Does a change in valve construction by a 3rd party require a new SEP/PED declaration?

[Dawson1977]

Hi folks, this is a quality assurance question that I'm looking for advice on.

When a valve is supplied to SEP/PED by an OEM and then a vendor modifies the construction, does the modification need to covered by a new declaration to SEP/PED?

In this instance we have a valve where the O-Ring on the Ball Valve Stem, above the fire-safe gasket, has been changed out for another type (compound) by the Vendor.

This is after the OEM supply, so does the vendor have a responsibility to provide their own declaration to SEP/PED or can they rely on the OEM's on the basis the change is not significant in terms of design?

I feel that they do, as the OEM never agreed to the change in their product but I could be interpreting the standard too conservatively.

 

[mk3223]

The OEM won't warranty the valve if the vendor changed the parts without the OEM authorization or permission after received it. If the vendor can't provide a legal document, the owner should reject the valve.

 

[Dawson1977]

Thanks for the info mk3223, in this instance we have the 3rd party issuing a generic CofC, so warranty isn't an issue. What i'm particularly interested to clarify is whether this change in construction has an affect on the SEP / Ped declarion from the OEM. If so, then it stands to reason the 3rd party would have to re-certify.

Basically the way I read PED was that if a 3rd party changes the design of a valve, they then own it and must certify it.

 

[mk3223]

From my past experience with the orbit valves service, there is no warranty issue as the 3rd party vendor is authorized by the OEM. If not, the vendor needs to rectify the valve for any change. You need the vendor to confirm what are included in its "generic" certificate.
Also, besides reading the PED, verify it with OEM for the authorization of this vendor and the warranty coverage due to the valve condition.

 

[MGZmechanical]

I think that the vendor must be authorized by the OEM or that change must be described in the instruction and operation manual.