Management of Change: Further Thoughts on Replacement-In-Kind
We continue our discussion to do with the challenge of defining ‘change’ in the context of Management of Change (MOC). Previous posts in this series are:
The following criteria provide further guidance regarding when a change is to be considered ‘In-Kind’ or ‘Not-In-Kind’.
Same Specification
If a replacement item has the same technical specifications as the original, then it is generally considered to be ‘In-Kind’. The replacement item should have the same materials of construction, rating (pressure, temperature, voltage, amperage, and resistance), function, capacity, electrical area classification, and settings.
The new item should be a genuine replacement — not an improvement on the old one. If the purpose of the replacement is to upgrade the operation in some manner, then the change is likely not ‘In-Kind’. For example, if a new vendor is used to supply a replacement part that has the same specification as the old part, then the change may be ‘Not-in-Kind’. After all, the reason for using the new vendor is that management wanted to make a change to the system (probably to reduce costs or improve system reliability). There must be some difference between the old and the new products in order to explain why the new vendor was chosen. Therefore, the decision to change a vendor or a supplier should generally be validated using the Management of Change process.
If the item to be replaced has been in service for some years, then it is probable that its replacement is not going to be ‘In-Kind’. The new item probably will have upgraded electronics, different control panels and an updated vendor manual. These changes may not be critical, but they do need to be reviewed.
Same Service
The service in which the item is being used should not have changed. Process conditions ― including pressure, temperature and process materials ― must be the same as when the original item was in service. Nor should the inspection and maintenance requirements have changed.
If the item to be replaced has been in service for some years, then it is probable that its replacement is not going to be ‘In-Kind’. The new item probably will have upgraded electronics, different control panels and an updated vendor manual. These changes may not be critical, but they do need to be reviewed.
If an item fails unexpectedly, it is important to determine the cause of the failure. If the reason for failure is not known then the replacement should be treated as not ‘In-Kind’. There must be some reason for the system failures — they could be occurring because the system has changed in some undetected manner. Hence, a Management of Change review is required.
Usually, a proposal to change instrumentation systems will require that the Management of Change policy be followed. This is certainly true if alarm limits, interlock settings, or control logic are to be changed. Changing operating set points should not require a formal change approval as long as the new values stay within the safe operating range, as shown in Figure 1.7. Any changes to the emergency shutdown system and its associated interlocks will certainly need to go through the MOC process.
Same Storage and Handling Process
As we saw in the ‘wrong gasket’ story, the replacement item should be stored and handled in the same manner as was used for the original item. It will never be possible to have absolutely identical storage and handling processes for all items, so some judgment is required. For example, changing the storage location from indoors to outdoors could have an effect on the stored items, as could the use of air-conditioned facilities.
If the item to be replaced has been in service for some years, then it is probable that its replacement is not going to be ‘In-Kind’. The new item probably will have upgraded electronics, different control panels and an updated vendor manual. These changes may not be critical, but they do need to be reviewed.
Procedure Update
If a proposed change requires that the operating or maintenance procedures be updated then that change is not ‘In-Kind’. The same criterion applies it the Emergency Procedures have to be updated.
