AMERICAN LUMBER STANDARD COMMITTEE, INCORPORATED®

RESIDENTIAL/COMMERCIAL DENSIFIED FUEL

ENFORCEMENT REGULATIONS

November 2, 2012
TABLE OF CONTENTS

1. INTRODUCTION................................................................................................................. 3

2. STANDARDS AND TEST PROCEDURES............................................................................... 3

3. RESIDENTIAL/COMMERICAL DENSIFIED FUEL MANUFACTURERS QUALIFICATION....... 4

4. INSPECTION AGENCY ACCREDITATION ........................................................................... 4

5. FUNCTIONS OF THE BOARD OF REVIEW......................................................................... 11

6. LABORATORY ACCREDITATION ...................................................................................... 12

7. INTERPRETATIONS.......................................................................................................... 16

8. ADDITIONAL PROCEDURES ............................................................................................. 16
American Lumber Standard Committee, Incorporated®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations

November 2, 2012

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1. INTRODUCTION

1.1 General

1.1.1 This program is intended to establish a 

common basis for uniform, industry-wide inspection and quality marking procedures for residential or commercial densified fuels produced in 

accordance with the provisions hereof. 

1.2 Covered Products

1.2.1 These regulations are applicable for the 

determination of fuel quality grade for densified 

fuel products as defined in the Pellet Fuels Institute (PFI) Standard Specifications for Residential/Commercial Densified Fuel. 

2. STANDARDS AND TEST PROCEDURES

2.1 The commodities and test methods to 

be used in this program shall be those referenced 

in the PFI Standard Specification for Residential/Commercial Densified Fuel standard, PFI 

Residential/Commercial Densified Fuel QA/QC 

Handbook or other applicable standards. 

2.2 Regular verification of the quality of 

densified fuel produced by a manufacturer shall 

be carried out by an inspection agency accredited 

by the Board of Review of the American Lumber 

Standard Committee (ALSC).

2.3 The detailed procedures by which the 

agency shall monitor the above standards shall 

be those approved by the Board of Review.

2.4 Board of Review activities involves

verification of the inspection agencies' abilities 

and performance.

2.5 Definitions

Accreditation Criteria - A set of requirements used 

by the Board of Review which an agency or a 

laboratory must meet to be accredited.

Additives – Any substance other than cellulosic 

material that has been intentionally introduced 

into the fuel feed stock prior to pellet extrusion 

(except steam/water). De minimis amounts of 

grease or other lubricants that are introduced into 

the fuel processing stream as part of normal mill 

operations are not considered as additives.

Bag Weight – The weight of the fuel plus the 

bag, determined by weighing a standard bag of 

fuel.

Board of Review - The Board of Review of the 

American Lumber Standard Committee as established by Section 10 of PS-20.

Bulk Density – the fuel mass per cubic foot of the 

fuel sample; determined by ASTM E873 Standard 

Test Method for Bulk Density of Densified Particulate Biomass Fuels as modified by PFI Standard 

Specifications for Residential/Commercial Densified Fuel.

Chemically Treated Materials – With the exception of de minimis levels, any feed stock material 

(cellulosic or otherwise) that has at any time 

been processed, formed, treated or contaminated 

with any bonding agent, resin, preservative, surface coating or other finish, or any other chemical 

compound. Trace amounts of grease or other 

lubricants that are introduced into the fuel processing stream as part of the normal maintenance operations are not considered as chemically treated materials.

De Minimis – Term meaning about minimal 

things. Refers to trace concentrations that are 

too small to be concerned with.

Diameter – The average diameter of the fuel 

pellets in the fuel sample.

Fines – The percentage of fuel material in the 

fuel sample passing through a 1/8 inch screen 

when the fuel is sampled in accordance with the 

requirements in 6.1.4 and Annex C.1 of the PFI 

Standard Specification for Residential/Commercial 

Densified Fuel..

Heating Value – The higher heating value of the 

fuel sample as determined by ASTM 

E711Standard Test Method for Gross Calorific 

Value of Refuse-Derived Fuel by the Bomb Calorimeter.

Inorganic Ash – The percentage of inorganic 

material in the fuel sample as determined by 

ASTM D1102 Standard Test Method for Ash in 

Wood.
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Laboratory - Any laboratory, not owned or operated by a densified fuel manufacturer, that is 

affiliated with or contracted by one or more inspection agencies to perform analyses on densified fuel.

Laboratory Assessment - The on-site examination 

of a laboratory to evaluate its compliance with 

specified criteria.

Laboratory Accreditation - A formal recognition 

that a laboratory is competent to carry out specific tests.

Length – The weight percent of pellets exceeding 

1.5 inches in length in the fuel sample.

Logo - A symbol or trade mark which identifies an 

inspection agency or standards writing organization. 

Moisture – The moisture content of the asreceived fuel sample as determined by ASTM 

E871 Standard Test Method for Moisture Analysis 

of Particulate Wood Fuels.

NIST – The National Institute of Standards and 

Technology (NIST) is a federal technology agency 

that develops and promotes measurement, 

standards and technology.

Pellet Durability Index (PDI) – A standardized 

parameter for specifying the ability of the fuel 

pellets to resist degradation caused by shipping 

and handling.

Quality Control Agency - An organization accredited by the Board of Review to sample and test 

quality marked densified fuels manufactured in 

accordance with quality control and inspection 

procedures. The quality control agency shall 

have no financial interest in any company producing any portion of the densified fuels inspected 

and tested. The quality control agency shall not 

be owned, operated or controlled by any such 

company.

Quality Mark - The mark of the Pellet Fuels Institute in conjunction with an agency accredited by 

the Board of Review indicating product conformance to the PFI Standard Specification for Residential/Commercial Densified Fuel standard and 

other referenced documents. The mark indicates 

that all of the actions and quality requirements 

under the agency's quality control and inspection 

procedures have been met by both the manufacturer and the quality control agency which licenses the use of the mark by densified fuel manufacturers.

Traceability of the Accuracy of Measuring Instruments - A documented chain of comparison connecting the accuracy of a measuring instrument 

to other measuring instruments of higher accuracy and ultimately to a primary standard.

3. DENSIFIED FUEL MANUFACTURER 

QUALIFICATIONS

3.1 Manufacturer Equipment--Must 

comply with Section 6.8--Equipment and Operating Processes requirements outlined within PFI 

Residential/Commercial Densified Fuel QA/QC 

Handbook.

3.2 Manufacturer Records

3.2.1 Each manufacturer shall maintain records as outlined within PFI Residential/Commercial Densified Fuel QA/QC Handbook.

3.5 Internal Quality Control

3.5.1 Maintaining quality is the responsibility 

of the manufacturer management. Internal 

quality control procedures shall be performed to a 

degree that assures compliance of the densified 

fuel product to the PFI Standard Specification for 

Residential/Commercial Densified Fuel standard 

and other applicable documents. Production 

found non-conforming to the fuel grade requirements shall have its quality mark obliterated or 

relabeled with a quality mark of the next lower 

fuel grade provided the production meets all the 

requirements of the lower fuel grade.

3.5.2 Management shall appoint an adequately trained employee as manufacturer quality 

manager. He shall be vested with the authority to

correct any condition causing a non-conformance, 

to remove the quality mark from any material 

that does not conform to the PFI Standard Specification for Residential/Commercial Densified Fuel

standard and other applicable documents, and to 

stop shipments of quality marked non-conforming 

material.

4. INSPECTION AGENCY ACCREDI-
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TATION

4.1 Approval

4.1.1 The initial and continuing accreditation 

of an agency to provide inspection services under 

these regulations is contingent upon providing 

reliable and adequate inspection services in accordance with the current and applicable PFI 

Standard Specification for Residential/Commercial 

Densified Fuel standard and other applicable 

documents. The Board of Review will use these 

regulations to judge the competency, reliability 

and adequacy of densified fuel quality control 

agencies.

4.2 Participation in this program

4.2.1 Any agency is eligible to participate in 

this program established herein if that agency:

(a) Formulates, publishes and maintains quality control and inspection procedures for the specific densified fuel, which it inspects, and which 

are covered by the PFI Standard Specification for 

Residential/Commercial Densified Fuel standard 

and other applicable documents.

(b) Demonstrates initial and continuing competency and reliability in the field of the densified 

fuel inspection.

(c) Agrees to pay charges and fees assessed 

by the ALSC.

4.2.2 Any agency desiring to participate in 

this program shall apply in writing to the Manager 

of the Board of Review in such form as may be 

prescribed by the Manager. If the application is 

in proper order, the Manager shall promptly forward the application to the Board of Review for 

its consideration and the Manager shall undertake 

any further investigations of the applicant as may 

be requested by the Board of Review. The applying agency shall be responsible for the fees established to cover expenses incurred in conducting the qualification, including the cost of accreditation of quality control laboratories. Such fees 

to be paid in advance.

4.3 Accreditation Requirements

Before accrediting the inspection services of any 

agency, the Board of Review shall require evidence that the agency conforms to the following 

requirements:

4.3.1 It shall not be controlled by any person 

or firm whose own products are subject to its 

inspection and certification nor shall its inspectors 

be employed by any densified fuel manufacturer 

or producer of densified fuel products or by any 

buyer of densified fuel, or engaged in any other 

undertaking which might conflict with their independent position as inspectors.

4.3.2 It shall maintain the practice of having 

all inspections done only by properly supervised 

and qualified inspectors all of whom shall be 

under the direct control of the agency. Each 

inspector shall be thoroughly competent in the 

inspection of densified fuel he/she inspects. Inspectors shall be directed by a chief inspector, 

supervisor or manager who is thoroughly experienced in the inspection of densified fuel products 

and who shall be held responsible for the proper 

functioning of the members of the inspection 

staff.

4.3.3 It shall maintain a bona fide densified 

fuel manufacturer audit service for the purpose 

of assuring the uniform application of the PFI

Standard Specification for Residential/Commercial Densified Fuel standard, other 

applicable documents and agency quality control 

and inspection procedures. The agency shall 

perform sampling and testing of a manufacturer’s qualified production at a minimum rate of 1 

sample per every 1,000 tons of densified fuel 

produced. If less than 1,000 tons of densified 

fuel have been produced since the last inspection then a minimum of 1 sample shall be collected and tested, if available. The agency’s 

samples shall be representative of a manufacturer’s production for the period elapsed between inspections. Written reports of each inspection shall be made to the manufacturer and 

copies shall be kept available by the agency for 

examination by the Board of Review or its representative upon request. The agency shall also 

have available conforming reports from an ALSC 

accredited laboratory for the densified fuel sampled during the agency inspection. These records shall be kept for a minimum of two years.

4.3.3.1 It is the obligation of the agency to 

audit the densified fuel manufacturer on a regular 

basis, and the obligation of the manufacturer to 
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produce a properly labeled densified fuel product. 

Samples of previously manufactured densified 

fuel product shall be inspected as part of the 

agency supervision. At the minimum rate as 

prescribed in 4.3.3, the agency shall sample a 

sufficient amount of production representative of 

the densified fuel grade levels produced by the 

manufacturer to adequately evaluate the 

proficiency of the densified fuel manufacturer. 

When a sample of densified fuel indicates the 

product is not properly labeled the production 

representing that non-conforming sample shall be 

held for correction. The agency shall verify that 

the production has been corrected by either 

removal of the quality mark or by relabeling with 

a quality mark of the next lower fuel grade 

provided the production meets all the 

requirements of the lower fuel grade. The 

agency shall take whatever steps necessary to 

prevent recurrence. Each month the agency 

headquarters personnel shall review the 

performance of each manufacturer and take 

whatever action is warranted. In addition, the 

review shall include the assessment of the agency 

sample results for each inspection. If the 

inspection results fail to meet the specified 

criteria, the agency shall increase inspections 

until such time as the inspection results are in 

compliance with the requirements at which time 

the frequency of inspections may return to 

normal.

4.3.4 It shall conduct all audit and inspection 

activities in a manner which complies with all 

requirements of these Enforcement Regulations 

and its quality control and inspection procedures 

as approved by the Board of Review. 

4.3.5 It shall adhere to the policy of uniformly requiring its inspectors to determine conformance to all applicable specifications before issuing

a certificate thereon or marking the densified fuel 

product with the quality mark.

4.3.6 It shall uphold the standards of the 

industry through proper inspection procedures 

and shall maintain sufficient checks of its inspection staff to assure not only the continuing honesty and competency of its members, but consistency on their part in the proper application of 

densified fuel products specifications.

4.3.7 Regardless of production each 

manufacturer of densified fuel shall be inspected 

a minimum of twelve times per year at 

approximately monthly intervals, except in those 

cases where a manufacturer is inactive in excess 

of 2 months in any 12 month period in which 

case an inspection is required for each month the 

plant actually produces densified fuel.

4.3.8 All accredited agencies shall provide at 

all times an adequate, competent and reliable 

inspection service according to the requirements 

of these Enforcement Regulations. 

4.3.9 All quality control and inspection procedures submitted for approval shall conform to 

the minimum requirements of the PFI Standard 

Specification for Residential/Commercial Densified 

Fuel standard, other applicable documents and to 

the requirements of these Enforcement Regulations. If deficiencies are found in the review of 

an agency's quality control and inspection procedures, the deficiencies shall be brought to the 

attention of the agency. The agency shall have 

the option of amending the procedures to conform or requesting a hearing before the Board of 

Review.

4.3.10 An agency shall agree to have its quality control and inspection procedures carry a specific reference to the approval by the Board of 

Review and that these procedures conform to the 

PFI Standard Specification for Residential/Commercial Densified Fuel standard and other applicable documents.

4.3.11 Agencies shall agree to permit republication of their quality control and inspection procedures in whole or in part without charge with 

all quoted parts clearly so indicated. The republication shall carry a reference to the source of the 

procedures and their effective date, and when 

they are revised to conform with any subsequent 

changes in the quality control and inspection 

procedures they shall show the effective date.

4.3.12 When quality control and inspection 

procedures have been approved by the Board of 

Review, subsequent revisions shall be proposed 

by the promulgating agency to the Board of Review for approval.

4.3.13 Security and Contracts. The Board of 

Review shall require as a condition to its accreditation of any agency the payment when due of all 

charges and fees assessed by the ALSC to cover 
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the cost of carrying out its functions and the 

reimbursement to the ALSC for all costs and expenses incurred by the ALSC or its Board of Review in any investigation of the activities or practices of the agency, whether or not the investigation is initiated by the ALSC or its Board of Review or upon complaint. The Board of Review 

shall require that each accredited agency execute 

a contract with the ALSC in such form and containing such provisions as the ALSC may from 

time to time decide, and that each such agency 

observe and act in a manner consistent with the 

provisions of the contract.

4.3.14 The Board of Review shall require each 

accredited agency to prepare and submit to it for 

approval, a form of contract which each agency 

shall require the subscribing densified fuel manufacturer to execute. Accredited agencies shall 

maintain copies of contracts executed with each 

densified fuel manufacturer receiving their services for a period of not less than two years after 

termination of such contracts.

4.3.15 Agency Policy Changes. If at any time 

there should be any change in any policies of an 

agency relative to matters that are required under these Enforcement Regulations, the agency 

shall immediately notify the Board of Review in 

writing.

4.4 Agency Accreditation for Manufacturer Supervisory Service and/or Inspection Service

4.4.1 The Board of Review shall require an 

applicant to submit complete information as to its 

form or organization, the length of time it has 

functioned, the experience of its management as 

well as the individual inspection personnel and 

the supervision of its inspection staff. The applicant shall also submit, as applicable to the service(s) offered, complete information about the 

manufacturers under its supervision, the production volume of the manufacturers, programs for 

which supervision will be offered, programs for 

which lot inspection services will be offered, procedures for handling requests for inspection, 

adequate provisions for supervision of manufacturers quality control, supervision of manufacturers performance, authority to apply the agency's 

quality mark and evidence that all applicable 

requirements of the PFI Standard Specification 

for Residential/Commercial Densified Fuel standard and other applicable documents are being 

met by the agency and its manufacturers.

4.4.2 Before accrediting the inspection service(s) of any agency, the Board of Review shall 

require evidence that it conforms to all the requirements of Section 4.2 and Section 4.3 of 

these Enforcement Regulations in the conduct of 

its manufacturer supervision and/or inspection 

services and that the agency conforms to its own 

approved quality control and inspection procedures, these Enforcement Regulations and all 

applicable requirements of the PFI Standard 

Specification for Residential/Commercial Densified 

Fuel standard and other applicable documents.

4.5 Application of the Quality Mark 

and Certificates of Inspection

4.5.1 The application of the quality mark 

shall be accomplished by one of two methods: by 

manufacturer employees under the supervision of 

an accredited agency or by employees of the 

accredited agency, as specified herein. Application of the quality mark of agencies approved to 

conduct supervisory services will be conducted 

under the requirements of these Enforcement 

Regulations, the agency's quality control and 

inspection procedures and approved procedures 

for the withdrawal of services for unsatisfactory 

performance. When an employee of any agency 

is regularly stationed at a point of production, he 

will be checked at the same intervals in the same 

manner as a facility employee would be checked 

by a supervisory agency.

4.5.2 Inspections and certificate of inspection shall be permitted at any point where there 

is good and sufficient reason for them and shall 

be performed only by qualified agency personnel 

or qualified agents of an accredited agency.

4.5.3 Densified fuel accepted by the Inspector on a certificate inspection shall be identified by the Inspector’s mark or other identifying mark and the identifying mark shall be 

shown on the certificate.

4.6 Marking

4.6.1 An accredited agency is permitted to 

license the use and application of its quality mark 

to complying densified fuel products by any manufacturer which subscribes through the agency to 
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this program.

4.6.2 Continued use of the quality mark is 

subject to continued conformance to the PFI 

Standard Specification for Residential/Commercial 

Densified Fuel standard and other applicable 

documents by sampling and testing in accordance 

with these Enforcement Regulations.

4.6.3 Application of the quality mark to 

products covered by the PFI Standard Specification for Residential/Commercial Densified Fuel

standard by a manufacturer licensed by an accredited agency constitutes verification that the 

product has been produced under the agency 

quality control program.

4.6.4 A quality mark shall not be applied to 

any densified fuel product where the product is 

misrepresented by a deceptive grade mark, label, 

brand or certificate. 

4.6.5 Except as provided below when the 

quality mark of an accredited agency is used each 

densified fuel bag shall be marked and densified 

fuel products bearing a quality mark shall not be 

mixed with non-marked products. 

4.6.5.1 In the case of bulk shipments the quality mark shall be provided with commercial documents.

4.6.6 The following minimum information is 

required to be on a quality mark whether 

stamped, labeled or branded:

 Registration number

 Densified fuel grade

 Grade Requirements as outlined in Section 8 

of PFI Residential/Commercial Densified Fuel 

QA/QC Handbook

 Manufacturer’s Guaranteed Analysis

 The identifying symbol or logo of the accrediting agency and the Pellet Fuels Institute

4.6.7 Quality marks of accredited agencies 

shall be uniform in providing the required information and shall be legible when placed on a 

densified fuel product.

4.6.8 A representative facsimile of an agency's quality mark shall be on file with the Board of 

Review. 

4.6.9 It is the policy of the Committee that 

densified fuel manufacturer quality marks, grade 

marks, grade stamps, labels, brands, certificates 

or other product description shall not be confusingly or deceptively similar to the quality marks

of any ALSC accredited agency, including, but 

not limited to, reference to the PFI Standard 

Specification for Residential/Commercial Densified Fuel standard or other applicable documents directly or indirectly. 

4.6.10 It is the policy of the Committee that 

densified fuel manufacturer quality marks, grade 

marks, grade stamps, labels, brands, certificates 

or other product description shall not misrepresent densified fuel products, including, but not 

limited to, reference to the PFI Standard Specification for Residential/Commercial Densified Fuel

standard or other applicable documents directly 

or indirectly. 

4.6.11 Each accredited agency shall be responsible for the control of its quality marks. 

Quality marks shall only be used at manufacturers or by personnel authorized by accredited 

agencies. Accredited agencies shall require a 

participating manufacturer to provide care and 

security of the agency quality marks. An accredited agency shall retain on file a facsimile of each 

quality mark issued, require worn out or discarded quality marks to be destroyed, and require 

missing or stolen quality marks be reported to the 

agency. The agency shall report missing, stolen, 

or misuse of its quality marks to the Board as 

soon as the agency is aware of such.

4.6.11.1 Except by prior written arrangement 

with the agency, the quality marks issued by an 

agency to a specific manufacturer location are to 

be used only at that location.

4.6.12 To obliterate means to render the approved quality mark unreadable or clearly inapplicable. Examples of obliteration of the approved 

mark or stamp include, but are not limited to 

removal by over-stamping with opaque indelible 

ink or paint applied in a solid block, multiple ‘x’ 

stamp or other means of over-marking. Marking 

through the approved quality mark with a semitransparent ink, paint, or crayon which allows full, 

though possible reduced visibility of the approved 

quality mark does not constitute obliteration.

4.7 Warnings, Suspensions and With-
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drawals

4.7.1 Accredited agencies shall withdraw 

quality marks from any manufacturer utilizing 

their services when an inspection or a series of 

inspections reveal serious non-conformances. An 

agency will immediately notify the Manager of the 

Board of Review by letter when it warns, suspends or withdraws the quality marking services

at any manufacturer for cause, supplying all pertinent details. Upon receipt of such notice, the 

Manager of the Board of Review shall immediately notify by letter all other accredited agencies 

extending services in the area. No other agency 

shall extend supervisory service or any other 

quality marking services to the manufacturer for 

a period of 180 days in the case of a suspension 

or withdrawal notice, or 60 days in the case of a 

warning notice, after the date of the letter of the 

agency's notification, unless the manufacturer 

has been reinstated by the agency which warned, 

suspended or withdrew its service, when the 

services of the other agency result in evading the 

warning, suspension or withdrawal. The agency 

may reinstate quality marking supervisory services only after the manufacturer involved 

demonstrates the ability and willingness to maintain the applicable requirements of the agency's 

quality control and inspection procedures, these 

Enforcement Regulations and the PFI Standard 

Specification for Residential/Commercial Densified 

Fuel standard and other applicable documents. 

The agency shall file a complete report with the 

Board of Review outlining all corrective steps 

taken.

4.8 Reinspection

4.8.1 Reinspection by agencies accredited by 

the Board of Review shall be available to both 

buyer and seller upon request for the purpose of 

determining compliance with purchase specifications and effecting settlement of complaints and 

invoices.

4.8.2 Reinspection shall be performed in 

accordance with the reinspection provisions as 

outlined in Section 6.11 of the PFI Residential/Commercial Densified Fuel QA/QC Handbook.

4.8.3 The expense of reinspection shall be 

borne in accordance with the provisions of the 

quality control and inspection procedures of the 

applicable agency, but the person calling for the 

reinspection shall be responsible to the agency 

for the costs thereof.

4.9 Agency Reports

The Board of Review shall require reports to be 

rendered at such times it determines necessary. 

The reports shall include, among other things, 

information as follows:

4.9.1 The number of lot inspections performed during a particular period and the volume 

of densified fuel involved.

4.9.2 Reinspection of densified fuel products 

originally graded by the agency or marked with 

an agency's quality mark during a particular period with details on each, including the name of 

the original inspector and the date of the original 

inspection if certification is involved, the point of 

origin, name and location of the consignee, date 

of reinspection, item(s) and quantities involved 

and results of the reinspection.

4.9.3 A summary report on the agency's own 

manufacturer inspections and analytical results 

during a given time which generally shall coincide 

with the random sample survey conducted by the 

Board of Review.

4.10 Record Retention

4.10.1 As a condition for accreditation, an 

agency shall maintain for a period of at least 2 

years records of all inspections made. These 

records shall be available for examination by a 

representative of the Board of Review at any time 

during normal working hours. Any employee of 

any agency whose principal job is inspecting any 

manufacturer's product shall be supervised by the 

agency and reports of the supervision kept in the 

agency's files for a period of two years.

4.11 Field Examination

4.11.1 Each agency shall agree to permit the 

staff representatives of the Board of Review to 

examine any densified fuel product certified 

and/or quality marked by the agency or under 

the agency's supervisory service at the manufacturer or destination points, for the purpose of 

checking the performance of the agency, its inspectors and the general reliability of its service.
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4.11.2 Board of Review staff personnel shall 

have the right to examine unmarked material at 

plants and at destination points.

4.11.3 The agency shall agree that if any 

densified fuel product which it has certified or 

quality marked or is produced under its supervisory service whether quality marked or not, is 

found to be deficient, the agency shall cooperate 

fully in taking such steps as shall be necessary to 

eliminate the risk of recurrence of such deficiencies by the same inspector or plant. Each agency 

shall also agree that serious deficiencies, when 

found, shall require complete reinspection of the 

shipment or lot.

4.12 Random Sample Survey

4.12.1 The staff representatives of the Board 

of Review shall conduct on a random sampling 

basis, check inspections on densified fuel produced by each accredited agency's manufacturers. The manufacturers included in each survey 

shall be selected at random and shall be of sufficient number to be deemed representative of the 

total quantity of densified fuel produced under an 

accredited agency's authority. The results of 

the random sample survey shall be used by the 

Board of Review as one measure of determining 

the continuing competency and reliability of an 

accredited agency.

4.13 Agency Follow-up

4.13.1 Unsatisfactory Reports

On each occasion when a field report by a Board

of Review inspector reveals a serious infraction, 

the Board of Review or its staff shall promptly 

notify the agency of the infraction, send the 

agency a copy of the inspector's report, and request the agency to take corrective action with 

the manufacturer or agency employee involved to 

prevent a recurrence of the infraction. The agency shall reply stating in detail the corrective actions taken, and shall continue to make such 

reports until such time as it is satisfied that a 

recurrence of the infraction is unlikely and it notifies the Board of Review that it is satisfied. Appropriate documentation shall accompany all 

reports.

The Board of Review shall periodically evaluate 

the effectiveness of an agency's follow-up. The 

Board of Review shall to the extent possible confirm that the agency did in fact take all action as 

reported to the Board of Review.

The Board of Review shall maintain records of the 

agency's follow-up performance. These records 

shall be used by the Board of Review as one 

measure of the continuing competence and reliability of an agency.

4.13.2 Board of Review Requested Reinspection

(a) Destination: Upon finding that a given 

shipment of densified fuel that is quality marked 

and/or certified appears to contain serious infractions, the Board of Review inspector without 

divulging detailed information to the customer 

shall request the material be held for reinspection. The inspector shall immediately notify his 

office with full details of the infraction. The office 

of the Board of Review shall immediately notify 

the agency whose quality mark appears on the 

material and the agency in turn shall immediately 

advise the customer holding the material that a 

prompt reinspection is to be made by the agency 

at no cost to the customer provided the customer 

agrees to hold the stock and furnish labor if necessary (for which he shall be reimbursed by the 

agency) and further agrees to assess no holding 

charges for the densified fuel held for reinspection.

The agency shall furnish results of the reinspection to all parties of the transaction. Costs of 

such reinspection shall be funded by the ALSC 

except when the densified fuel is found to be 

non-conforming according to the reinspection 

provisions shown in Section 4.8 of these Enforcement Regulations, the shipping manufacturer shall be responsible to the agency for the cost 

of the reinspection.

(b) Origin: Upon finding quality marked and/or 

certified material at the point of origin which 

contains serious infractions, the Board of Review 

inspector shall request the manufacturer to hold 

the material for review by the agency and notify 

his office immediately of the infraction giving full 

details. The office of the Board of Review shall 

immediately notify the agency whose quality 

mark appears on the material. The agency shall 

immediately notify the manufacturer management and confirm that the material is to be held 
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for review by the agency. The agency shall review the material being held and determine the 

appropriate action and shall promptly report the 

actions taken to the Board of Review. Any manufacturer failing to hold such material shall be 

subject to having the use of its quality marking

devices suspended immediately.

4.13.3 If the agency disagrees with the ALSC 

field representative’s finding as to the labeling of 

the densified fuel product, the agency shall notify 

the ALSC office and give the ALSC an opportunity 

to review the densified fuel product with an 

agency representative if necessary. If this procedure is not followed, the ALSC report stands.

4.14 Board of Review Destination Inspections

4.14.1 The results of destination inspections 

may be used by the Board of Review as one 

means of determining the agency's performance.

4.15 Board of Review Enforcement 

Actions

4.15.1 Probation, Suspension or Revocation of 

Agency Accreditation: The Board of Review shall 

judge the continued competency, reliability, adequacy and integrity of accredited agencies under 

these Enforcement Regulations. The Board of 

Review, after reviewing the competency, adequacy, integrity and performance of an agency, shall 

take any of the following actions as in the judgment of the Board of Review is necessary to 

maintain the integrity of this program. 

(a) Take no action.

(b) Place an agency on probation.

(c) Suspend the approval of an agency.

(d) Revoke the approval of an agency.

In arriving at its decision to take any of the above 

actions, the Board of Review shall consider any 

information at its disposal, including, but not 

necessarily limited to, the information contained 

in agency reports to the Board, results of the 

random sample survey inspection, destination 

inspections and follow-up performance of an 

agency in specific instances. Actions of probation, suspension or revocation by the Board of 

Review shall be made public.

4.15.2 Board of Review Procedures: Before 

any agency is placed on probation or its accreditation is suspended or revoked by the Board of 

Review, the Board shall notify the agency that 

enforcement actions against the agency may be 

taken by the Board and the agency shall be afforded opportunity to appear before the Board in 

person and by counsel in connection with such 

pending action by the Board. A Board of Review 

action placing an agency on probation, suspending or revoking the accreditation of an agency 

shall be taken on the basis of evidence introduced on the record in a hearing held by the 

Board with opportunity on the part of the agency 

concerned to examine the evidence of record and 

to cross examine witnesses testifying before the 

Board and the opportunity on the part of the 

agency concerned to submit its own evidence in 

the hearing.

4.16 Lapse of Accreditation

4.16.1 If an accredited agency shall not have 

inspected any densified fuel product for a period 

of two years, the accreditation of that agency 

shall thereupon lapse and terminate, unless the 

agency shall establish grounds for continuance of 

its accreditation. Lapse and termination of accreditation shall not prejudice later application for 

accreditation.

5. FUNCTIONS OF THE BOARD OF 

REVIEW

5.1 Inspection Visits

Inspections shall be performed by the field staff 

of the Board of Review for the purpose of monitoring agency performance. Four types shall be 

made. They are as follows:

(a) Random Sample Survey Inspections

(b) General Inspections

(c) Destination Inspections

(d) Recall Inspections

The purpose for each type of inspection is:

5.1.1 Random Sample Survey: Inspections 

shall be made at a specific number of an agency's 

manufacturers chosen at random. The number of 

manufacturers chosen for inspection from each 

agency shall be determined by the number of 

manufacturers an agency supervises. Samples 

from randomly selected commodities shall be 
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obtained at each manufacturer and the number 

of samples taken at any manufacturer included in 

a survey shall be dependent on the manufacturer's annual production.

5.1.2 General Inspections: Inspections shall 

be made at manufacturers on a general basis. 

Samples taken at these inspections shall be from 

any material present at the manufacturer at the 

time of inspection.

5.1.3 Destination Inspections: Destination 

inspections shall be made in chosen market areas.

5.1.4 Recall Inspections: Where serious 

deficiencies are found at a manufacturer during a 

random sample survey inspection, at a destination inspection, or a general inspection, recall 

inspections shall be made to determine that the 

deficiencies have been corrected.

5.2 Testing

5.2.1 Each inspection shall ensure that densified fuel production facilities are manufacturing 

fuel in accordance with PFI Residential/Commercial Densified Fuel QA/QC Handbook.

5.2.2 When material bearing an agency's 

quality mark is found to be non-conforming during any Board of Review inspection, the agency 

shall be notified immediately. It shall be the 

obligation of the agency to take immediate corrective actions and report such actions to the 

Board of Review.

5.3 Record Review

The records of each accredited agency shall be 

checked at least annually by staff personnel of 

the Board of Review.

The following groups of records shall be among 

those checked:

5.3.1 Records pertaining to agency supervision of its own inspection staff, including records 

of initial inspector training and continuing inspector training, records of the correction of deficiencies in individual inspectors, records showing 

specific qualifications of individual inspectors and 

records showing assignments of individual inspectors.

5.3.2 Records pertaining to manufacturer 

inspections including results of samples taken 

during manufacturer inspections. Records of 

procedures for application of the quality mark. 

Records of frequency of manufacturer inspections.

5.3.3 Records pertaining to the correction of 

deficiencies, found by agency inspection at manufacturers and destination sites and their satisfactory correction and records of reinspection generated by customer complaint and the settlement 

of claims.

5.3.4 Records pertaining to enforcement, 

including records of manufacturer qualification, of 

warnings issued, suspensions, and revocations.

5.4 Findings

5.4.1 Records--The result of the Board of 

Review's staff review of the agency's records 

shall be reported to the Board of Review. The 

Board of Review shall use this information and 

all other information available to the Board in its 

evaluation of an agency's adequacy, competency and reliability.

5.5 Board of Review

5.5.1 The Board of Review shall judge the 

performance, efficiency, reliability, and integrity 

of agencies based on reports of the Board of 

Review's staff using the procedures in Section 4 

and all other information available to it.

5.6 Quality Control Laboratory Accreditation

5.6.1 The Board of Review shall accredit 

agency quality control laboratories or quality 

control laboratories under contract to an agency 

using procedures in Section 6.

6. LABORATORY ACCREDITATION

6.1 General Information

6.1.1 The purpose of this section is to set 

forth procedures for the Board of Review accreditation of laboratories that provide service to inspection agencies under this program.
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6.1.2 Laboratory accreditation is a voluntary 

system for accrediting a laboratory's competence 

to perform specific tests. Competence is defined 

as the ability of a laboratory to meet the program 

conditions and to conform to the criteria.

6.1.3 The Board of Review or its representative shall have the right to visit the laboratory, 

unannounced, during the normal working hours 

for the purpose of inspecting the laboratory and 

its record.

6.2 Definitions--See Section 2.5

6.3 General Conditions for Accreditation

6.3.1 To become accredited and maintain 

accreditation, a laboratory shall agree in writing 

to:

 Be assessed and evaluated initially and on a 

periodic basis;

 Participate in proficiency testing as required.

 Be capable of performing the tests for which 

it is accredited according to the latest version 

of the PFI Standard Specification for Residential/Commercial Densified Fuel standard

test methods and any other referenced 

methods, as applicable;

 Limit the representation of the scope of its 

accreditation to only those tests for which accreditation is granted;

 Maintain records of all analysis for a minimum of two (2) years;

 Render all test reports objectively and without bias;

 Report to the Board of Review thirty (30) 

days prior to any major changes involving the 

location, ownership, management structure, 

or facilities of the laboratory; and

 Return to the Board of Review the document 

of accreditation for possible revision or other 

action, should it become unable for any reason to conform to any of these conditions. 

6.4 Specific Criteria for Accreditation

6.4.1 The laboratory shall operate under an 

internal procedure appropriate to the volume of 

work performed.

6.4.2 The laboratory procedures shall be 

documented in a quality manual or equivalent 

(e.g., operations notebook), which is available for 

use by laboratory staff. A person(s) shall be identified as having the responsibility for maintaining 

the quality manual.

6.4.3 The quality manual shall include, as 

appropriate:

 Laboratory procedures for each approved test 

method.

 Sample control procedures including a system for sample identification.

 Instrument calibration records.

 Specific procedures for each accredited test 

including use of reference standards and control charts, interlaboratory testing procedures, and procedures for retesting where 

necessary.

 Procedures for corrective actions for suspected test discrepancies.

 Quality management responsibilities for each 

procedure in the laboratory.

 Detailed training procedures for new or reassigned employees.

 Procedures for dealing with disputed tests.

6.4.4 The laboratory shall periodically review 

its internal procedures by or on behalf of management to ensure its continued effectiveness. 

These reviews shall be recorded with details of 

any corrective action taken.

6.5 Staff

6.5.1 The laboratory shall be staffed by 

knowledgeable and competent analysts for each 

of the approved analyses.

6.5.2 The laboratory shall have a technical 

manager (or similar title) that has overall responsibility for the technical operations of the laboratory.

6.5.3 The laboratory shall have one or more 

signatories to sign test reports. Approved signatories shall be competent to make a critical evaluation of test results; and shall occupy positions 

within the laboratory's organization which make 

them responsible for the adequacy of test results.

6.6 Facilities and Equipment

6.6.1 The laboratory shall be furnished with 
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all items of equipment and facilities for the correct performance of the tests and measurements 

for which accreditation is granted.

6.6.2 All equipment shall be properly maintained to ensure protection from corrosion and 

other causes of deterioration. Instructions for a 

proper maintenance procedure for those items of 

equipment which require periodic maintenance 

shall be available. Any item of equipment or 

component thereof which has been subjected to 

overloading or mishandling, gives suspect results, 

or has been shown by calibration or otherwise to 

be defective, shall be taken out of service and 

clearly labeled until it has been repaired. When 

placed back in service, this equipment shall be 

shown by test or calibration to be performing 

satisfactorily.

6.6.3 Records of each analytical instrument 

shall be maintained. Each record shall include:

 The name of the analytical instrument.

 The manufacturers' name and type, identification, and serial number.

 Date received and date placed in service.

 Current location, when appropriate.

 Details of maintenance.

 Date of last calibration, next calibration due 

date, and calibration report reference.

6.7 Calibration

6.7.1 All new test and measuring equipment 

shall be calibrated according to the manufacturer's recommendations before putting it into service.

6.7.2 Maintain records of all calibrations and 

recalibrations.

6.7.3 Document the source of all calibration 

and reference standards. When the use of 

standards is not applicable, the laboratory shall 

provide satisfactory evidence of the accuracy or 

reliability of test results (e.g., by participation in a 

suitable program of interlaboratory comparison).

6.8 Test Methods and Procedures

6.8.1 The laboratory shall perform all tests in 

accordance with approved PFI Standard Specification for Residential/Commercial Densified Fuel

standard procedures.

6.8.2 The laboratory shall maintain a system 

of sample identification to ensure that there is no 

confusion regarding the identity of the samples 

and the results of the measurements made.

6.8.3 Laboratories shall retain 5 pounds of all 

inspection samples in numerical order, for 3 

months. If the analytical procedure employed 

results in the destruction of the sample, the sample shall be divided prior to analysis to permit 

compliance with this section. The samples may 

be retained in appropriate form and shall be 

made available to the Board of Review upon request.

6.9 Records

6.9.1 The laboratory shall maintain a record 

system which contains sufficient information to 

permit verification of any issued report.

6.9.2 All laboratory records shall be signed 

and dated by the operator.

6.9.3 The laboratory shall retain all original 

observations, calculations, derived data and calibration records for two (2) years unless a longer 

period is specified.

6.9.4 These records shall be made available 

to the Board of Review on request.

6.10 Test Reports

6.10.1 The laboratory shall issue test reports 

of its work including all of the following information:

 Name and address of the laboratory;

 Name and address of the manufacturer;

 If destination sample, name and address of 

the destination;

 Identification of the test report by serial 

number or other appropriate means; 

 The date the sample was received;

 Identification of standard and grade of densified fuel material being analyzed;

 Description of sample, such as diameter, 

length;

 Date code on the densified fuel sample;

 Description of material;

 Analytical results;

 Signature of an approved signatory; and
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 Any remarks which are considered to be 

significant.

6.10.2 The laboratory shall issue corrections 

or additions to a test report by a document suitably marked which meets the relevant requirements of Section 6.10.1.

6.11 Application Process

6.11.1 Any laboratory is permitted to submit 

an application for laboratory accreditation to the 

Board of Review.

6.11.2 To become accredited, the laboratory 

shall complete an application for accreditation in 

one or more analytical procedures and include 

the following information:

 Legal name and full address of laboratory;

 Ownership of the laboratory;

 Organization chart that is relevant to performing testing covered in the accreditation 

request;

 General description of the laboratory, including its facilities and scope of operation;

 Name and telephone number of the authorized representative of the laboratory;

 A specific list of equipment relevant to the 

analysis for which accreditation is being 

sought;

 Names, titles and qualifications of laboratory 

staff; and

 Other information as required.

6.11.3 Upon receipt of a laboratory's application, the Board of Review shall:

- Acknowledge receipt of application.

- Request further information, if necessary.

- Specify the next step(s) in the accreditation 

process.

6.11.4 Assessing and evaluating a laboratory:

Information used to evaluate a laboratory's compliance with the conditions for accreditation set 

out in Sections 6.3 - 6.10 and the technical requirements established for the review process 

shall include:

 A review and confirmation of information.

 On-site assessment of the laboratory.

 Laboratory responses to identified deficiencies, if any.

 Laboratory performance on proficiency tests.

 Any other procedure judged appropriate by 

the Board of Review.

6.11.5 In evaluating a laboratory for accreditation and ongoing evaluation of an accredited 

laboratory, the Board of Review may utilize consultants, third parties or other entities, such expense to be borne by the applicant agency.

6.12 Granting Accreditation

6.12.1 The Board of Review, after its evaluation of a laboratory, shall grant or propose to 

deny accreditation of an applicant agency no later 

than ninety (90) days following the conclusion of 

the evaluation. If action is not taken within this 

time limit, the Board of Review shall notify the 

agency stating the reasons for the delay.

6.12.2 If accreditation is granted, the Board of 

Review shall:

 Provide a document of accreditation to the 

agency; and

 Identify the scope and terms of the laboratory's accreditation.

6.13 Denying or Revoking Accreditation

6.13.1 If the Board of Review proposes to 

deny or revoke accreditation of an agency or 

laboratory, it shall inform the agency or laboratory of the reasons for the proposed denial or revocation and the procedure for appealing such a 

decision.

6.13.2 Upon receipt of a proposed denial or 

revocation, the agency shall have the option to 

request a hearing by the Board of Review. If a 

hearing is requested the Board shall have the 

option to stay the denial or revocation pending 

the outcome of the hearing.

6.13.3 The proposed denial or revocation shall 

become final through the issuance of a written 

decision to the agency in the event that the laboratory does not correct the deficiency or the 

agency appeal the proposed denial or revocation.

6.13.4 An agency whose laboratory accreditation has been denied, revoked or terminated, or 
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which has withdrawn its application before being 

accredited, may reapply and be accredited if the 

agency and the laboratory complete the assessment and evaluation process and meet the conditions and criteria for accreditation as set forth in 

Sections 6.3 - 6.10.

7.0 INTERPRETATIONS

7.1 The purpose of interpretations is to 

promote consistency in the application and understanding of the provisions of this document. 

Interpretations are occasionally needed to add 

further clarification to the requirements of these 

regulations. An interpretation of the American 

Lumber Standard Committee, Incorporated®

(ALSC) Board of Review Enforcement Regulations may be obtained through the submission 

of a written request to the president.

(a) The written request shall identify the specific section of the Enforcement Regulations 

involved.

(b) The interpretation shall be made by the 

President or his designated staff person in writing.

(c) The interpretation of the President shall 

be distributed to all participants in the ALSC 

Program.

(d) If the interpretation is acceptable to the 

requestor and all participants, the interpretation 

shall be endorsed by the Enforcement Subcommittee at its next scheduled meeting and made 

part of the Enforcement Regulations when ratified by the ALSC.

(e) If the requestor or any participant in the 

program finds the interpretation of the President/Enforcement Subcommittee unacceptable, 

the requestor or any participant may submit a 

written request for an interpretation to be provided by the ALSC. The interpretation approved 

by the Enforcement Subcommittee shall be subjected to a ballot of the full ALSC within 30 days. 

If approved by the ALSC, the interpretation shall 

be distributed to all participants and with copies 

of the Enforcement Regulations.

(1) Any ALSC members voting negative on 

the proposed interpretation must provide 

written justification for their negative vote, 

together with a recommended revision if 

possible. All negative ballots shall be considered by the Enforcement Subcommittee.

(2) The Enforcement Subcommittee shall 

attempt to resolve all negative ballots 

deemed persuasive. The Enforcement Subcommittee shall make a recommendation for 

the disposition of all negative ballots to the 

ALSC in the form of a ballot.

(3) The ballot shall provide three response 

options:

 Approve the Subcommittee recommendation.

 Disapprove the Subcommittee recommendation.

 Abstain.

(f) If a majority of the ALSC does not approve the recommendation of the Enforcement 

Subcommittee, the matter shall be referred back 

to Enforcement Subcommittee for further consideration. If the negative cannot be disposed

of, it shall be placed on the Agenda for the next 

ALSC meeting for resolution.

(g) A complete record of all interpretations and committee actions on interpretations 

shall be maintained at the offices of the ALSC 

and shall be fully available upon written request 

to the ALSC President.

8.0 ADDITIONAL PROCEDURES

8.1 Additional procedures for this densified 

fuel program shall be adopted as needed by the 

American Lumber Standard Committee.