Final Thoughts: Changing standards

Some edits to the program simply update language in the program manuals to make it clearer and more concise. Other changes are more substantive and include:

• A clarification that in referencing bags or weights, the program is not a weights and measures program. Individual states provide their own weights and measures oversight.
• Reductions in the sampling frequency for manufacturers who demonstrate and maintain compliance with the program and who commit to setting up more comprehensive on-site testing and monitoring protocols (from one sample per 1,000 tons to one per 5,000 tons for qualifying producers).
• Non-conformance level reduced from 95 per cent to 90 per cent. The previous level did not allow for virtually any variance from any test result at any time.
• The inclusion of rules of using the PFI Quality Mark (Annex A.1 in the program’s QA/QC Handbook).

Two other changes address the allowable diameter and bulk density. Once the program was implemented, it became apparent that the bulk density and diameter limits were not consistent with current industry norms. The revisions allow for a wider range for bulk density and for a slight increase of the diameter range.

The PFI Board and the American Lumber Standards Committee, the program’s oversight body, approved the changes as a result of several
years’ experience with PFI Standards Program implementation. These changes improve and strengthen the existing program and are a result of ongoing oversight and review of the program against industry best practices and data.

The PFI Standards Program remains a voluntary program, however fuel manufacturers on the fence about joining an industry standards program are advised to consider the impact of a new regulation recently promulgated by the U.S. Environmental Protection Agency. The EPA’s New Source Performance Standard for New Residential Wood Heaters (NSPS) requires that new residential pellet appliances utilize fuel submitted to an EPA-authorized fuel grading program, including the PFI Standards Program, CANplus and ENplus.

Pellet manufacturers who wish to provide products to consumers using these new appliances must meet the specifications of at least one of these programs, as well as what EPA is calling minimum requirements; some of which differ from the requirements of the three standards programs. The language of the NSPS rule is ambiguous in certain instances, and PFI has been seeking clarity from EPA on a number of items in the rule so that fuel manufacturers can have a clear understanding of how to meet the rule’s requirements.

Simultaneously, PFI has taken legal action against EPA to seek removal of the minimum requirements from the rule, as we believe they are onerous and unnecessary given EPA’s acceptance and inclusion of the three graded fuel programs that have been adopted by the industry.

These issues have not been resolved and do not delay the implementation of the rule. Despite the uncertainties, the rule is now in effect. Any consumer who purchases a new pellet appliance will need access to fuel produced by a manufacturer participating in an EPA-approved grading program—PFI Standards Program, CANplus or ENplus.

PFI will continue to provide updates on fuel standards and actions related to the NSPS Rule on our website.

We encourage you to learn more at www.pelletheat.org/pfi-standards.