Define "Replacement in Kind"
Define "Replacement in Kind"
(OP)
I didn't know where else to post this since it's a non-technical question.
I've always thought that "replacement in kind" meant replacing something with the exact same thing. For example, replacing a section of 4" CS, 150#, sch40 pipe with another piece of 4" CS, 150#, sch40 pipe, or replacing a fisher globe valve with the exact same fisher globe valve.
However, our Maintenance Manger has written an MOC of all things, requesting to define "Replacement in kind" (however he wrote it as "Replacement of kind"). Anyway, after looking it up in OSHA 1910.119, and 1926.64, they both define replacement in kind as "a replacement that satisfies the design specification".
By this definition, if you replace a globe valve from one manufacturer, with a globe valve of another manufacturer that has the exact same specifications, you do not need an MOC. However, since the manufacturer is listed on the spec sheet, you have to update the spec sheets and possibly some other documentation. In order to make sure you update the documentation, you have to have some kind of process that involves forms with action items and so on, basically more documentation.
So if you're going to have to create a whole different system to document these "non-changes", why not just use the MOC system and allow for this RIK to forgo approval signatures.
Please let me know what you guys are doing at your plants. Any input would be appreciated.
I've always thought that "replacement in kind" meant replacing something with the exact same thing. For example, replacing a section of 4" CS, 150#, sch40 pipe with another piece of 4" CS, 150#, sch40 pipe, or replacing a fisher globe valve with the exact same fisher globe valve.
However, our Maintenance Manger has written an MOC of all things, requesting to define "Replacement in kind" (however he wrote it as "Replacement of kind"). Anyway, after looking it up in OSHA 1910.119, and 1926.64, they both define replacement in kind as "a replacement that satisfies the design specification".
By this definition, if you replace a globe valve from one manufacturer, with a globe valve of another manufacturer that has the exact same specifications, you do not need an MOC. However, since the manufacturer is listed on the spec sheet, you have to update the spec sheets and possibly some other documentation. In order to make sure you update the documentation, you have to have some kind of process that involves forms with action items and so on, basically more documentation.
So if you're going to have to create a whole different system to document these "non-changes", why not just use the MOC system and allow for this RIK to forgo approval signatures.
Please let me know what you guys are doing at your plants. Any input would be appreciated.





RE: Define "Replacement in Kind"
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RE: Define "Replacement in Kind"
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RE: Define "Replacement in Kind"
The classical question: is a car a car?
With performing products, say a globe valve or a more complicated actuated valve, there could be (and usually is) a difference in buying price between two competing suppliers.
This, of course, do not necessarily mean that the cheapest has the same quality as the higher priced, or that the cost over the liftime is the lowest for the cheapest one.
Hence, for simple products, the 'design qualifications' is fairly simple. For uncomplicated pipe 'design qualification' this would mainly mean same material, measurements, grade, tests, approvals, surface etc, from any supplier. But: it could also mean from only a few given pre-qualified suppliers, this being a part of the approved design preview and qualifications for the project.
For more complicated products or projects the 'design qualifications' review and selection should absolutely, for any company or project, include performance and lifetime cost comparison, along with comparison of technical details influencing performance, standtime and maintenance and running cost.
All this is valid both for cars and globe valves.
RE: Define "Replacement in Kind"
I guess you could get by this by not listing the manufacturer on the spec sheet.