in Kind’ does not require an MOC. Note that determination of in Kind’ ‘Replacement ‘Replacement can sometimes be nearly as involved as conducting an MOC on an actual change. As determination of replacement in kind is not always obvious, consider the following when developing an MOC program: It may not always be clear if a replacement satisfies the design specifications. First example: Replacing one ball valve with another of exactly the same manufacture and model is likely a in Kind’. However, replacement of one ball valve with a ball valve of ‘Replacement different manufacture may or may not be in Kind’. Some review to determine if the ‘Replacement replacement meets all of the original valve design specifications (materials of construction, design ratings, etc.) is necessary. If the valve meets all of the original valve design specifications, then it would be determined to be a in Kind’ and the MOC evaluation would not be ‘Replacement necessary. Second Example: Replacing one and tube heat exchanger with another shell and tube heat exchanger of identical nominal heat transfer duty may or may not be in Kind’. In ‘Replacement order to make the determination, materials of construction, design ratings and heat exchanger configuration would have to be among the considerations. The MOC procedure needs to address how personnel determine if the proposal is a change or is a in Kind’. ‘Replacement It is also critical to understand that in Kind’ DOES NOT mean replacing a ‘Replacement component in the field with an exact duplicate component. When determining in ‘Replacement Kind’, the replacement should be compared with the design specification, not with the component in the field. The concept is to prevent the perpetuation of an error made that could have been made previously in the field. This is the primary function of the MOC. Thorough direction must be provided in the MOC procedure A note about for conducting this review. Regulation requires evaluation of the impact of the change on safety and Reviewing the impacts of a change on safety and health. This means that some type of hazard analysis must be conducted and implies, at a minimum, health utilization of some type of hazard review checklist. The review could be also be satisfied by conducting
‘Replacement in Kind’ does not require an MOC. Note that determination of ‘Replacement in Kind’ can sometimes be nearly as involved as conducting an MOC on an actual change. As determination of replacement in kind is not always obvious, consider the following when developing an MOC program: It may not always be clear if a replacement satisfies the design specifications. First example: Replacing one ball valve with another of exactly the same manufacture and model is likely a ‘Replacement in Kind’. However, replacement of one ball valve with a ball valve of different manufacture may or may not be ‘Replacement in Kind’. Some review to determine if the replacement meets all of the original valve design specifications (materials of construction, design ratings, etc.) is necessary. If the valve meets all of the original valve design specifications, then it would be determined to be a ‘Replacement in Kind’ and the MOC evaluation would not be necessary. Second Example: Replacing one and tube heat exchanger with another shell and tube heat exchanger of identical nominal heat transfer duty may or may not be ‘Replacement in Kind’. In order to make the determination, materials of construction, design ratings and heat exchanger configuration would have to be among the considerations. The MOC procedure needs to address how personnel determine if the proposal is a change or is a ‘Replacement in Kind’. It is also critical to understand that ‘Replacement in Kind’ DOES NOT mean replacing a component in the field with an exact duplicate component. When determining ‘Replacement in Kind’, the replacement should be compared with the design specification, not with the component in the field. The concept is to prevent the perpetuation of an error made that could have been made previously in the field. A note about Reviewing the impacts of a change on safety and health This is the primary function of the MOC. Thorough direction must be provided in the MOC procedure for conducting this review. Regulation requires evaluation of the impact of the change on safety and health. This means that some type of hazard analysis must be conducted and implies, at a minimum, utilization of some type of hazard review checklist. The review could be also be satisfied by conducting
data-vii-moc.docx