• Work Group 5 - REACH Authorisation

Latest Updates

Date

Title and Links To Information

4 December 2018

Slides: Bisphenol A, HHPA & MHHPA - REACH Authorisation Regulatory Implications and Supply Chain Mapping (pdf file)

4 December 2018

Webinar: Bisphenol A, HHPA & MHHPA - REACH Authorisation Regulatory Implications and Supply Chain Mapping

27 October 2017

Status on REACh Authorisation of Chromates (pdf file)

(including critical information and compliance obligations for “downstream users”)

7 September 2017

NPE and OPE Webinar Slides (pdf file)

7 September 2017

Webinar : NPE and OPE

26 January 2017

Cadmium & Cadmium Compounds Webinar Slides (pdf file)

26 January 2017

Webinar:  Cadmium & Cadmium Compounds

Work Group 5 Objective(s)

  • Understand the use of substances in the aerospace supply chain
  • Identify risk in the supply chain
  • Determine REACH Authorisation intentions
  • Facilitate the creation of Authorisation Consortia as required following a structured process that can be repeatedly used

Purpose

In accordance with the EU REACH Regulation, the supply or use of certain chemical substances within the European Union (EU) will be prohibited unless the user, or a supplier in the same supply chain, has an Authorisation in place. These substances are known to be used in numerous products and applications critical to production, operation and maintenance in the aerospace industry.  The supply of these products may be interrupted at any point in the supply chain by the failure to have in place the necessary Authorisation, which could be catastrophic for our industry sector.

In the aerospace industry, all efforts are being made to identify, validate, and seek airworthiness approval for the use of suitable alternatives. The pace of change poses challenges for us. Work continues within the industry in the pursuit of alternatives with reduced environmental impact. However, from the point at which a potential alternative becomes available, extensive empirical data is required to establish flight safety and airworthiness, which takes an extended period of time. Often it will extend beyond the established sunset date for the substances. It is therefore necessary for the aerospace industry to develop an approach to Authorisation that engages all of our supply chain.

To support continuity of supply and the continued use of certain key substances, we need help to identify each point in the supply chain at which these substances are supplied or used. We have chosen to carry out supply chain mapping activities which essentially will allow us to better understand the risk associated with specific substances. The results produced from this surveillance activity will provide us with the insight we need to make informed decisions around Authorisation. It is necessary to gather as much information as possible about the use of these substances in order to determine the intentions of the supply chain to obtain Authorisation. Failure to contact and involve relevant suppliers could lead to a critical material or application being overlooked, and may impact our ability to support applications for Authorisation by relevant actors within the supply chain. The consequences for all involved are serious, affecting our suppliers and our customers as well as ourselves. (See Box 1 below for all our Supply Chain Mapping Activity to date.)

Box 1:  Supply Chain Mapping Activity Matrix

Substance Name

Launch Date

Completion Date

Cr+6 Substances

March 2015

June 2015

RCFs

March 2015

June 2015

Borates

2Q2016

2Q2016

HHPA / MHHPA

3Q2016

4Q2016

Cadmium and Compounds

1Q2017

3Q2017

Nonylphenol ethoxylates / octylphenol ethoxylates

3Q2017

4Q2017

(est.)

June 2017 Annex XIV additions to Annex XIV (excluding NPE/OPE)

4Q2017

4Q2017

(est.)

We recognize that the aerospace supply chain is both extensive and complex. Therefore we need help from all our suppliers. As a start please go through our Checklist of possible sources for substance information. (See Box 2 below.)

 Box 2: Checklist of Sources for Identification of Substance Use

Where to Check for Substance Use (guidance to get you started)

Constituent ingredients listed in Safety Data Sheets (SDS) or Material Safety Data Sheets (MSDS)

Information held by R&D, technical, production and quality control personnel

Purchasing Records

Bills of Material

Product Labels

Engineering

Product Specifications or Operating Procedures

Other sources

The entire aerospace supply chain will benefit from participating in surveys that we, and/or our appointed consultants operating on our behalf, send for information gathering purposes. If you are asked to participate in our surveys and would like verification of authenticity, or would like to volunteer information, please contact anyone from the list of participants. (See below in Box 3.)

We are creating a body of knowledge and expertise in the international aerospace industry that will collaboratively work to support REACH Authorisation activities for global business continuity.

Box 3: IAEG WG5 Participating Companies and corresponding contact details

Name

Contact Name

Contact email address

Aviall Service, Inc. (Boeing Company)Douglas Howie

REACH@aviall.com

AirbusOlivier Barret

olivier.barret@airbus.com

Airbus Helicopters

Christine Triai

christine.triai@airbus.com

BAE Systems

 Zia Usmani

 zia.usmani@baesystems.com

Boeing Company

 Paul Hogben

 paul.r.hogben@boeing.com

Bombardier Aerospace

Angela Lyttle

angela.lyttle@aero.bombardier.com

Cobham Plc.

Jeff Woodlee

jeff.woodlee@cobham.com

Dassault

Sarah Vonach

sarah.vonach@dassault-aviation.com

Embraer S/A

 Venancio Neto

 venancio.neto@embraer.com.br

GE Aviation

 Rachel Becker

 rachel.becker@ge.com

Gulfstream Aerospace Corp

 William Sherrod

 bill.sherrod@gulfstream.com

Honeywell

Brian Terry

brian.terry@honeywell.com

Lockheed Martin

Scott Fetter

reach.info@lmco.com

Mitsubishi Aircraft Corporation

Kaz Fujihara

 kazuyoshi_fujiahra@mitsubishiaircraft.com

Northrop Grumman

Jen Imhoff

Jennifer.Imhoff@ngc.com

Pratt & Whitney (UTC)

Erin Yaeger

Reach.Compliance@pw.utc.com

Pratt & Whitney Canada (UTC)

Valerie Bilodeau

 reach.compliance@pwc.ca

Raytheon Company

Martin Mennie

 global_substances@raytheon.com

Rolls-Royce

Phil Humphries

 reach.programme@rolls-royce.com

Safran

Pascal Delannoy

pascal.delannoy@safrangroup.com

Textron Aviation

Jordan McNally

reach@txtav.com

Thales

Aurélie LECLERC

 aurelie.leclerc@thalesgroup.com

UTC Aerospace Systems

Kate Goldstone

REAChUS@utas.utc.com

Contact:  Christer Hellstrand