Changes Coming to PFI Standards Program

Some upcoming changes are coming to the Pellet Fuels Institute Standards Program.
By Chris Wiberg | July 27, 2017

At the 2017 Pellet Fuels Institute annual conference on July 24 in Stowe, Vermont, on behalf of the PFI Standards Program, I provided an update to convey general logistical program information, as well as to notify everyone of some upcoming changes. For those not able to attend, I will provide a summary in this column.

For the past several months, PFI has been in discussion with the Northeastern States for Coordinated Air Use Management and other northeastern state regulatory representatives, as it pertains to the use of wood pellets within the region. It was brought to our attention that various Northeast states are planning to develop state-level requirements for the use of wood pellets. We were informed that while they felt most aligned with the PFI Standards Program for use in assuring quality requirements, there were some components that needed to be addressed before the program could be referenced for this purpose. 

While there were several components identified for discussion, the majority were determined acceptable as is, once we explained how the item was being addressed within the program. This included questions concerning inclusion of bark, use of additives, concerns about pellet size (length in particular), and handling of nonconforming product. There were two areas of concern in which it was agreed changes were necessary—the use of the term De Minimis, and provisions for the testing of metals. 

De Minimis is a term used by the PFI Standards Program to reference the presence of very small amounts of incidental chemical contamination, the primary example being the forestry practice of marking logs or lumber with paint. No doubt, some of these markings end up in the materials used to make wood pellets, but it is a very small amount, and incidental, so PFI has referred to such situations as De Minimis, and the program considers this to be acceptable. The regulatory community has found the adopted definition of De Minimis to be too broad, but rather than redefining the term, PFI will remove the term, and instead incorporate this language within the definition of chemically treated materials. PFI intends to remove all references to De Minimis.

In regard to metals, PFI has long held that the up-front screening of raw material suppliers, and the ongoing inspection of raw materials as they are delivered to the site, is the primary means by which inappropriate materials are excluded from the production of PFI premium, standard, or utility grade pellets. This philosophy still holds true, and is a central premise of the PFI Standards Program, however, it is clear that the regulatory community will not be comfortable without some amount of metals testing. Fortunately, and again through education of how the program works, regulators have been agreeable to a fairly small amount of testing for conforming producers, provided there are stricter provisions if auditors witness suspicious activities and/or if metals are found in the product. A summary of PFI’s new metals testing provisions are as follows:

• A metals test will be required as part of the initial qualification of each pellet production facility and continue, as a minimum, once annually.

• The minimum annual test is to be conducted at a time of the auditing agency’s choosing, however, the test is to be invoiced at the beginning of the year, and results are not to be disclosed until the end of the year, unless results are failing. 

• Additional audit samples may be tested for metals at the auditing agency’s discretion if they suspect the use of inappropriate materials.

• The metals of interest include arsenic, cadmium, chromium, copper, lead, mercury, nickel and zinc.

These are the same metals as are referenced in ISO 17225-2, which is the ISO standard referenced by ENplus, CANplus, and DINplus. Limits for each metal will be the same as are published in ISO 17225-2. The test method to be used is ISO 16968, which is the same as is referenced in ISO 17225-2.

• If at any time the test results of an audit sample exceed these limits, the affected materials will be further evaluated, and the producer will be required to have at least one audit sample tested for metals each month until there are three consecutive months where no exceedances of metals are found. 

• Affected product will be dispositioned based on the inspection and reinspection conformance criterial outlined in the PFI Standards Program.

The changes above have been vetted and approved by the PFI Standards Committee, the PFI Board of Directors, and by the regulatory officials engaged in discussion with PFI. The institute is currently working with the program accreditation body American Lumber Standard Committee to adopt these changes into the enforcement regulations. The formal revisions process will still take several months, but it is expected that final changes will be implemented by the end of the year.

Author: Chris Wiberg
Lab Director, Timber Products Inspection/Biomass Energy Lab
[email protected]