ASME VIII-1 (2017) - UG-120(c)(1) - Replacement parts design responsibility

[marty007]

I have been reviewing the new 2017 edition of the VIII-1 code to understand how changes will affect the way we do our work, and have a question about replacement parts.

The last sentence of UG-120(c)(1) now reads:
Manufacturers and Assemblers of parts who do not perform or assume any design responsibility for the parts they manufacture shall identify on the Partial Data Report the organization responsible for the design of the part.

Many times we fabricate replacement parts for existing equipment, a common example would be a replacement part for a heat exchanger (channel/bundle/etc...). In these cases, we have all of the drawings from the original equipment, and are asked to fabricate a new part in-kind. We do not perform any calculations, and are not taking any design responsibility.

In this case, who should be listed as the organization responsible for the design? Should it be the original fabricator of the equipment (may no longer even be in business)? Should it be the repair organization that will be installing the replacement part? Should it be the owner?

I remember this coming up a while back... www.eng-tips.com/viewthread.cfm?qid=385307

I'm not expecting any cut and dried answers, as this is new to everyone. I'd really like to see how everyone else will be approaching this change.

 

[TGS4]

My opinion would be that it would be the original manufacturer that took design responsibility. This is part and parcel of the new PRT designator. You take responsibility for the part manufacture, but not the design.

For repairs and replacements-in-kind, this would be governed by NBIC, which should provide additional clarification. Remember that VIII-1 is a code of new construction, so you should read such sentences in the context of new construction.