Since the great recession of 2008 -2010 we have seen an increase in the used equipment market. This is due to so many businesses going under and auctioning off their equipment and the remaining businesses needing to find ways to save $.
In my personal opinion, buying used equipment for a process that contains any of the HHC’s in OSHA or EPA chemical list for PSM or RMP is asking for a disaster, and here’s why…
Imagine going to buy a used car. If the salesperson told you they could not tell you anything about the car, would you buy it and put your family in it for the annual summer vacation. I try to use the CarFax commercials as a means to make my point. In almost every case we have run into in our work, the facility has
- absolutely no history of the equipment, no knowledge of what it last contained,
- how it was used,
- where it was used,
- how it was cared for, etc.
Heck, many times they do not even have the U1A form for a pressure vessel they bought. THERE IS NO FREE LUNCH with this type of set up. An employer is responsible for their PSM/RMP covered process from the unloading hose through the last valve in their battery limit. Not knowing/ignorance of the condition of a piece of equipment is just not going to get you out of anything and may even sink you further into trouble with either OSHA and/or EPA.
If you wish to buy used equipment you should require that the seller provide a DOCUMENTED history for the equipment/vessel (e.g. a “CarFax”) that shows you the use, location, care/inspections records, repair records, etc. so you can know what you are actually buying. We have done audits where the company did not have any documentation, they hired a certified inspector to do a fit-for-service inspection on the pressure vessel, only to be told they would need to have the vessel re-rated and the relief valves replaced with a lower set point (whatever the rating ended up being). They saved $12,000 only to discover that the vessel could not be used in their process since the re-rating ended being much lower than they could operate within. They WERE LUCKY… they found out before an incident.
The same line of thinking would apply to buying an entire facility. Since “due diligence” seems to be a thing of the past, we have gone into a client’s newly purchased facility to do an audit and found they had nothing on pipe conditions, such as engineering specs, schedules, materials of construction, etc. The seller had recently completed an insulation replacement project due to a hail storm a few years earlier and “everything looked nice and shiny” on the outside!!!! They hired an API inspector and found that the piping was a hodge-podge of schedules, materials of construction, conditions varied greatly and in the long run, the vast majority of pipe had to be replaced at a considerable cost.
Keep in mind this is only speaking to the physical nature of the process, but the same could be said for poorly written SOP or non-existent SOPs, none or poor training, significant PHA issues unresolved from previous studies, etc. As the new owner, it is NOW YOUR BABY and although your attorneys may seek damages against the seller, OSHA and EPA could care less about your sob story and I can assure you they will not go and cite the previous owner who is now out of business. Only you are in the crosshairs and I can assure you it is a lonely feeling! A half-day review is better than nothing and a full review is best, but not doing any type of review is setting you up for some serious problems.