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.

MORE NEWS