What is Replacement in Kind?

An efficient approach to Management of Change (MOC)

This document outlines the concept of “Replacement in Kind” (RIK) in the context of OSHA’s Process Safety Management (PSM) regulations, emphasizing it as an efficient approach to Management of Change (MOC) by allowing certain replacements that meet original design specifications to bypass the formal MOC process.

This approach is cost-effective as it avoids the extensive requirements typically associated with MOC, provided that the replacement aligns precisely with the original design intent, as outlined in OSHA’s definition of RIK.

The document addresses challenges related to missing or incomplete design specifications, explaining three primary assumptions that guide RIK decisions in such cases: the “grandfathering” assumption, which allows identical part replacements; the “generic” assumption, which permits parts from alternative manufacturers if they meet the same operational criteria; and reliance on Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) where applicable.

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