The impact of REACH on the
aerospace sector
- a DU’s perspective & response
Nigel Marsh, Company Head of Environmental Management
UK REACH Competent Authority Roadshows
November/December 2007
Issue 1
© 2007 Rolls-Royce plc
The information in this document is the property of Rolls-Royce plc and may not be copied or communicated to a third party, or used for any
purpose other than that for which it is supplied without the express written consent of Rolls-Royce plc.
This information is given in good faith based upon the latest information available to Rolls-Royce plc, no warranty or representation is given
concerning such information, which must not be taken as establishing any contractual or other commitment binding upon Rolls-Royce plc or
any of its subsidiary or associated companies.
2
A Downstream User’s Perspective
z The potential impact of REACH on the aviation
sector and its global supply chain
z How Rolls-Royce is responding to REACH
z Concerns and advice on implementation
3
Rolls-Royce Group plc
z Power for air, sea and land
z Annual sales £7+ billion (£24bn order book)
z Customers; 500+ airlines, 4,000 corporate and utility aircraft and
helicopter operators, 160 armed forces and more than 2,000
marine customers, including 50 navies.
Energy customers in nearly 120 countries
z 38,000 employees in 50 countries
z A Global company with a Global Supply Chain
4
REACH scope
Importation
Manufacture
Placing on the market
Use
Im
of substances
On their own
Trichlorethylene
In preparations
Paints, Sealants, Resins
po
rt a
ti o
n
In articles
Systems, Components, aircraft
5
What REACH means to Rolls-Royce
Rolls-Royce as an importer (?)
z Alloys - preparations (bar, billet,
specialist metallic powders etc)
z Processing chemicals (drums of
chemicals and powder preparations etc)
z Imported finished articles (with no
intended substance release)
z
Contracts on non-EU suppliers will have to change to
obtain information to complete registration.
6
What REACH means to Rolls-Royce
Rolls-Royce as a downstream user
z Making articles out of preparations,
and using preparations / substances
during manufacture and R&O
z Making some preparations
(eg, thermal paints)
z Conducting Product and Process
Oriented Research and Development
(PPORD) with suppliers
7
What REACH means to Rolls-Royce
Rolls-Royce as a downstream user
z Check whether SVHC are in products
following manufacture, at > 0.1% w/w
z Check all our uses are registered
z Substances used in PPORD will require
notification to the Agency, and will
probably avoid SVHCs (including
candidate substances)
8
What REACH means to Rolls-Royce
Rolls-Royce as a user of substances of
very high concern (SVHC)
z Using SVHCs within alloys, within
process chemicals
z Unable to change quickly to
alternatives (air worthiness)
z In some cases, there may be no
alternatives
9
What REACH means to Rolls-Royce
Rolls-Royce as a user of substances of
very high concern (SVHC)
Rolls-Royce specifiers, purchasers,
designers and technical experts will need
to work with customers (who may specify
SVHC use) and suppliers (who may have
a technical necessity to use SVHC) to
prove the need for each SVHC within any
Authorisation.
10
RR – As a ‘Downstream User’
z REACH is aimed primarily at manufacturers and
importers of chemicals
z RR will mainly be a ‘downstream user’ and
therefore fall outside much of the REACH burden
z However, for strategic, niche/small market
materials and targeted substances we will need to
ensure that suppliers are REACH compliant
z We will be an importer of ‘articles’ from all over
the world and this brings responsibilities,
especially when SVHC are involved
z We expect to have significant involvement in SEA
Some Aerospace Issues
z Low use speciality products may be removed from the market
(uneconomic for the manufacturer to put through REACH)
z Some substances will be liable for Authorisation for continued use
z Will need to register any substances that we import into the EU where
we are the only importer and may need to directly register novel uses
of substances in our operations. We will also need to ensure that
suppliers/RR companies complete ‘pre-registration’
z We may need to register/notify substances in imported ‘articles’
(intended release??)
z Supplier awareness & security of supply?
z Costs of supply will most likely increase
z Data will need to be passed along the supply chain - exchange of
information could have implications for commercial confidentiality and
intellectual property rights
z Internal company resource to support REACH
z Development of lists of targeted substances/timetables and align
elimination/substitution programmes
z Unique Industry issues - Product life cycles, safety and reliability
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Purchasing – impact of REACH
z Changes will be needed in purchasing practice
– a new way of working
z Closer ties with engineering, design and
manufacturing functions
z Cost, Quality, Delivery + REACH compliance
z May need to place contractual requirements on
suppliers regarding a responsibility to register
and obtain any relevant authorisations
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REACH COMPLIANCE
– Continued access to substances:
z Registration for an imported or manufactured substance is
the right to bring onto the market irrespective of hazard or
risk posed by the substance, OR it will be illegal:
z
z
to PURCHASE the substance
to use the substance IN PRODUCTS
z Authorisation is the right to use a substance - including
presence in an ‘article’ – if the substance is considered of
‘very high concern’
z Communication – you must tell your customer if an article
you sell to them contains SVHC at >0.1% w/w
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Priority for
replacement
CANDIDATE LIST
List of all substances that
meet the criteria
for Authorisation
1,800 - 2,500
Substances?
Pressure on continued use
ANNEX XIV LIST: List of Subs.
SUBJECT to Authorisation
ECHA WORK
PROGRAMME
Helping aviation businesses
understand REACH
z
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Banned / Targeted list of substances
To be used by companies for forward planning
- Anticipating possible obsolescence and required R & T
- OEMs can target B/T list substances for phase out EARLY –
‘Future-Proofing’ our industry
-
Banned / Targeted list
Annex XIV
= substances
submitted to
authorisation
ALL REGISTERED
SUBSTANCES
Known
SVHC
Priority
SVHC
Newly Classified
SVHC
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Ranking for REACH Authorisation
Priorities?
Still not finalised but will be something like..
z Priority 1: Cat A substances (PBT, vPvB or ‘equiv concern other’) x wide dispersive use
z Priority 2: Cat B substances (Carc & Mut 1&2 nonthreshold) x wide dispersive use
z Priority 3: Cat C substances (rest) x wide dispersive use OR
Cat A non-dispersive use
z Then it becomes unclear (algorithm’s complexity)
17
Substances of concern
– eg R50/R53
z ‘Very toxic to aquatic organisms, may cause
long-term effects in the aquatic environment’
z Eg’s: Alochrom, Ardrox, chromic acid, colbalt
oxide, copper chloride, resins, paints,
potassium cyanide, potassium permanganate,
sodium chromate, sodium cyanide, thermal
paints …..
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Other examples of substances of
concern:
z
z
z
z
z
z
z
Trichloroethylene
Chromium (6)
Cadmium
Beryllium
Nickel oxides
PTFE
Kevlar
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Enforcement
z The manufacture, import, sale, supply or use of
substances without the appropriate registration
z Using hazardous substances outside the terms of an
authorisation or contrary to a restriction
z Failure to provide required information up and down
the supply chain
z Failure to comply with other duties regarding
information, eg, workers’ or consumers’ rights of
access to information
z Failure to comply with the duty to apply
recommendations, eg, in safety assessments
z Failure to comply with the duties to co-operate and
supply information (in a timely manner)
20
Rolls-Royce Approach to REACH:
The most cost effective solution is for a centrally
co-ordinated/consistent approach:
z One defined process for the Group
z Formation of a Corporate IPT >> Operations
Council
z REACH Executive appointed
z Purchasing and laboratories have a key role to
play (make to Print, Design Make and
Consumables)
z Engineering, Design, Manufacturing Operations,
Repair & Overhaul
z ~ 12 FTEs currently
20 FTE by end 2007
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A voice for the industry..
z ASD REACH Task Force (lobbying >>> focus
on implementation)
z RIPs
z Alliances with other industry groups and trade
associations
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Helping our Supply Chains
Understand REACH
z Significant outreach and awareness
raising including supplier workshops
z ASD (EU)- Paris Airshow – launch of
‘Implementation Guidelines’
z SBAC (UK) – EWG
z AIA (North America)
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http://www.sbac.co.uk/pages/42351931.asp
Managing the Issues:
Collaboration
z
The Aerospace sector globally is now working
on several initiatives:
- ARTICLES interpretation
- Standard data to be collected from suppliers for REACH
- Common standards/guidelines for our sector
- Supporting trade association / professional institution
-
z
workshops on REACH
Provision of international training
Sharing best practice across other sectors
RIPs
Cost sharing
Working with DEFRA and HSE (CA) (in the UK)
24
25
Working With the European
Commission and ECHA
z
z
z
Various companies across ASD, SBAC
and GIFAS are representing our sector in
REACH IMPLEMENTATION PROJECTS
(RIPs)
The RIPs will generate TECHNICAL
GUIDANCE DOCUMENTS (TGDs) to help
businesses find their way through the
legal maze
http://ec.europa.eu/echa/home_en.html
Communication through Supply
Chain US/EU
Chemical
Producer 1
Pb
26
US EU
Supplier 1
Repair shop
Spec ##
Antigallant
Chemical
Producer 2
CdO & Ni(SO3
NH2)2.4H2O
Plater
Chemical
Producer 4
(Importer)
Steel alloy disc
w/ AMS##
NiCd plating,
conversion
coat, & Spec
## antigallant
CrO3 (e.g.)
Chemical
Producer 5
(Importer)
Steel alloy
Aircraft
Airline
Engine
Steel alloy disc
Preparation Importer
(Supplier 1)
• Appoint “only
representative” or provide
info to importer to:
• pre/register by use
⇒ provide SDS or reg
#/auth/restrict info
Courtesy of AIA
Airframer
Forger/Part
Producer
Supplier 2
Fe
Large,
Complex
Component
Producer
⇒ Information on
substances intended
to be released or
SVHC on candidate
list contained in
article will need to be
collected through
specs, MSDS or
contractual
requirements
Article Importer
• Register
substances intended
to be released
For SVHC on
candidate list,
• notify Agency
⇒ provide safe use
info
Article D/U
• Register uses not covered by
substance M/I
⇒ For SVHC on candidate list,
provide safe use info
?? ⇐ Pass identified uses and
hazard/risk info to next actor in
supply chain
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Some current concerns
z
z
z
z
z
z
z
z
z
z
z
z
Business continuity – continued access to materials
Legal entities (defined locations)
‘Importer’
Access to IT tools & IUCLID5
Data collection!!
Pre-registration (for strategic substances)
RIPs
Representation at EU/ECHA level
Supply chain awareness (7 000 UK Companies)
Defence exemptions
Enforcement
Provision of information
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Business Priorities
z
z
z
z
z
z
z
z
z
z
Senior management commitment (& resource)
Ownership – appoint a champion
Awareness
Inventories of substances & preparations (& REACH
responsibilities eg, Importer)
SVHC – Candidate List (0.1%)
Identify priority substances
Substitution programmes (R&D)
Pre-registration (08)
Checking that the supply chain are going to meet their
obligations for registration
Collaboration with partners, competitors and trade
bodies
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End of Presentation
Thank you for listening
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