Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK). Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially defined what a “replacement in kind” would be by stating… Replacement in kind means a replacement that satisfies the design specifications. For years, the PSM/RMP community has felt that if we had a valve with the same materials of construction throughout the valve components, and the performance specifications for items such as pressure and temperature were the same, we were doing a “replacement in kind.” I want to challenge this approach from a first-hand account I had in a PSM-covered process.