REACH Authorisation Work Group Purpose

The EU REACH Regulation prohibits the supply or use of certain chemical substances within the European Economic Area (EEA) unless the user, or a supplier in the same supply chain, has an Authorisation in place.  Several of these substances are used in numerous products and applications critical to production, operation and maintenance in the aerospace and defence (A&D) industry.  Failure to have in place the necessary Authorisation(s) may interrupt continuity at any point in the supply chain, which could be catastrophic to our industry sector.

While the A&D industry continues to make all efforts to implement the use of suitable alternatives with reduced human health and environmental impact, the pace of change poses challenges.  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.  Full industrialization of alternatives in the supply chain and at manufacturing and maintenance sites also requires time.  Often, implementation of alternatives cannot be completed before the established sunset dates for the substances have passed.  It is therefore necessary for the A&D 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 every point in the supply chain at which these substances are supplied or used.  WG5 carries out supply chain mapping activities to better understand the risk associated with specific substances.  The results produced from this surveillance activity provide us with the insight member companies need to make informed decisions around Authorisation. It is essential to gather as much information as possible about the use of these substances in order to determine the need for the supply chain to obtain Authorisation. Failure to contact and involve relevant suppliers could lead to a critical material or use being overlooked, and may hinder the industry’s ability to support applications for Authorisation by relevant actors within the supply chain. The consequences for all involved are serious, affecting suppliers and customers, as well as, Work Group member companies.

The entire aerospace supply chain will benefit from participating in surveys that the Work Group’s appointed consultants are performing on our behalf.

Overview of WG5 Activities

• SVHC (Substance of Very High Concern) Matrix
  • An SVHC  summary maintained by a WG5 consultant that includes:
    • All Annex XIV SVHCs
    • All proposed Annex XIV SVHCs (including Recommendation List number)
    • All Candidate List SVHCs, including CAS numbers in scope of the entry but not identified in ECHA entry
      • This information is taken from IAEG WG1 RSL/AD-DSL research and may be verified by WG5 consultant
    • Status and intel on prioritisation status and timing
    • Links to relevant ECHA and EC documents relating for each SVHC
  • Matrix of Aerospace and Defence Authorisations, including links to all relevant documents and decisions related to each Authorisation
  • Although this information is publicly available and often kept by each company independently, WG5 members appreciate having a common source to keep it up to date.  In addition, our consultants have strong working relationships with the European Chemical Agency and European Commission members, and often have information from meetings and discussions regarding prioritisation that members may not immediately have.
• Supply chain mapping activities for SVHCs (typically those recommended or newly added to Annex XIV. 
  • Activities under this task, facilitated or performed by a WG5 consultant, include:
    • Background / trade studies of the SVHC(s)
    • Member survey of SVHC uses (anonymised and aggregated by the consultant before sharing, often as a list of formulations containing the SVHC)
    • Formulator interviews, as necessary, depending on SVHC
    • If deemed necessary, supplier survey, sent to those suppliers provided by WG5 members to our consultant (anonymised and aggregated)
    • Informational webinar for suppliers prior to the launch of a WG5 supplier survey of SVHC uses
    • Review, discussion, assessment of uses and outcome of survey
    • Final report from Supplier
  • SVHCs mapped to date include:
    • 9^th Recommendation SVHCs
    • February 2020 Additions to Annex XIV
    • Short Chain Chlorinated Paraffins (SCCPs)
    • Bisphenol A
    • Anhydrides (HHPA & MHHPA)
    • June 2017 Additions to Annex XIV (excluding NPEs/OPEs, which were mapped separately)
    • Nonylphenol ethoxylates (NPEs) and Octylphenol ethoxylates (OPEs)
    • Cadmium and its compounds
    • Borates
    • Refactory Ceramic Fibers (RCFs)
    • Annex XIV-listed Hexavalent Chromium Cr(VI) substances
  • Members review the information both within their own company and as a WG member.
  • Member companies use this information to assist in making informed decisions regarding the need to form or join an Authorisation consortium for at-risk substances
  • All of these final reports are available to new IAEG members for an additional one-time fee of $10K
     
• Tools for Authorisation Consortia and Applications for Authorisation:
  • Pre-consortium and consortium agreement templates
  • Authorisation application process / procedure aids
  • White papers on the A&D industry relating to Authorisation, including streamlined standard overviews of the Change Management Process and airworthiness approval scheme to be used for education and future Authorisation dossier
  • Supply chain communications on Authorisations relevant to the A&D industry
  • Aggregation of members and service providers’ experience and knowledge regarding Authorisation process and application content
  • Some of the above are still under development

Successes

In addition to the above activities, interested WG5 members have launched 2 Authorisation consortia, after completing supply chain mapping activities, and assessing their risk based on the output:        

• Global Chromates Consortium for Aerospace (GCCA) was launched in 2015, by interested WG5 members after completing our chromates mapping, and prepared seven upstream Authorisation applications to support the aerospace and defence industry
• Ethoxylates in Aerospace Authorisation Consortium (EAAC) was launched in 2018 by interested WG5 members after completion of the NPE/OPE supply chain mapping task, and prepared two upstream Authorisation applications to support the aerospace and defence industry’s use of NPE and OPE-containing polysulfide sealants.

IAEG WG5 membership fees can be viewed by individual companies as a very inexpensive consulting fee.  In addition to cost-sharing the expertise of key REACH consultants, members are collaborating with some of the key REACH experts in the aerospace industry.

As quoted by the WG5 chair “I personally can’t imagine being able to do my job without the support of WG5 and its members.  Although we may be competitors, customers and suppliers of each other, we work very collaboratively in the framework of the WG.”

Benefits of WG5 Membership Summary

• Access to WG5-proprietary intelligence, essential for informed decision-making regarding REACH Authorisation
• Access to experience and knowledge of members and service providers regarding Authorisation process and application content
• Access to white papers on the A&D industry relating to Authorisation, including streamlined standard overviews of the Change Management Process and airworthiness approval scheme to be used for education and future Authorisation dossiers. 
• Process efficiencies through consistency of approaches and argumentation.
• Identification of potential providers of consortia management and technical expertise.