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ASME VIII-1 / NBIC Part 3 - Design Responsibility

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marty007

Mechanical
Mar 8, 2012
622
I have a problem that I'm trying to sort out relating to ASME VIII-1 and NBIC Part 3 design responsibility. I'm wondering if anyone has a perspective on this issue.

This question relates to the supply of replacement parts for existing equipment. We are an ASME VIII-1 shop, and are often asked to build in-kind replacement channels/bundles/shells for existing heat exchangers. We are provided complete original drawings, which we use to generate fabrication drawings for the new parts. We fabricate the components as ASME PARTs with partial data reports, but take no design responsibility. These parts are then shipped to site, where an "R" Certificate Holder installs the parts.

NBIC Part 3, paragraph 3.2.2(c) states:
When ASME is the original code of construction, replacement parts subject to internal or external pressure fabricated by welding, which require inspection by an Authorized Inspector shall be fabricated by an organization having an appropriate ASME Certificate of Authorization. The item shall be inspected and stamped as required by the applicable section of the ASME Code. A completed ASME Manufacturer's Partial Data Report shall be supplied by the manufacturer.

The "R" Certificate Holder, using replacement parts fabricated and certified to an ASME Code edition and addenda different from that used for the original construction, shall consider and seek technical advice, where appropriate, for change or conflicts in design, materials, welding, heat treatment, examinations and tests to ensure a safe repair/alteration is performed. Note that work once classified as a repair could now be considered an alteration.​

NBIC Part 3, paragraph 3.2.4(a) states:
Many repairs may not require drawings or design calcualtions when the original code of construction is known and drawings and/or a Manufacturer's Data Report is available.​

ASME VIII-1, paragraph UG-120(c)(1) states:
... 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.​

Okay, with all of those references out of the way, here's my question: If we supply an in-kind replacement ASME PART, and take no design responsibility, who should we list as the organization responsible for the design on the Partial Data Report?
[ul]
[li]The customer purchasing the PART?[/li]
[li]The original equipment manufacturer (may no longer exist...)?[/li]
[li]Someone else?[/li]
[/ul]

Many of the partial data reports that we have received over the years for items such as large diameter welded S.E. heads have not listed a specific organization, but instead have just stated that they are not responsible. Is this acceptable?

Thanks for any help you can provide,
Marty
 
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The answer to the first question is easy. The original designer of the part you're fabricating. Whether they're in business or not doesn't change the fact they did the design calculations you're relying on.

As for the second, what's acceptable by the letter of the rules and what happens in real life are sometimes different.
 
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