Stack Testing: a Commodity?

First, a definition: a commodity is something for which there is demand, but which is supplied without qualitative differentiation across a given market.

In the regulated utility world, stack testing, whether for regulatory compliance or for engineering/diagnostic purposes, is often lumped into the general category of a ‘required vendor supplied service’. As such, many ‘hands-off’ managers and purchasing agents may have a tendency to view these services as commodities. That is to say, these services are basically the same regardless of the selected vendor, and, therefore, price becomes the primary determining buying factor.

Has stack testing evolved to the point where it can be considered a commodity? After all, the methods are published, and as long as the procedures are followed, aren’t all results good enough? The short answer is no. There are major differences between stack testing companies in competency, capability and compatibility. These differences can translate into obtaining inaccurate results, protracted testing or frustrating expectations; the tangible and intangible costs of which can adversely affect overall project or future operating costs, far outweighing any perceived ‘savings’ in the initial contract price. So what are the factors that should be considered in evaluating a prospective stack testing company?

There are several key points to consider in this process. A long-term, excellent reputation is a strong indicator of a high-value vendor. Does the company have a record of working with similar facilities? Checking references can be a valuable exercise. Not only is the quality of the work product significant, it is also important to have a sense of the tester’s flexibility in scheduling, in scope of work development and in project planning.

The next thing to look at is the level of experience in performing the specific type of testing (USEPA methods, NCASI methods, etc.) needed. What training programs – both internal and external – are in place?

Another indication of the testing contractor attitude is the willingness to conduct a site visit prior to the test – perhaps even prior to submitting a proposal. If a site visit is not contemplated, what is the process for the contractor to obtain the necessary site data?

On the business side, the client needs to evaluate the testing company’s insurance coverage and invoicing details. Is professional liability insurance a part of the package? How well do these match up? Also, is the testing contractor willing to discuss the test equipment – manufacturer, age, quantity, maintenance and calibration schedules?

Other issues include quality and safety. While regulatory agencies generally will not recommend a specific contractor, sometimes it is helpful to inquire as to whether there have been any substantive problems or issues with testing procedures, communications, report quality, etc. It is also worth finding out what safety programs (internal and external) are in place. Are tailgate meetings on-site a part of the daily on-site routine? Requesting the company’s experience modification rating (EMR) can often provide insight to the level of importance placed on a safe work philosophy.

The USEPA is collaborating with several stack-testing firms to define the qualifications for a Certified Air Emission Testing Body. While this is still in the development phase, it can prove enlightening to ask the testing company about plans to meet the requirements. And last – but certainly not least – how does the price compare?

In summary, even though it may appear that all stack-testing companies operate and deliver at the same level, there are significant differences. The levels of overall quality and value need to be seriously considered when deciding on the source of important data – data that can be used to demonstrate compliance and/or data that can lead to operational changes or capital expenditures.