Do You Know Who Made Your Valves?

Counterfeiting is a slippery business. Here’s how to minimize the risk and danger of fake process controls.

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Willing Participants

Unfortunately, some end users accept counterfeiting and knowingly buy fake devices that potentially endanger themselves, their co-workers, end users and the public.

“Some people actually choose to purchase counterfeit products, assuming they’re paying less for products that are equal in value to the legitimate products they mimic. People who deliberately choose to buy counterfeit products are not victims. Instead, they support the criminally deceptive practices of counterfeiters by creating a built-in market for their goods. If consumers stopped using counterfeit products, counterfeiting wouldn’t disappear. However, in many cases, counterfeiting would be less profitable and more risky without these easy sales,” states the OSHA-ACIL report.

Bob Arnold, president of Rotork Controls Inc., Rochester, N.Y., says his firm’s U.K.-based parent found another company, Autork, producing and attempting to sell copies of its valve actuators in China and then exhibiting them in the Netherlands (see Sidebar, Rotork Copes with Copies at the end of this article). “It all depends on what the market is willing to accept,” says Arnold. “What scares us is that the world has grown so much smaller. Folks have easy access to email addresses. For instance, they can buy a list at ISA and just start pumping out product introduction emails. Fortunately, customers we deal with say they won’t buy copies. This is why it’s so important for users to make sure suppliers have legitimate certificates of compliance for each device, as well as original copies of FM and/or CSA approvals, and approvals for operating in hazardous areas, if needed. We’ve found suppliers that say they’re compliant, but they usually don’t have their certificates. We hoped that China’s joining the World Trade Organization would have an impact on this situation, but it has not.”

Repair and Refurbish

Though not strictly 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/or 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 65-70%. 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 that 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 found that 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 in time, the valve’s Class 150-rated flanges were cut off, and Class 600 flanges welded on. Since the OEM repair facility had never had 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.”

When a new plant is designed or an old one is repaired, everything within its piping systems needs to meet applicable ANSI and ASME pressure class ratings for wall thickness and shape, so they’ll be able to safely contain the application’s pressures and temperatures. “If a plant doesn’t meet its original standard, and there’s a fire, explosion or hazardous chemical release, it can mean a huge increase in liability because the compliance burden is on the end user,” says Baker. “That’s why it’s important to be educated and aware of the potential safety issues with equipment on the plant floor. For instance, you can buy refurbished process equipment like used car parts, and they may work fine, but the question is: does the equipment continue to meet original OEM design requirements necessary for safe use and meeting safety and regulatory requirements?” 

For example, a refurbisher may buy a Class 600 valve from a former plant, and sell it as a Class 600 because that’s what the nameplate says, but fail to account for the valve’s previous experience. “Before selling, a salvager/refurbisher/remanufacturer should measure valve wall thickness at appropriate critical stress areas, and verify that it continues to meet specifications as originally designed by the OEM to meet applicable code requirements, but many may not know how to do it, may not care, or may not have the proprietary design information to for verification,” says Baker. “In addition, there can be uniform wall thickness degradation that isn’t readily noticeable (unlike the visible signs of localized erosion). So, a valve may have been sandblasted and repainted, and looks like new, but its walls may not be thick enough to meet the valve’s original pressures class rating. OSHA and EPA process safety management regulatory standards typically refer to use of equipment suitable for the process.”

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