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We last reported on the EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation in 2010 (‘Have you been REACHED?’). In two short years, REACH, once the anomaly in environmental regulation, is now the global model for chemical use restrictions. The EU REACH regulation once stood alone in rules affecting the availability of chemical inputs to industrial manufacturing. Today, REACH regulates thousands of substances, with hundreds more proposed for review, and is the standard for the many copy-cat regulations appearing around the world. South Korea, China, Canada, Brazil and the United States are currently playing catch-up to implement requirements that dictate what can and cannot be used in making products. The REACH effect is spreading around the world.
REACH is extremely complex and its potential impact on the aerospace industry so broad that AIA (through the EHS Committee’s REACH Working Group and other committees) is fully engaged and will remain so throughout the regulation’s 11-year phase-in period. The Rapid Response Network of the Engineering Management Committee composed of AIA members’ material and design engineers, was newly engaged in 2010. Today the RRN continues to add members to review substances for aerospace applications as they are proposed for regulation and potential market disappearance. REACH, and chemical restrictions in general, are also on the radar screen of AIA’s National Aerospace Standards Committee, the Technical Operations and Supplier Management Councils.
In the past two years AIA members have seen both the removal from the market and reformulation of key substances used to meet highly specific product performance requirements, including requirements that impact aviation safety. Both removal and reformulation are a concern, as the key substances may be the primary reason for those products being used by the aerospace industry. Often the substances are used because they deliver product attributes that cannot presently be achieved by other substances.
A critical deadline was reached late last year with chromates, a family of substances long recognized for their ability to prevent corrosion in metals. On November 21, the EU member states voted to place five chromate substances on the REACH authorization list. The list requires that continued use of these chromates within the EU be ‘authorized’ beyond 2017 when its existing use will expire. Authorization is lengthy, costly and uncertain and details are scarce as no substance has yet been through the process.
Sometimes just the threat of restrictions is enough to remove substances from the market. If the use of chromates becomes restricted in the EU, coating and plating bath suppliers that produce products containing chromates may depart the market; particularly if their primary customers are based in the EU and can no longer use chromates. This is a very serious concern for the aerospace industry.
Additionally, being in compliance with REACH requires companies to assume the costs of collecting the level of chemical detail that the law requires. The aerospace industry is particularly affected by proprietary concerns associated with the public availability of product chemistry. A key goal of the AIA REACH WG 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 also 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 organization, the AeroSpace and Defence Industries Association of Europe and its member state organizations. International partnerships will continue as these organizations review the lists of chemicals announced by ECGHA and identify substances key to the industry. DOD is also working with AIA to identify a multitude of issues related to research and development needs and the defense acquisition process as REACH is implemented
AIA and its colleagues plan to address these challenges jointly to ensure continuity of operations in the aerospace industry.
AIA Source: lisa.goldberg[at]aia-aerospace.org