Have you been REAChed?
It’s been called the world’s toughest law on toxic chemicals. We know it as REACh. It’s the acronym for the Registration, Evaluation, Authorisation and Restriction of Chemical substances, a European Community law that entered into force in June 2007 to regulate chemical usage throughout the EU. REACh is so complex and its potential impact so broad regarding the aerospace industry that AIA must be fully engaged during the regulation’s 11-year phase-in period.
The EU intended REACh “to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances.” By design, the REACh Regulation puts the onus on industry to manage chemical risks and to provide safety information on the substances it uses and produces. REACh requires manufacturers and importers of products to the EU countries to report detailed chemical substance information on their products.
The reported data is then registered into a central database run by the European Chemicals Agency (EChA) in Helsinki. The EChA is the focus of the Reach framework. EChA:
- determines which chemicals are subject to the law;
- coordinates the in-depth evaluation of chemicals;
- collects the registered data, and
- hosts the public database containing registered information.
Many aspects of REACh concern the aerospace industry. There are logistical and cost concerns with simply collecting the level of chemical detail that the rule requires. There are proprietary concerns associated with the public availability of product chemistry. Perhaps most troubling is the regulation’s stated objective to progressively substitute substances that EChA identifies as “the most dangerous chemicals” when EChA determines that “suitable alternatives have been identified.”
The potential for chemical substitution in the manufacture of strategic products also concerns the Defense Department. DOD recognizes that expected outcomes for products associated with REACh may include:
- limited availability of key chemical ingredients,
- increased costs,
- undisclosed substitution of key chemicals,
- disruptions to the supply chain and
- decreased product performance or performance failures.
AIA is not alone, nor is AIA passively monitoring REACh as the EChA progresses through its 11-year plan to implement the REACh program. The AIA REACh Working Group, co-chaired by Dennis Hussey of Goodrich and Sally Gestautas of Raytheon, begins its fourth year with an ambitious agenda. Projects this year will build upon current and past activity to prepare the aerospace industry for the full impact of REACh.
Materials used in past AIA training sessions were recently updated and are now posted on the AIA web site. A key AIA goal is to inform the complete aerospace supply chain of REACh requirements in order to facilitate accurate exchange of chemical product data. AIA members recognize that many suppliers do not have the resources to address REACh on their own.
AIA is working to standardize information collection among aerospace companies world-wide. An international standard was developed and is managed through AIA member direction with our SAE-aerospace panel.
Key partners in these tasks include AIA’s sister organizations, AeroSpace and Defence Industries Association of Europe (ASD) and A|D|S. Our international partnerships will continue as our organizations review the lists of chemicals announced by EChA and identify substances key to the industry. DOD is also working with AIA to identify a multitude of issues that will need to be addressed as REACh is implemented. These issues include research and development needs and the defense acquisition process, to name just two.
AIA and our colleagues plan to address these challenges jointly to ensure continuity of operations in the aerospace industry.
AIA Source: Lisa.Goldberg[at]aia-aerospace.org
