PFI Standards Program Proposed Revisions 

February 2010 

Solicitations for feedback on PFI’s Standards and QA/QC program have revealed 

numerous reasons why individual producers have not registered. PFI’s Standards 

Committee has compiled a list of what is believed to be the most pressing concerns 

regarding the Standards Program. It is the Committee’s intent to gain feedback on these 

key components from all PFI manufacturer members to identify if there is enough 

support to modify the program in a manner which increases acceptance within the 

industry, while at the same time does not compromise the underlying program objectives. 

Please review the issues described below and provide your preferences and/or comments. 

Any feedback you can provide is greatly appreciated. 

1. Enforcement – One of the main concerns expressed regarding this program is 

that it is one way to “cheat the system” and not sufficiently enforceable (i.e. lacks 

teeth). Original discussions regarding external/unannounced auditing was 

excluded in the final program due to concerns of program cost (anticipated to cost 

several thousand dollars per facility per year). Enforcement measures included in 

the program are the Certification of Compliance document, date coding, the Data 

Review Board, and a caveat on page 4 of the QA/QC Program document, which 

reads “PFI also retains the right to perform unannounced audits on participating 

mills or labs that had received complaints, that appear to be selling product that 

had been improperly labeled or falsely registered, or just as a periodic spot 

check.” 

A possible option has recently been identified that allows for an external auditing 

component that could cost in the hundreds of dollars as compared to the 

thousands. The concept is that we can use an inspection company that has 

auditors/inspectors throughout North America already providing inspections for 

other related industries. If audits are performed unannounced at the convenience 

of the inspector, they can be incorporated into other inspection efforts and cost 

can be minimized. Audits could of course also be pre-planned and specially 

coordinated. However, costs would be expected to increase and the aspect of 

surprise is lost. Please identify your preference below, or provide an alternate 

option: 

A. _______ Leave enforcement as it is. 

B. _______ Include external unannounced auditing. 

C. _______ Include scheduled auditing. 

D. _______ Other, Please specify below. 
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2. Cost – It has always been understood that the Standards Program needs to 

incorporate key components, but still be affordable. Program components that 

affect bag printing certainly affect cost. However, these are addressed below. 

Otherwise, components that affect cost include purchasing equipment for an 

internal QC lab, personnel time in conducting tests and maintaining the quality 

program, third party QA analysis, and the registration fees. Please provide your 

opinions regarding the various costs associated with this program (a list of fees 

can be found on page 7 of this document). 

Registration Fees (Used to pay for registration review costs, quarterly data 

evaluation costs and staff time associated with program maintenance): 

A. _______ Are acceptable, leave as is. 

B. _______ Are too high. 

C. _______ Should be increased to pay for an external auditing component. 

D. _______ Other, Please Specify 

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Third Party QA Analysis (Samples are submitted at a rate of 1 sample per 1000 

tons of product produced): 

A. _______ Current frequency is acceptable, leave as is. 

B. _______ Current frequency is too high or too low (please specify 

 alternate rate below and provide any justification you can for 

 the rate provided). 

C. _______ Current frequency is acceptable as an initial submittal rate, 

 however a schedule should be developed for reducing the 

 frequency based on the quality of the data set provided by the 

 producer. 

D. _______ Current frequency is acceptable as an initial submittal rate, 
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 however a schedule should be developed for reducing the 

 frequency based on having full in-house laboratory capabilities 

 (capable of testing all PFI parameters in accordance with PFI 

 accepted test methods). 

E. _______ Other, Please Specify: 

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Other Program Costs (Please provide any additional concerns you may have 

regarding other associated program costs): 

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3. Logistical Issues – As various producers have initiated the implementation of 

PFI’s Standards Program various program components have been identified that 

logistically make the program difficult to comply with. Here are a few of them: 

Bar Graphs – The bar graphs for ash and BTU were developed to provide a visual 

reference within the stove manual so that the consumer can match the picture on 

the bag with the picture in their stove manual to assure that they are burning the 

fuel specified by the stove manufacturer, to provide more information to the 

consumer as to the actual ash and BTU values, and to allow producers that could 

not produce a particular grade of fuel (most notably Super Premium) an option for 

demonstrating that their fuel quality may be close to the grade. This component, 

however does create some logistical difficulties. Producers with multiple plants 

may not be able to use the same bag for their various plants, increasing cost. Data 

compliance becomes more difficult in that you can pass the grade requirements, 

but fall outside of the limits on the bar graph. Finally, the bar graph can create a 

marketing advantage or disadvantage as consumers will likely look for bags that 
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have as low and as narrow of an ash bar graph as possible. Here are some 

options: 

A. _______ Leave both bar graphs as they are. 

B. _______ Keep the ash bar graph so that it can be used for the visual 

 purpose originally intended for the stove manufacturers, 

 however limit the bar graph by having the graph extend the full 

 range of the registered grade (e.g. a bar graph for a premium fuel 

 would show the bar span from 0 – 1.0%, 0 – 0.5% for super 

 premium, etc.) 

C. _______ Remove the ash bar graph. 

D. _______ Keep the BTU bar graph as is. 

E. _______ Remove the BTU bar graph. (would require some other measure 

 for making sure producers report As-Received BTU values 

 representative of their product and not just the best value ever 

 seen or Dry Basis BTU values). 

F. _______ Other, Please Specify; 

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Grading Requirements – There are certainly cases where producers are having a 

hard time making the grade they intend to produce as it is currently defined. 

Grade requirements are primarily what was going to be reviewed after the year of 

data collection, however if in the short term there are enough issues raised 

regarding specific parameter requirements modifications can be made. Are there 

any grade requirements that you feel are inappropriate, please specify: 

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Standard Deviations – PFI’s QA/QC program currently specifies that grade 

compliance is based on calculating the mean +/- 2 Standard Deviations, in which 
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if these values meet the grade requirements then the fuel is in compliance with the 

PFI Standards. By definition, +/- 1 SD, +/- 2 SD, and +/- 3 SD, incorporates 

68.2%, 95.4%, and 99.6% of the data set respectively. Most industries use +/- 3 

SD in assessing quality compliance with QA/QC metrics. PFI’s program has 

incorporated +/- 2 SD to ease the burden of grade compliance and allow some 

forgiveness in the program considering the nature of variability in biomass. Some 

have indicated that +/- 2 SD is too strict and others have indicated it is not strict 

enough. What do you consider to be the appropriate metric for establishing grade 

compliance? 

A. _______ +/- 3 Standard Deviations 

B. _______ +/- 2 Standard Deviations 

C. _______ +/- 1 Standard Deviation 

D. _______ Other, Please Specify; 

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4. Program Promotion – There have been numerous efforts to get the word out 

regarding PFI’s Standards Program, which includes write ups in several 

newsletters and publications, however it will take time for PFI’s Certification 

Marks to become recognized as the industry symbol of quality. If there is 

anything you feel PFI should be doing, in addition to its current efforts, to 

promote this program please advise: 

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5. Legal Authority – Some producers have expressed dissatisfaction in that they 

feel PFI should have a greater degree of legal authority to prosecute fraudulent 

activities in the pellet industry (primarily in the form of confronting producers 

that have mislabeled product). Currently the only legal authority that the PFI has 
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is to enforce PFI logo and Certification Mark use and misuse. PFI is currently 

developing a licensing agreement to accompany the use of the Certification Marks 

so that they can be provided to a producer and revoked if necessary. In time, if an 

external auditing component is accepted, manufacturers provide warranty 

restrictions, and regulatory agencies require the use of PFI’s Standards Program, 

the Certification Marks and licensing agreement should provide a significant level 

of legal authority. Please provide any additional thought or feedback you have 

regarding this issue: 

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6. Other – If there are any other issues or have ideas that you feel are critical to the 

industry acceptance of the PFI Standards Program please share them with us: 

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7

Mill Participation/Registration Fees

First Year: 

Members: $1,000 

Non-members: $2,500 

Additionally, if you operate more than one production location you can register each additional 

production location for $750 if you are a PFI member and $1,500 for non-members, provided 

that they are registered at the same time. 

Second year and beyond: 

Members: $400 

Non-members: $1,200 

Additionally, if you operate more than one production location you can register each additional 

production location for $300 if you are a PFI member or for $600 if you are a non-member, 

provided that they are registered at the same time. 

Testing Lab Participation/Registration Fees 

(In order to participate in the standards program, all testing labs must be registered with PFI. 

Participating mills must send pellets for testing to a registered lab only. ) 

PFI Suppliers Membership level PFI Membership Fees Lab Registration Fees Total Fees

Non-member $0 $1,750 $1,750

HPBA member* $0 $1,000 $1,000 

Bronze $1,500 $1,000 $2,500

Silver $3,000 $500 $3,500

Gold $5,000 Free $5,000

*Note: The HPBA membership fees are accepted as the equivalent to the baseline PFI membership fees 

and as such, the HPBA member lab would enjoy the same lab registration fees as the Bronze PFI member.