Densified Fuel Inspection Program Qualification Process and Inspection Procedures Northeastern Lumber Manufacturers Association (NELMA) P.O. Box 87A 272 Tuttle Road Cumberland, ME 04021 (p) 207.929.6901 (f) 207.829-4293 (e) info@nelma.org www.nelma.org
About the PFI Standard and ALSC In 2005, The Pellet Fuel Institute (PFI) began the process of redeveloping its pellet standards in advance of the Environmental Protection Agency s (EPA) update to its New Source Performance Standards (NSPS) for Residential Wood Heaters. Wood fuel combustion can be an important contributor to fine particulate matter in colder climate states, and science has established contributory associations between fine particles and the aggravation of respiratory conditions such as asthma, cardiac conditions such as heart disease, and premature mortality. ALSC Review 8 This update to the 1988 version will reflect significant Inspection Discrepancies & NELMA Disciplinary Actions 8 advancements in wood heater technologies and design, broaden the range of residential wood heating appliances covered by the regulation, and improve and streamline implementation procedures. The EPA has encouraged pellet producers and appliance manufacturers to develop pellet grades based upon characteristics such as durability, ash content, and limits on the use of construction debris and chemicals. While EPA is mandating the regulation of pellet fuel through its NSPS, it has voiced its support of the revised PFI Standards Program for inclusion in the NSPS, which requires not just 3rd party analyses but also 3rd party inspections, approval of Quality Control plans, sampling, auditing, corrective actions, verification of conformity, and reporting of results. PFI has contracted with the American Lumber Standard Committee (ALSC) to oversee the 3rd party inspection portion of the Standard based upon ALSC s significant experience in product standard implementation and accreditation of agencies to perform verification and quality inspections at manufacturing facilities. Pellets that are tested through the PFI Standards Program and inspected by an accredited agency under ALSC overview are assured to be qualified to a specified grade and can be properly matched to the appliances that are permitted to burn them. The revised PFI Standards Program addresses the needs of consumers, fuel and appliance manufacturers and the EPA. About NELMA Table of Contents Facility Qualification 3 Quality Program Management Plan 3 Quality Management Personnel Requirements 4 Raw Material Qualifications & Contaminant Check 4 The Northeastern Lumber Manufacturers Association, otherwise known as NELMA, was created in 1933 as a non-profit trade organization to oversee a number of federal standards developed to stimulate economic recovery of the forest products industry located in the Northeastern states. For more than 75 years, the Association has continued to provide a leadership role in the development and implementation of industry standards critical to quality control and consumer acceptance. The establishment of lumber grading standards in conjunction with an education, and inspection program for the industry has been a primary function of NELMA for decades. The Association is accredited by the American Lumber Standard Committee (ALSC) as a lumber rules writing agency and as an agency to provide inspection services for lumber, timbers, and export wood packaging materials. NELMA has certified facilities located throughout the Northeast, Mid-Atlantic, Great Lakes, and Midwest regions of the U.S. NELMA s Densified Fuel Inspection Program is the most recent addition to the Association s inspection programs. The information published with this booklet is based upon the provisions implemented by ALSC and the Pellet Fuel Institute (PFI) that will enable manufacturers to produce and label pellets that meet the specifications of the Industry Standard. Page PFI Fuel Grade Requirements 4-5 In-House Product Testing Requirements 5 Product Labeling & Use of NELMA s Quality Marks 6 Disposition of Non-Conforming Pallets 7 Facility Production Reports & Customer Feedback 7 NELMA Inspection Procedures 7-8 Retention of Records 8 NELMA Densified Fuel Inspection Program Page 2
Facility Qualification Process NELMA s process of qualifying a facility for PFI Standard compliance will commence upon receipt of a completed application (contact the NELMA office or print an application online at www.nelma.org). An appointment will then be scheduled for a NELMA Inspector to visit the facility and meet with management and all designated personnel that will be involved with the quality control program. The Inspector will discuss the compliance process and assess the operation to determine if the facility can fully meet the requirements set forth by the PFI and ALSC requirements for qualification. When all conditions for compliance are met, the Inspector will register the facility for qualification, obtain a signed agreement for services, and train designated facility personnel on all required documentation procedures. Quality Program Management Plan The pellet manufacturing facility must include a detailed Quality Management Plan with its application to NELMA. This plan shall provide details of the facility s process to ensure that the final product will meet the specifications of the intended grade(s) of pellets, as outlined in the Pellet Fuel Institute (PFI) Standard Specification for Residential/Commercial Densified Fuel, the PFI Residential/Commercial Densified Fuel QA/QC Handbook, the ALSC Residential/Commercial Densified Fuel Enforcement Regulation, and other appropriate documents. This includes, but not limited to: Defining responsibility and authority throughout the organization, Training of designated personnel assigned to quality management, both ongoing and back-up personnel, Controlling the quality of raw materials, Quality control and quality assurance processes, which include in-house laboratory testing, proper packaging, labeling, storage, handling, transport, and delivery, Immediate corrective actions when compliance deficiencies are identified, Disposition plans for non-conforming raw materials and finished products. Management of changes to the program (production of new grades, changes in production levels, etc.) NELMA will provide the following official forms to document the record keeping components of the facility s Quality Management Plan: Quality Manager (QM) certification and training record, Raw material purchases record, Periodic Inspection of Facility record, Daily pellet testing log, Corrective action request (CAR) report, Monthly production record by pellet grade, and Product complaint record. An official NELMA recordkeeping binder will be provided to the facility upon acceptance of the facility s application for PFI and ALSC requirements. The facility s approved Quality Management Plan and all documents associated with the in-house quality control program that will be utilized during each NELMA inspection for verification and compliance shall be maintained within this binder. NELMA Densified Fuel Inspection Program Page 3
Quality Management Personnel Requirements Facility management shall appoint adequately trained employees as Quality Managers that have the authority and knowledge to oversee and conduct the in-house quality control program and correct any condition within the facility process that may cause the output of non-compliant pellets. The Quality Manager (QM) shall have the authority to remove the quality mark from material that does not meet the PFI or ALSC requirements and stop shipments of noncompliant quality marked product. A minimum of two QMs is recommended for each work shift, one primary and one as back-up. The names of all personnel designated as a Quality Manager for the facility, along with their date of certification and appointment, shall be recorded on the NELMA Quality Manager Certification and Training Record form and maintained within the NELMA Binder at all times. Re-certification of each Quality Manager must take place annually and cover all applicable Standards and specifications. The date of QM re-certification and name of trainer will also be recorded on the NELMA form. Raw Material Qualifications Cellulosic fiber in the form of sawdust, grindings, chips, or logs may be used as feedstock to produce pellets. These materials MUST be free of any bonding agent, preservative, surface coating or other finish, or any other chemical additive. The Quality Manager will record detailed information for each shipment of raw material received at the facility for the production of pellets on NELMA s Raw Material Purchases Record, to include the suppliers name, address, and phone contact, species and type of raw material, and quantity received. A copy of the bill of lading or invoice must accompany the Purchases Record and placed in the NELMA Binder for review purposes. Accurate supplier information is critical should questions arise that may require verification of the raw material content. At this time, construction waste debris and post-consumer recycled wood, such as recycled pallets, may NOT be used as a raw material to produce PFIgrade densified fuel. Contaminant Check Both the feedstock and grounds and equipment must be free of contaminants such as soil, stones, non-wood debris, and moisture intrusion to ensure final product quality. A periodic check by the QM of raw materials when received, handling areas, silos, conveying equipment, storage containers, and transport equipment (front-end loaders, trucks, etc.) is required. Each contaminant check will be recorded on the NELMA Periodic Inspection of Facility Form and maintained within the NELMA Binder of information. PFI Fuel Grade Requirements The PFI Standard Specification for Residential/Commercial Densified Fuel designates three (3) types of Grades for Pellets: PFI Premium PFI Standard PFI Utility NELMA Densified Fuel Inspection Program Page 4
Each grade is based upon specific fuel property requirements, as noted in the Table below: Residential/Commercial Densified Fuel Standards Fuel Property PFI Premium PFI Standard PFI Utility Bulk Density (lbs./cu.ft.) 40.0 46.0 38.0 46.0 38.0 46.0 Diameter (in.) 0.230 0.285 0.230 0.285 0.230 0.285 Diameter (mm) 5.84 7.25 5.84 7.25 5.84 7.25 Pellet Durability Index (%) 96.5 95.0 95.0 Fines (%) 0.50 1.0 1.0 Inorganic Ash (%) 1.0 2.0 6.0 Length (% > 1.5 in.) 1.0 1.0 1.0 Moisture (%) 8.0 10.0 10.0 Chloride (ppm) 300 300 300 In-House Product Testing Requirements The in-house testing of specific pellet properties on a regular basis at the pellet manufacturing facility is critical to the quality control process. Deviations from the Standard during production can be readily identified and corrected through diligent product testing before large quantities of non-compliant pellets are produced. NELMA requires the in-house, on-site testing of the following six (6) pellet properties: Bulk Density Diameter Durability Fines Length Moisture Each test shall be conducted in accordance with the methods provided in the PFI Standard Specifications for Residential/Commercial Densified Fuel. All on-site equipment shall be in accordance with this PFI Standard and include calibration of the equipment prior to each test. NELMA requires that in-house quality testing of these 6 properties be conducted at a minimum of twice per work shift, as follows: 1. Within the first hour of work shift start-up, and 2. Within THREE hours prior to end of shift. Each test result will be recorded on the NELMA Daily Pellet Testing Report. Additional testing is encouraged and may be conducted during the work shift and recorded on the report. Should any one of the 6 properties tested be in non-compliance with the applicable PFI Grade Standard, the Quality Manager shall immediately initiate the Corrective Action Request (CAR) Report. The entire pellet production since the most recent test showing product in compliance with the Standard shall be segregated to a designated non-compliant product area and the quantity recorded on the CAR Report. Once the suspected process issue creating the noncompliant pellet production is verified, re-testing of the resulting production shall be completed until all properties are in compliance with the Standard. All pellets produced during this corrective process shall be added to the previously segregated production for NELMA-approved disposition. NELMA Densified Fuel Inspection Program Page 5
Product Labeling & Use of NELMA s Quality Marks NELMA shall license the use and application of its quality mark to densified fuel manufacturers that subscribe to its inspection program. The application of the mark constitutes verification that the facility s products meet the PFI Standard Specification for Residential/Commercial Densified Fuel and have been produced under NELMA s quality control program. Application of the mark is subject to continued conformance to the PFI Standard and the provisions required by NELMA. The following minimum information is required to be on a quality mark, whether stamped or labeled: Registration Number (Facility number) Densified fuel grade Grade Requirements as outlined in Section 8 of the PFI Standard Manufacturer s Guaranteed Analysis: o Type of Material (hardwood, softwood, mixed hardwood and softwood, agri grasses, nutshells, etc.) o Additives (type of additive must be listed and may not exceed 2% by weight) o Minimum Higher Heating Value (as received and reflect a minimum BTU value as a result of Lab testing) o Additional Guarantees (must be verifiable through audited samples by an accredited laboratory) The symbol or logo of PFI and the accrediting agency. Provided below are facsimiles of Quality Marks available for use by certified NELMA facilities: The facility management shall alert the NELMA Office prior to ordering any pre-printed labels and provide a facsimile of the quality mark for final approval. Contact information of the provider of the pre-printed packaging and total quantity to be ordered shall be conveyed to NELMA as part of the approval process and for recordkeeping purposes. The quality marks issued by NELMA to a specific location are to be used ONLY at that location. Separate facilities operated by one company must have their own quality mark; each assigned a unique registration number. For bulk shipments of densified fuel that meet the PFI Standard, a facsimile of the approved facility s quality mark shall be included with commercial documents. Quality-marked densified fuel must not be allowed to co-mingle with non-quality marked product. In addition, qualitymarked fuel of one grade that is co-mingled with another grade must be quality-marked to the lowest grade on the final packaging label or document. NELMA Densified Fuel Inspection Program Page 6
Disposition of Non-Conforming Pellets Pellet production found non-conforming to the grade of pellet as produced and labeled shall have its quality mark obliterated from the packaging. The relabeling/repackaging of the product to the next lower grade is permissible, ONLY if the pellets meet the Standard requirements for that grade. Other product disposition options approved by the Agency may be included within the facility s Quality Management Plan. Facility Production Reports & Customer Feedback The Quality Manager will record the total production of densified fuel each day by shift on the NELMA Daily Production Record by Pellet Grade report, maintained within the NELMA binder of information, and include the type of raw material used in production, type of additive used (if any), and total tons produced. As a tool to assist NELMA and the facility s management in determining the success of its quality management program, a Product Complaint Record shall be maintained. This record will include a brief description of each complaint received by the facility from its customers, along with a summary of the final resolution to correct the issue. NELMA Inspection Procedures As required by the American Lumber Standard Committee (ALSC), NELMA will conduct a minimum of twelve (12) inspections per year, at approximately monthly intervals, at each densified fuel facility. This interval may increase should prescribed corrective procedures require verification with additional on-site inspections. If a manufacturer is inactive for more than 2 months in any 12 month period, an inspection is required for each month of activity. With the exception of the initial visit to tour facility and review procedures, all subsequent inspections shall be unannounced visits, unless otherwise arranged for a meeting with facility management. The NELMA inspection procedures will include the following: A walk-thru of the facility grounds and production facility to check for contaminants, Check the quality of raw materials in storage on-site and verify with Raw Material Purchases Record, Review Daily Pellet Testing Log for non-compliance and verify any corrective actions required via CAR Report, Perform one in-house test with Quality Manager of the 6 properties and record results, Check and verify quantity of product segregated to the designated non-compliant product area, if corrective actions were necessary since last inspection, Release any non-compliant segregated product based on an approved disposition plan by management, Check Monthly Production Record by Pellet Grade report and Product Complaint Record. Check inventory and security of pre-printed packaging that includes the NELMA quality mark at the facility, Check inventory of packaged product for damage and proper labeling, Review inspection findings with Quality Manager and other management personnel as needed. In addition, the NELMA Inspector shall select from the on-site inventory a 40-lb. bag sample for each 1,000 tons of densified fuel produced that is representative of the densified fuel produced by the facility for the period elapsed between inspections. If less than 1,000 tons of densified fuel had been produced since the last inspection, one 40-lb. bag will be sampled. For bulk shipments, 40-lb. samples shall be collected at transfer points after the pellet cooler. NELMA Densified Fuel Inspection Program Page 7
These audit samples will be date stamped and/or numbered then shipped or transported by the NELMA Inspector to the agency s accredited laboratory for testing of the required densified fuel properties. The lab test results will be completed within 5-10 business days and provided to the facility s Quality Manager for review with the NELMA Inspector. The densified fuel producer shall be considered conforming if 95% of the audit samples are in compliance with all grade criteria as defined in the PFI Standard Specifications for Residential/Commercial Densified Fuel. If up to 5% of the sample does exceed the range specified for the grade, it may not exceed the range by more than 10%, with the exception of the Durability test, which may not exceed the range by more than 2%. For re-inspections, the densified fuel producer shall be considered conforming if the product does not exceed any of the ranges for the grade specified by more than 10%, with the exception of the Durability test, which may not exceed the range by more than 2%. Nonconformance in terms of physical specification criteria that could have reasonably be concluded to have resulted from improper handling or storage after the audit samples had left the manufacturer s site will not be considered in this conformance determination by the Laboratory. This will most commonly be seen as elevated moisture, excessive fines, and/or reduced durability resulting from condensation or exposure to the elements or other moisture sources in transit or storage. The Laboratory results will either confirm the accuracy of the facility s in-house testing procedures or require a reinspection by NELMA and immediate corrective action to ensure product compliance to the PFI Standard. All production of non-compliant densified fuel affected by the laboratory results MUST be held at the facility for corrective action. The facility management must take all measures necessary to ensure that non-compliant products remain at the facility for review and release by the NELMA Inspector. Retention of Records All records shall be retained for a minimum of 5 years and properly stored and labeled for access by the facility management and NELMA. ALSC Review NELMA-certified densified fuel manufacturers will receive inspection visits on a random and periodic basis by personnel of the ALSC. These inspections will also be unannounced and are conducted to ensure that NELMA, as an accredited agency of ALSC, is performing the required inspection procedures prescribed by ALSC for densified fuel. Inspection Discrepancies and NELMA Disciplinary Actions When an inspection or series of inspections reveal serious non-conformances, NELMA shall place the facility on WARNING, where no other agency accredited by ALSC may extend service to the facility for 60 days, or SUSPENSION of SERVICE, where no other agency may extend service for 180 days. Serious non-conformance issues include, but not limited to, failure to maintain an adequately trained Quality Manager, infrequent in-house testing of densified fuel, production of non-compliant product on a regular basis, failure to implement corrective actions as prescribed by NELMA or ALSC, or other unaddressed, ongoing non-compliant issues found at the facility by the NELMA Inspection staff. NELMA Densified Fuel Inspection Program Page 8
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