Replacement in Kind

Management of change A system to identify, review and approve all modifications to equipment, procedures, raw materials and processing conditions, other than replacement in kind, prior to implementation. 

The employer manages changes (except for "replacements in kind") with written procedures for changes in process chemicals, technology, equipment, procedures, and facilities. The procedures assure the following before any change ... 

Replacement in kind - A replacement that satisfies design specifications, resuspension - Re-entrainment of particulate into a wind field for dispersion. 

Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement-in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted. 

Typically at this plant, substitution of a gasket is authorized only after calculations ensure the substitution is acceptable. No calculations or authorizations were found. The substitution of a CAF gasket was probably intended as a one-time substitute and it was replaced in kind on each turnaround that followed. The 1/8-inch CAF gasket was theoretically acceptable in this service, but conditions would have required a full pressure test to ensure that the 24 bolts had sealed the gasket properly. Unfortunately, the risk of the gasket disintegrating under a high pressure leak was not appreciated. 

The employer shall establish and implement written procedures to manage changes [except for replacements in kind ] to process chemicals, technology, equipment and procedures and changes to facilities that affect a covered process. 

The standard also defines replacement in kind as a replacement that satisfies the design specification. Appendix C to OSHA 1910.119 is entitled Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory). It serves as a nonmandatory guideline to assist with complying to the standard. [3]... 

A Replacement in Kind (RIK) is a replacement that does not vary from documented plant specifications—a replacement of an instrument, electrical, piping, or other component with an identical part or an equivalent approved and specified by the applicable engineering standard. Some RIK examples include, but are not limited to ... 

Is it something that should be pursued Is the idea a replacement in kind or is it a change and therefore requires further evaluation ... 

The supervisor must determine if it seems to be a true change or a replacement in kind as previously defined. In an ideal situation, the unit supervisor and the second-level supervisor (SLS) should discuss the proposed change prior to spending a lot of time generating the MOC form and starting the evaluation. It may be that the second-level supervisor has information that such changes have been unsuccessfully tried before, or there is no money in the budget or similar roadblocks. 

Percentage ofworkorders/requests that were misdassified as replacement-in-kind (RIK) (or were not classified) and were really changes X ... 

In consequence of the above-mentioned demand for repeated assessments, when si ficant plant or process changes are made, a rating for minor and major modifications is required, A very carefiil approach for plant modifications was published by the Center of Chemical Process Safety (CCPS) in their series of guidelines for process safety management [9]. In their recommendations, minor changes remain restricted to 100 % replacement in kind or like for like replacements. Any other modifications exceeding those are subject to a safety assessment... 

Like all the elements of process safety, MOC procedures must be written down. This ensures consistency, and it means that they can be audited. This section of the standard introduces the phrase replacement in kind. The basic idea is that if an item is being replaced by something that is absolutely identical to it, then a change has not occurred, so the MOC process does not need to be implemented. 

The first paragraph of the OSHA MOC standard uses the phrase Replacements In-Kind and lists those aspects of the operation to which it can apply. 

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