API 6A Monogram Restricts Remanufactured Equipment

Inquiry:  My question is regarding application of the API monogram. Our company is an API 6A licensee. We manufacture valves and other related equipment at our facilities here in the USA and overseas.  During a recent re-certification audit, the Auditor told us that we could not monogram valves if they had been disassembled and reassembled. These are new valves, so why is this even a concern, especially since the valves were manufactured at our overseas facility that is also API 6A licensed?  I Look forward to your reply.

Reply:  Thanks for submitting this question to us.  In my opinion, the Auditor was correct to inform your organization about this nonconformance.  As you’re aware, application of the API monogram is limited to a new product.  If a valve is disassembled and reassembled, it’s considered as remanufactured.  Please review API 6A, 19th edition, terms and definition section 3.1.8.1 “remanufacture”.   Based on this definition, these valves aren’t eligible to be monogrammed as API 6A product.

I also suggest that your organization revisit the API Q1, Annex A, sections A1 and A3.1 requirements for application of the monogram.  As you know, this type of situation could result in the cancellation of your organization’s API monogram license.  Consider contacting the API for more explanation.

I hope this helps.