
Summary of Telephone Interviews with Industrial Hygiene Firms Regarding Personal Sampling at Hydraulic Fracturing Sites in the Oilfield
                                  MEMORANDUM
To: Robert Stone, Robert Blicksilver, Robert Burt, OSHA
From: Eastern Research Group, Inc.
Re: ERG 2014 Assessment of Sampling Costs Based on Interviews with IH Consultants (May 2014)
Date:  May 28, 2014
*********************************************************************************
In the OSHA Preliminary Economic Assessment, Appendix A, (Appendix A-OSHA-201-00034-17201), ERG (2011) estimated that an IH will spend one day, at a cost of $500, to obtain the following number of personal breathing zone (PBZ) samples: 2 for establishments with fewer than 20 employees; 6 for establishments with 20-499 employees; and 8 for establishments with 500 or more employees. ERG anticipated that sampling would be performed by an IH technician. 

Based on the 2000 EMSL Laboratory Testing Catalog, ERG (2007b) estimated that analysis of each sample will cost $133.38 (adjusted to 2009 dollars) in lab fees and shipping costs. When combined with the IH fee, the cost per PBZ sample is projected to range from $195.88 to $383.38 (depending on establishment size). 

The American Foundry Society criticized the estimates, suggesting that the industrial hygienist costs, at least in their industry, would be $1,700 per day, including $700 for pump rental costs. The pump rental cost estimate was based on use of higher volume pumps. 

To obtain better estimates of costs associated with exposure monitoring, ERG conducted interviews with a small sample (n=7) of industrial hygiene consultants in May 2014. An eighth interviewee provided general information regarding costs of sampling, without providing specific pricing.

Based on these interviews, ERG determined that, in addition to labor costs for sample collection, labor costs also apply to preparation of sampling reports. Reports may be needed to identify potential sources of exposure and to meet OSHA recordkeeping requirements. Also, sample collection costs vary with the skill level of the individual performing the sampling. Independent consultants often perform their own sampling.  Larger consulting firms often use a technician, for example to perform routine sampling at well characterized sites; however, for new or complex operations,  a certified industrial hygienist (CIH) might be needed. One of the consultants stated that sampling costs are typically highest during the "discovery phase," such as characterization of a new site or facility or compliance with a new rulemaking, and that sampling costs are generally lower for routine periodic monitoring. Labor charges for a full day of sampling, with preparation of an accompanying report, were described as being in the range of $750  -  $3600, with the majority of respondents describing labor charges in the $1800- 2500 range per day of sampling. 


Labor Costs Reported per Day of Sampling, Including Report Writing Costs, by Industrial Hygiene Consulting Firms
Interviewee
Minimum
Maximum
A
$750
$1000
B
$1800
$3600
C
$1875
$1875
D
$1885
$2500
E
$1980
$2500
F
$2000
$3000
G
$2400
$2400
Average
$1812.86 
$2410.71 
Overall Average
$2111.78

ERG confirmed that it is feasible, common practice for a single field technician to collect up to 8 full-shift samples as described in the PEA.  Where 8 samples are collected, the IH fee, that is, costs per sample for field sample collection and report preparation, would be $2111.78/8 = $264. For smaller sites where fewer samples are collected, the overall time and costs associated with sampling and report preparation would generally be lower, but per sample costs might be higher. 
Comments from the Independent Petroleum Association of America (IPAA) expressed concern regarding elevated costs for sampling at remote hydraulic fracturing sites. Significant hydraulic fracturing operations are within a reasonable distance (e.g., two hour drive) to a metropolitan area, such as the shale deposits in Eastern Ohio near Pittsburgh (Utica shale formation), and the Barnett shale near Fort Worth, Texas. 
Regarding travel costs associated with sampling, consultants generally reported that hourly labor rates for field sampling personnel would be applied during travel to the site. Some firms charge a lower labor rate (e.g., 25-30% lower) during travel to a field site than during sampling and report writing. For facilities within driving distance, consultants generally reported charging mileage for travel to sites more than 50 miles from the base of operations, and in some cases applied a trip fee/gasoline charge of at least $50 for all sampling visits. Also, travel costs to remote facilities, including airfare, lodging, and meals would be passed along to the facility.  Several consultants stated that for multi-day sampling projects, the number of hours needed for report writing is proportionately less than for a one day project.  
The industry criticism had suggested that high volume sampling pumps would be needed. ERG industrial hygienists judge that no such special equipment would be needed to meet OSHA requirements. 
Regarding pump rental costs, most consultants reported having enough of their own equipment to support the majority of projects. Also, many consultants reported using pumps and other sampling equipment provided by the analytical lab that analyzes their samples, which were either free or available for the cost of shipping. In some cases, costs of equipment rental would be passed along, for example if the site requested use of unusual sampling equipment or for a large sampling campaign (for example involving more than fifteen eight-hour samples per day). This pump loan program would also be available to employers that use their own staff to perform sampling.



