### AMERICAN LUMBER STANDARD COMMITTEE, INCORPORATED ®



### RESIDENTIAL/COMMERCIAL DENSIFIED FUEL

ENFORCEMENT REGULATIONS

November 2, 2012TABLE OF CONTENTS

1. INTRODUCTION

................................ ................................ ................................ ................. 3

2. STANDARDS AND TES T PROCEDURES

................................ ................................ ............... 3

3. RESIDENTIAL/COMMERIC AL DENSIFIED FUEL MA NUFACTURERS QUALIFIC ATION

....... 4

4. INSPECTION AGENCY AC CREDITATION

................................ ................................ ........... 4

5. FUNCTIONS OF THE BOA RD OF REVIEW

................................ ................................ ......... 11

6. LABORATORY ACCREDITA TION

................................ ................................ ...................... 12

7. INTERPRETATIONS

................................ ................................ ................................ .......... 16

8. ADDITIONAL PROCEDURE S

................................ ................................ ............................. 16American Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 3

1. INTRODUCTION

1.1 General

1.1.1 This program is inten ded to establish a common basis for uniform, industry

- wide inspe ction and quality marking procedures for reside ntial or commercial densified fuels produced in accordance with the provisions hereof.

1.2 Covered Products

1.2.1 These regulations are applic able for the determination of fuel quality grade for densified fuel products as defined in the Pellet Fuels Inst itute (PFI) Stan

dard Specifications for Residential/Commercial Densified Fuel

.

2. STANDARDS AND TEST PROC EDURES

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 verific ation 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 monito r the above standards shall be those approved by the Board of Review.

2.4 Board of Review activities involves

ver i fication 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 minimi s 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 esta blished 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 Densi fied Partic

ulate Biomass Fuels as modified by PFI Standard Specifications for Residential/Commercial Densified Fuel

.

Chemically Treated Materials

– With the exce ption 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, su rface coating or other finish, or any other chemical compound. Trace amounts of grease or other lubricants that are introduced into the fuel pr ocessing str eam as part of the normal maint enance operations are not considered as chemica lly 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

E711 Standard 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

.American Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 4

Laboratory

- Any laboratory, not owned or ope rated by a densified fuel manufacturer, that is affiliated with or contracted by one or more i nspection a gencies to perform analyses on dens ified 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 speci fic 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 organiz ation.

Moisture

– The moisture content of the as

received 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,

s tandards 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 accre dited by the Board of Re view 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 produ cing any portion of the densified fuels inspe cted and tested. The quality control agency shall not be owned, operated or controlled by any such

company.

Quality Mark

- The m ark of the Pellet Fuels Inst itute in conjunction with an agency accredited by the Board of Review indicating product confor man ce 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 b een met by both the manufa cturer and the quality control agency which licen ses the use of the mark by densified fuel manufa cturers.

Traceability of the Accuracy of Measuring Instr uments

- A documented chain of comparison co nnecting the accuracy of a measu ring instrument to other measuring instruments of higher accur acy and ultimately to a primary standard.

3. DENSIFIED FUEL MANUFACTURER QUALIFICATIONS

3.1 Manufacturer Equipment

-- Must comply with Section 6.8

-- Equipment and O pera ting Process es requirements outlined within PFI Residential/Commercial Densified Fuel QA/QC

Handbook

.

3.2 Manufacturer Records

3.2.1 Each manufacturer shall maintain re cords 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 qual i ty control procedures shall be performed to a degree that assures compliance of the densified fuel product to the PFI Standard Specification for Residential/Com

mercial Densified Fuel standard and other applicable documents. Production

found non

- conforming to the fuel grade requir ements shall have its quality mark obliterated or relabeled with a quality mark of the next lower fuel grade provided the production me ets all the requirements of the lower fuel grade.

3.5.2 Management shall appoint an ad equately trained employee as manufacturer quality manager. He shall be vested with the authority to correct any condition causing a non

- conformance, to remove the qualit y 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 ACCRE D I-American Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 5

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 a ccordance 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 qual ity control and inspection procedures for the sp ecific densified fuel, which it insp ects, and which are covered by the PFI Standard Specification for Residential/Commercial Densified Fuel standard and other applicable documents.

(b) Demonstrates initial and continuing comp etency and reliability in the field of the densified fuel inspecti on.

(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 fo rward 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 appl ying agency shal l be responsible for the fees e sta b lished to cover expenses incurred in conduc ting the qualification, including the cost of accred itation 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 ev idence 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 certific ation 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 ind ependent 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 densif ied fuel he/she inspects. I nspectors shall be directed by a chief inspector, supervisor or manager who is thoroughly exper ienced in the inspection of densified fuel pro d ucts and who shall be held responsible for the proper functioning of the members of th e inspe c tion

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 do cuments and agency quality control and inspection procedures . The agency shall perform sampling and testing of a manufactu rer’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 inspe ction then a minimum of 1 sample shall be co llected and tested , if available . The agency’s samples shall be representative of a manufa cturer’s production for the period elapsed b etween inspections. Wr itten reports of each i nspection shall be made to the manufacturer and copies shall be kept available by the agency for examination by the Board of Review or its repr esentative upon request. The agency shall also have available conforming reports from an ALSC accredited laboratory for the densified fuel sa mpled during the agency inspection. These re cords 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 oblig ation of the manufacturer toAmerican Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 6

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 s ample 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 low er 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 En forcement 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 unifor mly requiring its inspectors to determine confor mance to all applicable specifications before i s suing a certificate thereon or marking the dens i fied 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 inspe ction staff to assure not only th e continuing hone sty and competency of its members, but co nsistency 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 twelv e 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 pr ocedures 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 Regul ations. If deficiencies are found in the review of

an a gency's quality control and inspection proc edures, the deficiencies shall be brought to the attention of the agency. The agency shall have the option of amending the procedures to co nform or requesting a hearing before the Board of

Review.

4.3.10 An agen cy shall agree to have its qual ity control and inspection procedures carry a sp ecific 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 an d ot her applicable documents.

4.3.11 Agencies shall agree to permit republ ication of their quality control and inspection pr ocedures in whole or in part without charge with all quoted parts clearly so indicated. The republ ication 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

proc edures have been approved by the Board of Review, subsequent revisions shall be proposed by the promulgating agency to the Board of R eview for approval.

4.3.13 Security and Contracts. The Board of Review shall require as a condition to its accred itation o f any agency the payment when due of all charges and fees assessed by the ALSC to coverAmerican Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 7

the cost of carrying out its functions and the

reimbursement to the ALSC for all costs and e xpenses incurred by the ALSC or its Board of R eview in any investigation of the activities or pra ctices of the agency, whether or not the investig ation is initiated by the ALSC or its Board of R eview or upon complaint. The Board of Review shall require that each accredited agency execute

a contract with the ALSC in such form and co ntaining 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 submi t to it for approval, a form of contract which each agency shall require the subscribing densified fuel man ufacturer to execute. Accredited agencies shall maintain copies of contracts executed with each densified fuel manufacturer receiving their se rvices 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 u nder these Enforcement Regulations, the agency shall immediately notify the Board of Review in writing.

4.4 Agency Accreditation for Manufa cturer Supervisory Service and/or Inspe ction 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 appl icant shall also submit, as applicable to the se rvice(s) offered, complete information about the manufacturers under its supervision, the produ ction volume of the manufacturers, p rograms for which supervision will be offered, programs for which lot inspection services will be offered, pr ocedures for handling requests for inspection, adequate provisions for supervision of manufa cturers quality control, supervision of manufactu rers performance, authority to apply the agency's quality mark and evidence that all applicable requirements of the PFI Standard Specification

for Re sidential/Commercial Densified Fuel stan dard and other applicable documents are being met by the agency and its manufacturers.

4.4.2 Before accrediting the inspection se rvice(s) of any agency, the Board of Review shall require evidence that it conforms to all the r equirements 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 proc edures, thes e Enforcement Regulations and all applicable requirements of the PFI Standard Spe c ification 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 ap plication 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. Applic ation of the quality mark of agencies a pproved 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 inspe ction 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 I nspector on a certificate inspe ction shall be ide nt i fied 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 complyin g densified fuel products by any ma nufacturer which subscribes through the agency toAmerican Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 8

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 stan dard 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 a ccredited 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 misrepresen ted 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 qua lity mark shall be provided with commercial do cuments.

4.6.6 The following minimum information is required to be on a quality mark whether stamped, labeled or branded:

 Registratio n number

 

### D ensified 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 accre diting agency and the Pellet Fuels Institute

4.6.7 Quality marks of accredited agencies shall be uniform in providing the required info rmation and shall be legible when placed on a densified fuel product.

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

Rev iew. 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 confu singly or deceptively similar to the quality marks of any ALSC a ccredited agency, including, but not limited to, reference to the PFI Standard Specification for Residential/Commercial Densified Fuel standard or other applicable do c uments directly or indirectly.

4.6.10 It is the policy of the Committee that

densified fuel ma nufacturer quality marks, grade marks, grade stamps, labels, brands, certificates or other product description shall not misrepr esent densified fuel products, including, but not limited to, reference to the PFI Standard Specification for Residential/Commer cial Densified Fuel standard or other applicable documents directly or indirectly.

4.6.11 Each accredited agency shall be r esponsible for the control of its quality marks. Quality marks shall only be used at manufactu rers or by personnel authorized by a ccredited agencies. Accredited agencies shall require a participating manufacturer to provide care and security of the agency quality marks. An accre dited agency shall retain on file a facsimile of each quality mark issued, require worn out or discar ded quality marks to be destroyed, and require missing or stolen quality marks be r e ported 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 wr itten 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 a pproved quality mark unreadable or clearly inappl icable. Examples of obliteration of the a p proved mark or stamp include, but are not limited to removal by over

- stamping with opaque indel i ble ink or paint applied in a solid block, multiple ‘x’ stamp or other means of over

- marking. Mar k ing through the approved quality ma rk with a semi

transparent ink, paint, or crayon which a l lows full, though possible reduced visibility of the approved quality mark does not constitute oblit e ration.

4.7 Warnings, Suspensions and Wit h-American Lumber Standard Committee, Incorporated ®

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drawals

4.7.1 Accredited agencies shall withdraw quali ty 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, su spends or withdraws the quality marking services at any manufacturer for cause, supplying all pe rtinent details. Upon receipt of such notice, the Manager of the Board of Review shall immediat ely notify by letter all other accredited agencies extending services in the area. No o ther 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 th e 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 qua lity marking supervisory se rvices only after the manufacturer involved demonstrates the ability and willingness to mai ntain the applicable requirements of the agency's quality control and inspection procedures, these

E n forcement Regulations and the PFI Sta ndard 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 specific ations and effecting settlement of complaints and

invoices.

4.8.2 Reinspection shall be performed i n 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 inspec tion 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 necess ary. The reports shall include, among other things,

information as follows:

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

of densified fuel involved.

4.9.2 Reinspection of densified fuel products originally grade d by the agency or marked with an agency's quality mark during a particular per iod 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 locati on of the co n signee, date of reinspection, item(s) and quant i ties 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 exa mination 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 t he 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 manufa cturer or destination points, for the purpose of checking the performance of the agency, its i nspectors and the general reliability of its service.American Lumber Standard Committee, Incorporated ®

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4.11.2 Board of Review staff personnel shall have the right to e xamine 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 superv isory 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 deficie ncies by the same inspector or plant. Each agency shall also agree that serious deficiencies, when found, shall r equire 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 pr oduced by each accredited agency's manu factu rers. The manufacturers included in each survey

shall be selected at random and shall be of suff icient number to be deemed representative of the total quantity of densified fuel produced under an accredited agency's authority. The results of

the r andom 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 r equest the agency to take corrective action with

the manufacturer or agency employee involved to prevent a recurrence of the infraction. The age ncy shall reply stating in detail the corrective a ctions taken, and shall continue to make such reports until such time as it is satisfied that a

recurrence of the infraction i s unlikely and it not ifies the Board of Review that it is satisfied. A ppropriate 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 exte nt possible co nfirm 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 reli ability of an agency.

4.13.2 Board of Review Requested Reinspe ction

(a) Destination : Upon finding that a given shipment of densified fuel that is quality marked and/or certified appears to contain serious infra ctions, the B oard of Review inspector without divulging detailed information to the customer shall request the material be held for reinspe ction. The inspector shall immediately notify his

office with full details of the infraction. The office

of the Board of Review s hall 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 c ustomer agrees to hold the stock and furnish labor if ne cessary (for which he shall be reimbursed by the agency) and further agrees to assess no holding charges for the densified fuel held for reinspe ction.

The agency shall furnish results of the reinspe ction 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 E nforcement Regulations, the shipping manufactu rer 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 r equest 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 manag ement and confirm that the material is to be heldAmerican Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 11

for review by the agency. The agency shall r eview the material being held and determine the appropriate action and shall promptly report the

act ions taken to the Board of Review. Any man ufacturer 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 t he 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 proc edure is not followed, the ALSC report stands.

4.14 Board of Review Destination I nspections

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 o r Revocation of Agency Accreditation : The Board of Review shall judge the continued competency, reliability, ad equacy and integrity of accredited agencies under these Enforcement Regulations. The Board of Review, after reviewing the competency, adequ acy, integrity and performance of an agency, shall take any of the following actions as in the jud gment 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 ap proval 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 contai ned 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 prob ation, suspension or revocation by the Board of Review shall be made p ublic.

4.15.2 Board of Review Procedures : Before any agency is placed on probation or its accred itation 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 Boar d and the agency shall be a fforded 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, suspen ding or revoking the accreditation of an agency shall be taken on the basis of evidence intr oduced 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 th e 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 th at agency shall thereupon lapse and terminate, unless the agency shall establish grounds for continuance of its accreditation. Lapse and termination of a ccre d itation shall not prejudice later application for

accreditation.

5. FUNCTIONS OF THE BOARD OF

REV IEW

5.1 Inspection Visits

Inspections shall be performed by the field staff of the Board of Review for the purpose of mon itoring agency performance. Four types shall be made. They are as follows:

(a) Random Sample Survey Inspections (b) General Inspec tions (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 beAmerican Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 12

obtained at each manufacturer and the number of samples taken at any manufacturer included i n a survey shall be dependent on the manufactu rer'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 ar eas.

5.1.4 Recall Inspections: Where serious deficiencies are found at a manufacturer during a random sample survey inspection, at a destin ation 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 dens ified fuel production facilities are manufa c turing
fuel in accordan ce 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 du ring any Board of Review inspection, the agency shall be notified immediately. It shall be the obligati on of the agency to take immediate co rrective 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 gro ups of records shall be among

those checked:

5.3.1 Records pertaining to agency superv ision of its own inspection staff, including records of initial inspector training and continuing inspe ctor training, records of the correction of deficie ncies in indivi dual inspectors, records showing specific qualifications of individual inspectors and records showing assignments of individual inspe ctors. 5.3.2 Records pertaining to manufacturer inspections including results of samples taken during manufacturer inspect ions. Records of procedures for application of the quality mark. Records of frequency of manufacturer inspe ctions.

5.3.3 Records pertaining to the correction of deficiencies, found by agency inspection at man ufacturers and destination sites and their sa tisfa ctory correction and records of reinspection ge nerated 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, compete ncy 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 Sec tion 4

and all other information available to it.

5.6 Quality Control Laboratory A ccre d itation

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 S ection 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 accred itation of laboratories that provide service to i nspection agencies under this program.American Lumber Standard Committee, Incorporated ®

Residential/Commercial Densified Fuel Manufacturers Enforcement Regulations November 2, 2012 Page 13

6.1.2 Labo ratory 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 o r its represent ative 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 Accredit ation

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 accred ited 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 a ccreditation is granted;

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

 Render all test reports objectively and wit hout bias;

 Report to the Board of Review thirty (30) days prior to any major changes involving the

locati on, 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 re ason 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 noteb ook), which is available for use by laboratory staff. A person(s) shall be ide ntified 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

me thod.

 Sample control procedures including a sy stem for sample identification.

 Instrument calibration records.

 Specific procedures for each accredited test including use of reference standards and co ntrol charts, interlaboratory testing proc edures, and proc edures for retesting where

necessary.

 Procedures for corrective actions for suspec ted test discrepancies.

 Quality management responsibilities for each procedure in the laboratory.

 Detailed training procedures for new or rea ssigned employees.

 Procedures for dealing with disputed tests.

6.4.4 The laboratory shall periodically review its internal procedures by or on behalf of ma nagement to ensure its continued effectiveness.

These reviews shall be recorded with details of any corrective action taken.

6.5 Sta ff

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 respo nsibility for the technical operations of the labor atory.

6.5.3 The laboratory shall have one or more signatories to sign test reports. Approved signat ories shall be competent to make a critical evalu ation of test results; and shall occupy positions within the laboratory's organization which make

th em responsible for the adequacy of test results.

6.6 Facilities and Equipment

6.6.1 The laboratory shall be furnished withAmerican Lumber Standard Committee, Incorporated ®

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all items of equipment and facilities for the co rrect performance of the tests and measurements for which accreditation is granted.

6.6.2 All equipment shall be properly mai ntained 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 rep aired. 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, identif ication, 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 referenc e.

6.7 Calibration

6.7.1 All new test and measuring equipment shall be calibrated according to the manufactu rer's recommendations before putting it into se rvice.

6.7.2 Maintain records of all calibrations and

recalibrations.

6.7.3 Document the source o f all calibration

and reference standards. When the use of standards is not applicable, the laboratory shall

pr o vide satisfactory evidence of the accuracy or reliability of test results (e.g., by participation in a suitable program of interlaboratory comp arison).

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 s ample 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 analytic al procedure e m ployed results in the destruction of the sample, the sa mple 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 r equest.

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 shal l retain all original observations, calculations, derived data and cal ibration 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 lab oratory shall issue test reports of its work including all of the following info rmation:

 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 repor t by serial number or other appropriate means;

 The date the sample was received;

 Identification of standard and grade of dens ified fuel material being analyzed;

 Description of sample, such as diameter, length;

 Date code on the densified fuel sample;

 Descr iption of material;

 Analytical results;

 Signature of an approved signatory; andAmerican Lumber Standard Committee, Incorporated ®

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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 suit ably marked which meets the r elevant requir ements 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 f or 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 pe rfor m ing testing covered in the accreditation

req uest;

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

 Name and telephone number of the autho rized representative of the laboratory;

 A specific list of equipment relevant to the analysis for which accreditation is bei ng sought;

 Names, titles and qualifications of laboratory staff; and

 Other information as required.

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

- Acknowledge receipt of application.

- Request further information, if nece ssary.

- Specify the next step(s) in the accreditation

process.

6.11.4 Assessing and evaluating a laboratory:

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

out in Sections 6.3

- 6.10 and the technical r equirements established for the review process

shall include:

 A review and confirmation of information.

 On

- site assessment of the laboratory.

 Laboratory responses to identified deficie ncies, if any.

 Laboratory performance on proficiency tests.

 Any other pr ocedure judged appropriate by

the Board of Review.

6.11.5 In evaluating a laboratory for accred itation and ongoing evaluation of an accredited laboratory, the Board of Review may utilize co nsultants, third parties or other entities, such e xpense to be bor ne by the applicant agency.

6.12 Granting Accreditation

6.12.1 The Board of Review, after its evalu ation 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 e valuation. 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 laborat ory's accreditation.

6.13 Denying or Revoking Accredit ation

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 laborat ory of the re asons for the proposed denial or rev ocation 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 th e 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 l aboratory does n ot correct the deficiency or the agency appeal the proposed denial or revocation.

6.13.4 An agency whose laboratory accredit ation has been denied, revoked or terminated, orAmerican Lumber Standard Committee, Incorporated ®

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which has withdrawn its application before being accredited, may reapply and be ac credited if the agency and the laboratory complete the asses sment and evaluation process and meet the cond itions 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 cons istency in the application and u nderstanding 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, Inc orporated ®
(ALSC) Board of Review Enforcement Regul ations may be obtained through the submission of a written request to the president. (a) The written request shall identify the sp ecific section of the Enforcement Regulations

involved. (b) The interpretat ion shall be made by the President or his designated staff person in wri ting. (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 participant s, the interpretation shall be endorsed by the Enforcement Subco mmittee at its next scheduled meeting and made part of the Enforcement Regulations when rat ified by the ALSC. (e) If the requestor or any participant in the program finds the interpretation of the Pres ident/Enforcement Subcommittee unacceptable, the requestor or any participant may submit a written request for an interpretation to be pr ovided by the ALSC. The interpretation approved by the Enforcement Subcommittee shall be su bjected 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 consi dered by the Enforcement Subcommittee. (2) The Enforcement Subcommittee shall

a t tempt to resolve all negative ballots deemed persuas ive. The Enforcement Su bcommittee 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 recomme ndation.

 Disapprove the Subc ommittee reco mmendation.

 Abstain. (f) If a majority of the ALSC does not a pprove the recommendation of the Enforcement Subcommittee, the matter shall be referred back

to Enforcement Subcommittee for further co nsideration. 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 interpret ations and committee actions on interpretations

shall be maintained at the offices of the ALSC and shall be fully available upon written r equest
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.