Section 1728.202 - Bulletin 1728H-702, Specification for Quality Control and Inspection of Timber Products(a)Scope.(1) The specification in this section describes the responsibilities and procedures pertaining to the quality control by producers and pertaining to inspection of timber products produced in accordance with the following RUS specifications in § 1728.201 , and poles, covered in Bulletin 1728F-700 (incorporated by reference in § 1728.97 ) and in § 1755.97 of this chapter.(2) Where there is conflict between the specification in this section and any other specification referred in this section, the specification in this section shall govern.(3) The specification in this section also describes and designates responsibilities of RUS borrowers in regard to their purchases under the specifications referenced in paragraph (a)(1) of this section.(b)General stipulations.(1) Conformance of poles and crossarms to RUS specifications is the responsibility of the producer. A member of the producer's staff shall be designated as quality control supervisor and charged with the responsibility for the exercise of proper quality control procedures throughout the production process. The primary responsibility of third party inspection agencies is to verify that producers involved in the manufacture of RUS treated wood products have functional in-house quality control systems in place that result in the shipment of materials meeting applicable RUS specification requirements to borrowers.(2) The requirements of AWPA M3 (incorporated by reference at § 1728.97 ), pertaining to recordkeeping, pretreatment storage, analytical laboratories, plant gauges, and other plant facilities, shall be followed.(3) Treated wood products intended for RUS borrowers shall not be inspected when in the opinion of the inspector, unsafe conditions are present.(4) Poles and crossarms can be purchased under either of two purchase plans; a RUS approved Quality Assurance Plan or an Independent Inspection Plan. The method of inspection described in this section shall be used no matter which plan timber products are purchased under.(5) Under the Independent Inspection Plan, the borrower should designate in the purchase order which inspection agency it has selected. Unless the borrower contracts for inspection as a separate transaction, the treating company shall obtain the services of the borrower's designated inspection agency. For reserve treated stock held in inventory by the producer, the producer shall obtain the services of the appropriate inspection program.(6) All third-party inspectors involved in the inspection of RUS products shall maintain their impartiality when providing their inspection service. This requires that these individuals and their employers, as well as producers and suppliers involved in providing RUS borrowers with treated wood products, maintain the greatest degree of professional separation during the performance of their respective functions to eliminate any possible conflict of interest.(7) With the exception of financial agreements for inspection services, inspection agencies shall not accept nor provide gratuities or free services to suppliers.(8) Inspection agencies shall not offer product warranties on inspected material.(9) Inspection agencies shall have and maintain liability insurance in the amount of $500,000 and a surety bond or miscellaneous Errors and Omission insurance for consequential damages for not less than $250,000. Evidence of compliance to the requirement in this paragraph (b)(9) shall be forwarded to the RUS annually. The evidence shall be in the form of a certificate of insurance or a Bond signed by a representative of the insurance or Surety Bonding company and include a provision that no change in, or cancellation of, will be made without the prior written notice to Chairman, Technical Standards Committee "A" (Electric).(10)(i) Inspection agencies shall maintain their own properly equipped laboratory that, at a minimum, is able to run the referee methods listed in table 1 to this paragraph (b)(10) for retention analysis for all preservatives being inspected. This laboratory shall be independent from any treating plant laboratory. Inspection Agencies may use one central laboratory. All XRF units maintained by third party inspection agencies as part of their RUS required laboratories shall be calibrated at least quarterly by said agency utilizing the referee method for each preservative treatment being analyzed or via comparison with a set of graduated treated wood standards. Each agency shall keep an up-to-date written record of these quarterly calibration results. Table 1 to Paragraph (b)(10)(i)
| Preservative | Analytical method | Referee method |
| Pentachlorophenol | XRF, Lime Ignition, Copper Pyridine | Lime Ignition, Copper Pyridine. |
| Creosote | Toluene Extraction | Toluene Extraction. |
| Waterborne | XRF | XRF. |
| Copper Naphthenate | XRF | ICP, GC. |
| DCOI | XRF, HPLC | HPLC. |
Note 1 to table 1 to paragraph (b)(10)(i): XFR means X-ray fluorescence; HPLC means High Performance Liquid Chromatography; ICP means Inductively coupled plasma; and GC means Gas Chromatography.
(ii) Inspection agencies shall, on an annual basis, provide RUS Technical Standards Committee "A" with proof that the agency does have the required, fully equipped laboratory capable of running each of the referee methods of analysis as illustrated in table 1 to paragraph (b)(10)(i) of this section. AWPA A83 or AWPA A9 (both incorporated by reference at § 1728.97 ) shall be followed for Pentachlorophenol testing.(iii) AWPA A30 (incorporated by reference at § 1728.97 ) or AWPA A9 shall be followed for DCOI testing. AWPA A6 (incorporated by reference at § 1728.97 ) shall be followed for Creosote testing and AWPA A9 shall be followed for XRF, as illustrated in table 1 to paragraph (b)(10)(i) of this section.(11) If used for analysis, plant XRF units shall be accurate and generate reproducible results per AWPA A9. At least once monthly, their accuracy and precision shall be checked by the third-party inspector. This verification shall consist of the inspector taking a retention sample previously analyzed by the plant quality control supervisor on-site and rerunning it in the inspection agency's own laboratory using said agency's XRF unit or the referee method for a specific preservative. If the inspection agency's analytical result is within +5% of the plant's retention result on that sample, the plant XRF unit needs no further calibration.(12) Individual inspectors in the employ of inspection agencies shall be properly trained and experienced. See § 1728.203 , for details of an inspector's minimum qualifications. Upon request, inspection agencies must provide RUS with detailed written documentation verifying that each of their employees inspecting RUS materials has the minimum experience and training described in § 1728.203 . Failure of an individual inspector to follow proper procedures or failure of an inspection agency to properly train and supervise their inspectors or follow applicable RUS specifications constitutes grounds for RUS debarment of said inspector and said inspection agency from future inspection of RUS financed material.(c)Quality control and inspection procedures. It is the responsibility of the plant quality control supervisor to perform the following procedures to ensure that a particular lot of material conforms to the requirements of the applicable Agency specification prior to treatment. After the plant quality control supervisor has performed these procedures, a particular lot of material shall be released to the inspector for verification of conformance.(1) For poles, inspection prior to treatment shall include:(i) Ample space and assistance shall be provided by the treating plant for handling and turning poles. Regardless of the purchase plan poles are being purchased under, all poles in a lot shall be inspected by the plant quality control supervisor prior to offering the lot for verification by a third party.(ii) When limited by the purchaser in a written purchase order, moisture content shall be measured with a calibrated electronic moisture meter. Calibration of the moisture meter shall include not only the zero settings for the X and Y readings, but also two resistance standards for 12 and 22 percent moisture content. Material failing to conform for moisture content may be retested upon request after recalibration of the moisture meter.(iii) Dimensions, length, and circumference shall be measured by a standard steel tape to determine that they meet specification requirements and that they agree with the details for class and length found in the face brand/tag and butt of each pole. If it is obvious by visual comparison with a measured pole that the brand information regarding class and length is correct, individual poles need not be measured. Pole circumference dimensions measured prior to treatment shall govern acceptance. Reduction in dimension due to treatment and shipping shall be no more than 2 percent below the minimum for the pole class.(iv) Poles in a lot shall be of the same seasoning condition and all shall be inspected for decay. If the plant quality control supervisor suspects that decay is present in a pole, a slice from both ends shall be cut for closer examination. If 3 percent or more of the poles in the lot inspected by the plant quality control supervisor show evidence of decay, the entire lot shall be unconditionally withdrawn without further sorting.(v) Under the Independent Inspection Plan, all poles shall be examined by the third-party Inspector for verification of conformance. Under a RUS approved Quality Assurance Plan, the number of poles inspected for verification of conformance may vary according to the terms of the approved plan.(vi) Whenever it becomes evident during third party inspection of any lot of poles offered by the producer that non-conforming pieces exceed 3 percent for any one defect or 5 percent for all defects, the inspector shall withhold further inspection and reject the balance of the lot. After the producer has acted to eliminate all defective pieces, the rejected balance may be inspected as a new lot. Sorting, however, shall not be permitted when a lot has been rejected for decay.(vii) Re-examination for mechanical damage or deterioration and for original acceptance shall be conducted on timber products not treated within 10 days after the original third-party inspection.(2) For crossarms, inspection prior to treatment shall include:(i) Regardless of the purchase plan arms are being purchased under, all arms in a lot shall be inspected by the plant quality control supervisor prior to offering the lot for verification by a third party. After the plant quality control supervisor has performed the procedures in paragraphs (c)(2)(ii) through (vii) of this section, a particular lot of arms shall be released to the inspector for verification of conformance.(ii) Moisture content of the arms in the lot shall be checked with a calibrated moisture meter.(iii) Surface inspection of both ends and the side surfaces of each arms. Particular attention shall be paid to visible defects such as compression wood, red heart, honeycomb and other forms of decay, shakes, splits, through checks, low density, wane, undersize, and pitch pockets.(iv) Inspection of bolt and insulator pin holes for proper location, dimension and excessive splintering.(v) Inspection of brands for proper location, required content and legibility.(vi) Under the Independent Inspection, both ends of all crossarms and a random representative sample of the lengthwise side faces of all crossarms shall be inspected. The sample size shall equal 20 percent of the lot size or 200 arms, whichever is smaller. Under a RUS approved Quality Assurance Plan, the number of crossarms inspected for verification of conformance may vary according to the terms of the approved plan.(vii) Whenever it becomes evident during third party inspection of any lot of arms offered by the producer that non-conforming pieces exceed 2 percent of the sample size, the entire lot shall be rejected. After the producer has acted to eliminate all defective pieces, the rejected balance may be inspected as a new lot.(d)Preservatives. Creosote, waterborne preservatives, pentachlorophenol, DCOI, and copper naphthenate shall conform to current AWPA U1 (incorporated by reference in § 1728.97 ) .(e)Results of treatment-Poles.(1) Following treatment, poles shall be sampled for preservative retention and penetration utilizing a calibrated increment borer 0.2 inches +0.02 inches in diameter in accordance with procedures listed in AWPA M2 (incorporated by reference in § 1728.97 ) .(2) Inspectors may take their own retention samples and analyze them concurrently with those taken by the quality control supervisor, but each shall work independently. The results of the plant's analysis shall be presented before verification and acceptance of the charge by the third-party inspector.(3) Unless otherwise specified, borings shall be taken from the section of the pole extending from 1 foot below the face brand/tag to 1 foot above the face brand/tag. For pressure treated Western Red Cedar, Alaska Yellow Cedar and all butt treated poles, borings shall be taken from the section of the pole approximately 1 foot below groundline.(4) For all species, core samples shall be taken from 20 poles in charges of 20 or more poles. If a charge consists of less than 20 poles, each pole shall be bored and then individual poles shall be bored a second time to obtain a minimum of 20 core samples. Any additional borings required to obtain the required 20 core samples shall be taken in a manner that represents the lot of material with respect to variations in size, seasoning condition, or other features that may affect the results of treatment.(5) Retention and penetration samples shall consist of borings representative of pole volumes for each class and length in the charge, as illustrated in the following table: Table 2 to Paragraph (e)(5)
| Number of poles | Class/length | Vol. in ft3 | % of total vol. | Number of borings2 |
| 20 | 5/40 | 550 | 22 | 4 |
| 30 | 4/40 | 840 | 34 | 7 |
| 20 | 4/45 | 510 | 20 | 4 |
| 20 | 3/45 | 600 | 24 | 5 |
| Total | | 2,500 | | |
Note 2 to table 2 to paragraph (e)(5): Retention and penetration requirements for each different species and preservative are listed in Table 8 of Appendix A, RUS Bulletin 1728F-700, Specification for Wood Poles, Stubs and Anchor Logs (incorporated by reference at § 1728.97 ) .
(6) Preservative retention analyses shall be performed per the standard AWPA U1, (incorporated by reference at § 1728.97 ) .(7) Penetration compliance of both poles and crossarms shall be determined in accordance with the standard AWPA A15 (incorporated by reference at § 1728.97 ) . Chrome Azurol S shall be used to determine the penetration of copper containing preservatives AWPA A69 (incorporated by reference at § 1728.97 ), Penta-Check shall be used to determine the penetration of penta AWPA A70 (incorporated by reference at § 1728.97 ), and Red-O dye for penetration of DCOI AWPA A71 (incorporated by reference at § 1728.97 ), respectively.(8) All bored holes created by penetration and retention sampling shall be promptly filled with tight fitting treated plugs.(9) Penetration sampling of poles shall be carried out as follows:(i) Group A poles (Those poles with a circumference of 37.5 inches or less at 6 feet from butt.):(A) Bore 20 poles or 20 percent of the poles in the charge, whichever is greater. Accept all poles in the charge for penetration if every boring in the sample conforms. If any sample fails penetration, bore all poles in the charge.(B) If more than 15% of the poles in the charge are found to be nonconforming, the entire charge shall be retreated. If 15% or less are found to be nonconforming, remove and retreat only those that are nonconforming.(ii) Group B poles (Those poles with a circumference greater than 37.5 inches at 6 feet from the butt.):(A) For Group B poles 45 feet and under, bore each pole in the charge. If more than 15% of these poles are found to be nonconforming, the entire charge shall be retreated. If 15% or less are found to be nonconforming, remove and retreat only those that are nonconforming.(B) For Group B poles 50 feet and over, bore each pole twice at 90 degrees apart and accept only those poles conforming to penetration in both borings.(iii) Nonconforming poles may be treated only twice. The letter "R" shall be added to the original charge number in the butts of all poles that are retreated. Poles failing to meet treatment requirements after two retreatments shall be permanently rejected and all brand and butt information removed.(f)Results of treatment-Crossarms. Retention and penetration samples shall be taken from not less than 20 crossarms in each charge. The sampling method and retention and penetration requirements for both Douglas-fir and Southern Yellow Pine crossarms are listed in § 1728.201 .(g)Product acceptance.(1) Third party inspectors shall verify their acceptance of untreated poles that have been offered by the producer as conforming by marking each accepted piece in the tip with a clear, legible hammer stamp. Following treatment, inspectors shall verify their acceptance of treated poles that have been offered by the producer as conforming by marking each accepted piece in the butt with a clear, legible hammer stamp. Inspection marks are not to be placed in the butt surfaces of any poles prior to treatment and proper retention analysis and penetration testing being completed. The inspector shall personally mark each piece for acceptance and shall not delegate this responsibility to any other individual.(2) Third-party inspectors shall verify their acceptance of untreated crossarms that have been offered by the producer as conforming by marking each accepted piece in one end with a clear, legible hammer stamp. Following treatment, inspectors shall verify their acceptance of treated crossarms that have been offered by the producer as conforming by marking each accepted piece in the opposing end with a clear, legible hammer stamp. The inspector shall personally mark each piece for acceptance and shall not delegate this responsibility to any other individual.(3) Each inspector or inspection agency shall retain for a period of at least one year a copy or transcript of each pre-treatment inspection report and a copy of analytical worksheets covering retention and penetration test results for each treated charge of material inspected. On request, a copy or transcript of these reports shall be furnished to the Chairman, Technical Standards Committee "A", Rural Utilities Service, Washington, DC 20250-1569.(i) On each inspection report the third-party inspector and the plant quality control supervisor shall certify in writing that the material listed on the report has been properly inspected both before and after treatment and that the preservative used met the requirements of this section. Inspection reports shall also include the following information: (A) Conditioning details of the material prior to treatment.(B) Total number of pieces offered by the producer.(C) Number of pieces rejected by the inspector, cause for rejection.(D) Copy of preservative analysis (usually supplied by the preservative supplier).(E) Treating sheet containing details of treatment for each charge.(F) Separate worksheets for retention analyses done by the plant quality control supervisor and by the inspector.(G) Penetration result on each individual core boring taken from poles in the charge.(h)Laminated materials.(1) All lumber used to fabricate laminated materials shall be inspected and its grade verified by a qualified lumber grader, then marked appropriately.(2) Laminated materials shall comply with manufacturing requirements specified in ANSI O5.2 (incorporated by reference at § 1728.97 ) . Melamine urea adhesives shall not be used. Plant quality control procedures and any third-party inspection shall be conducted in accordance with AITC 200 (incorporated by reference at § 1728.97 ), and § 1728.201 (Bulletin 1728H-701).(3) Following treatment, laminated material shall be checked for proper preservative retention and penetration, and for any evidence of delamination. All conforming laminated materials shall be clearly marked with either an American Institute of Timber Construction (AITC) or American Plywood Association (APA) quality stamp.(i)Safety provisions. Poles intended for agency borrowers shall not be inspected when, in the opinion of the inspector, unsafe conditions are present.84 FR 28198, June 18, 2019, as amended at 86 FR 57021, Oct. 14, 2021; 87 FR 26963, May 6, 2022 84 FR 28198, 6/18/2019; as amended at 86 FR 57021, 10/14/2021; 87 FR 26963, 5/6/2022