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AIA REACh Working Group at Lockheed Martin’s Global Training and Logistics Facility in Orlando
(Photo credit to Lockheed Martin)
Potassium chromate, sodium dichromate, chromic acid and chromium trioxide are all substances chemically grouped as chromates. Due to toxic health effects associated with exposures to these substances, the European Chemicals Agency proposed to restrict their use under the REACh regulation. These substances are often ingredients in paints, coatings and films that protect aerospace parts from corrosion. Once a substance is targeted for restriction under REACh, downstream users of products with restricted substances may be negatively impacted in several ways. Companies may incur increased costs to obtain the products they need, experience additional requirements to use the products and may even lose the opportunity to purchase these products because they have been removed from the market completely.
All of these impacts can hit aerospace companies even before REACh technically restricts a substance. AIA members are already being notified by suppliers that key products have been reformulated to remove a number of substances targeted by REACh. This may result in impacting the product’s ability to meet performance requirements.
Although the aerospace industry is large, it is not a big enough market to prevent chemical suppliers from discontinuing certain products when faced with REACh impacts. Suppliers often presume that if other industries have switched to non-REACh substance products or formulations, the aerospace industry is capable of switching as well. The aerospace industry has already made the change to alternative substances or processes for numerous applications, but due to certain conditions unique to the industry it is not possible to replace all of them at this point in time.
Unlike most products, aerospace products have exceptionally long life spans, ranging from 40-50 years. Additionally, aerospace manufacturing is guided by a number of customer specifications and government standards developed by DOD, FAA and their global counterparts including EASA. These standards and specifications are designed to ensure that aerospace products meet detailed safety and performance requirements over their lifespan and often require lengthy testing and costly certification procedures to change.
The AIA REACh Working Group is responsible for coordinating activities related to European Union registration, evaluation, authorization and restriction of chemicals. The group held its second Joint AIA/ASD REACh Workshop – with assistance from its partners at ASD and NASA – in Orlando, Fla. February 27-March 2. The meeting brought together 60 AIA, ASD and NASA representatives for a week of planning and strategizing.
ASD members briefed the group on the latest REACh developments from the EU and on discussions with representatives from the EU ministries and government departments that are responsible for implementing, interpreting and enforcing the REACh requirements. A frequent topic of discussion was the unique procedures the aerospace industry is required to use when working with specific substances.
AIA members reported on the RWG’s progress in developing tools and processes for tracking and identifying targeted substances through the aerospace global supply chain, communicating with suppliers on REACh requirements and managing the business risks which may develop from REACh regulation. AIA and ASD members also reported on their respective and joint progress as both continue to research and qualify alternative substances to ensure that REACh does not interrupt the aerospace manufacturing process.
Much like the products it supports, the REACh Working Group also has a long lifespan. The REACh regulation is at the beginning of its 10 year implementation period and has only just begun to review the thousands of substances it plans to address. Additionally, REACH has begun to spread. The U.S. EPA recently signed an agreement with the European Chemical Agency to share data collected through REACh. Other nations are in various stages of creating programs that mirror REACh in scope as well. With these developments, REACh and its counterparts will remain a global challenge for the aerospace industry.
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