. The original program makes references only to 40-lb. bags, so there was confusion as to whether the program enforced bag weights as being strictly over 40 pounds. Many states have their own rules for weights and measures allowing a certain level of variance. It was decided that the different rules from state to state were too difficult for PFI to enforce so the program was modified to remove references to 40 lb. bags and to include language clarifying that the PFI Standards Program does not enforce weights and measures.

Two other changes have to do with the allowable diameter and bulk density. Once the program was implemented it became apparent that the bulk density and diameter limits were set too tight. The revisions allow for a larger range for bulk density and incorporate Note 6 under table 1 to allow for an increase of the diameter range upon EPA review. This will allow producers with slightly higher bulk density and/or diameter to comply with the allowed grade criteria.

Finally, “conformance criteria” has been modified from 95% to 90%. The previous 5% conformance criteria allowed for only one non-compliant test sample for every 20 samples tested. With 10 parameters tested per sample this is essentially one failed parameter per 200 parameters tested, which was too strict. Dropping this to 90% allows for a more reasonable level of compliance. This is also applied with what we call the 10%-2% rule. If material is over a specified limit by not more than 10% (2% for durability) then it can still be sold as long as it is not more than 10% of your production (was formerly 5% of your production).

How will the changes affect potential program members?
We hope the changes will encourage more producers to enroll. The option for a reduced sampling frequency will do a lot to reduce program costs and will hopefully make participation more affordable. In addition, with the widening of some of the grade criteria some producers that did not qualify previously will now be able to participate without making modifications to the production process.

How does the PFI Standards Program compare to other graded fuel programs?
There are a lot of differences between the PFI Standards Program and the other graded fuel programs that were approved by EPA’s New Source Performance Standards (NSPS), ENplus and CANplus. The earlier versions of all three programs were more similar but now they have matured in different directions. The PFI program has much more robust third party monitoring and oversight, which gives a greater level of assurance that the material in the bag complies with the standard. PFI’s changes hone the third party verification process and compliance requirements. ENplus and CANplus are very similar to the PFI Standards Program in many ways, but only require a single audit per year and one audit sample to verify compliance. ENplus and CANplus are also focused on the entire supply chain to include pellet traders and the entire distribution network, whereas the PFI Standards Program is focused on production.

Do you expect to see growth of the PFI Standards Program following the release by the EPA of the final NSPS rule? 
With the release of the EPA’s NSPS Rule earlier this year, appliances manufactured after May 15, 2015 will be required to burn fuel that has been produced under a licensing agreement with one of the approved graded fuel programs, one of which is the PFI Standards Program. This will create a market for compliant fuel and no doubt producers will want to sell product to this sector of the industry. As such we do anticipate additional producers will want to qualify their product under the PFI Standards Program. We have already seen an increase in calls and activity to this effect.

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