Though not defined as counterfeiting or copying, misuse of identification when devices are repaired or refurbished is at least as unethical, and can cause many of the same problems and possible hazards. Several engineers report they haven’t seen fake process devices, but routinely see misrepresented or missing plates on those devices.
Bob Baker is a process safety consultant focused on educating process control end users about potential non-compliance with plant equipment design codes and standards, OSHA and EPA safety regulations, including process safety management (PSM), when using salvaged, refurbished, remanufactured, or repaired process control equipment.
The need for greater end user understanding and visibility is due to ever-increasing amounts of used equipment being salvaged and resold into many plants. The supply of used equipment is especially large as the numerous facilities built in the 1970s and 1980s are retired and torn down, especially along the Gulf Coast.
“This use of salvaged equipment really started in the offshore oil and gas industry and began to pick up in the early 1990s,” says Baker. “In 2001, it was estimated that only about 5% of Gulf Coast process plants were actively buying such salvaged/refurbished process equipment. By 2005, process plant use of such equipment was estimated to have grown 65% to 70%. This was driven primarily by its significantly reduced costs, yet providing operating viability comparable to new equipment.”
Yet the overlooked aspect of such equipment was whether it continued to meet the original manufacturers’ design criteria necessary to comply with appropriate safety and regulatory standards for safe use. Statistics being what they are, an ever-increasing installed base of potentially non-compliant equipment may increase the risks incurring an incident.
“For example, approximately two years ago, an OEM repair facility received what was supposed to be a Class 600 control valve from a major oil company refinery (removed from a Class 600 piping system handling hot hydrocarbons), and discovered years earlier the valve was originally manufactured and shipped new to a major chemical process plant as a Class 150 valve,” adds Baker.
“Apparently, at some point, the valve’s Class 150-rated flanges were cut off, and Class 600 flanges welded on. Because the OEM repair facility had no prior access to the valve during its lifetime, further inquiry yielded information that more than one independent, third-party shop had previously performed repairs on the valve, but no traceability existed as to when the flange change occurred or who did it. The installation and use of a Class 150 valve (modified to have Class 600 flanges) for use in a hot hydrocarbon application with Class 600 piping system specifications could have resulted in a fire or explosive incident had the valve failed.”
On the electrical side
OSHA’s 20-year-old Nationally Recognized Testing Laboratory (NRTL) program inspects the 18 labs presently authorized to test products, and confers non-incendive, intrinsic safety, and explosion-proof ratings on OEM-designed, new products. A subset of the 18 labs are authorized for specifically certifying process equipment for use in hazardous location.
However, it’s the end users that bear the responsibility for ensuring compliance to OSHA 1910 electrical approval requirements. Any change made to an NRTL-approved device, even if inadvertent, might alter the device’s design attributes as originally tested and certified by the NRTL to appropriate consensus standards.
“An instrument salvager/refurbisher/remanufacturer might sandblast, repaint, and recalibrate an NRTL-approved device, and then usually leave the old nameplate containing the original NRTL approval certification mark on it,” says Baker. “Some remanufacturers even produce new nameplates, and we’ve seen unauthorized NRTL certification marks applied to them (NRTLs have classified such as counterfeit marks). NRTL labs, such as FM Approvals, have taken the position that if a device’s ownership changes, then, until the device is re-certified by an NRTL-approved facility, the device is no longer considered approved, and its nameplate or certification mark and certification description should be removed.”
Removing these should assist end users in appropriately applying the instrument, and avoid installing it in a hazardous (classified) location, because the NRTL certification mark or certification descriptions would no longer be present on the device.
Baker adds “Engineers are typically very attentive to codes when specifying valves and instrumentation for new plants, but something just seems to get lost when small project or maintenance turn to salvaged/refurbished/remanufactured equipment. Sure, the salesman says a valve or instrument will look and operate as good as new when it’s refurbished, but you just don’t know if the equipment is safe (meeting original OEM valve design specifications or instrument NRTL approvals) until it’s tested and certified. The crux is getting buyers to ask for salvaged/refurbished/remanufactured valve or instrument certifications, and for sellers to provide it or acknowledge to having the capability to provide it.”