The impact of REACH on the aerospace sector - hse.gov.uk

1 2007 Rolls-Royce plcThe information in this document is the property of Rolls-Royce plc and may not be copied or communicated to a third party, or used for any purpose other than that for which it is supplied without the express written consent of Rolls-Royce information is given in good faith based upon the latest information available to Rolls-Royce plc, no warranty or representation is given concerning such information, which must not be taken as establishing any contractual or other commitment binding upon Rolls-Royce plc or any of its subsidiary or associated impact of REACH on the aerospace sector -a DU s perspective & responseNigel Marsh, Company Head of Environmental ManagementUK REACH Competent Authority RoadshowsNovember/December 2007 Issue 12A Downstream User s PerspectivezThe potential impact of REACH on the aviation sector and its global supply chainzHow Rolls-Royce is responding to REACHzConcerns and advice on implementation3 Rolls-Royce Group plczPower for air, sea and landzAnnual sales 7+ billion ( 24bn order book)zCustomers; 500+ airlines, 4,000 corporate and utility aircraft and helicopter operators, 160 armed forces and more than 2,000 marine customers, including 50 navies.

2 Energy customers in nearly 120 countriesz38,000 employees in 50 countrieszA Global company with a Global Supply Chain4 ManufacturePlacing on the market UseImportationImportationREACH scopeof substancesOn their ownTrichlorethyleneIn preparationsPaints, Sealants, ResinsIn articlesSystems, Components, aircraft5 What REACH means to Rolls-RoyceRolls-Royce as an importer (?)zAlloys -preparations (bar, billet, specialist metallic powders etc)zProcessing chemicals (drums of chemicals and powder preparations etc)zImported finished articles(with no intended substance release)zContracts on non-EU suppliers will have to change to obtain information to complete REACH means to Rolls-RoycezMaking articles out of preparations, and using preparations / substances during manufacture and R&O zMaking some preparations (eg, thermal paints)zConducting Product and Process Oriented Research and Development (PPORD)

3 With suppliersRolls-Royce as a downstream user7 What REACH means to Rolls-RoycezCheck whether SVHC are in products following manufacture, at > w/wzCheck all our uses are registeredzSubstances used in PPORD will require notification to the Agency, and will probably avoid SVHCs(including candidate substances)Rolls-Royce as a downstream user8 What REACH means to Rolls-RoycezUsing SVHCs within alloys, within process chemicalszUnable to change quickly to alternatives (air worthiness)zIn some cases, there may be no alternativesRolls-Royce as a user of substances of very high concern (SVHC)9 What REACH means to Rolls-RoyceRolls-Royce specifiers, purchasers, designers and technical experts will need to work with customers(who may specify SVHC use) and suppliers(who may have a technical necessity to use SVHC) to prove the need for each SVHC within any as a user of substances of very high concern (SVHC)

4 10RR As a Downstream User zREACH is aimed primarily at manufacturersand importersof chemicalszRR will mainly be a downstream user and therefore fall outside much of the REACH burdenzHowever, for strategic, niche/small market materials and targeted substances we will need to ensure that suppliers are REACH compliantzWe will be an importer of articles from all over the world and this brings responsibilities, especially when SVHC are involvedzWe expect to have significant involvement in SEA11 Some aerospace IssueszLow use speciality products may be removed from the market (uneconomic for the manufacturer to put through REACH ) zSome substances will be liable for authorisation for continued usezWill need to register any substances that we import into the EU where we are the only importer and may need to directly register noveluses of substances in our operations.

5 We will also need to ensure that suppliers/RR companies complete pre-registration zWe may need to register/notify substances in imported articles (intended release??) zSupplier awareness & security of supply? zCosts of supply will most likely increasezData will need to be passed along the supply chain -exchange of information could have implications for commercial confidentiality and intellectual property rightszInternal company resource to support REACHzDevelopment of lists of targeted substances/timetables and alignelimination/substitution programmeszUnique Industry issues -Product life cycles, safety and reliability12 Purchasing impact of REACHzChanges will be needed in purchasing practice a new way of workingzCloser ties with engineering, design and manufacturing functionszCost, Quality.

6 Delivery + REACH compliancezMay need to place contractual requirements on suppliers regarding a responsibility to registerand obtain any relevant authorisations13 REACH COMPLIANCE Continued access to substances:zRegistrationfor an imported or manufactured substance is the right to bring onto the marketirrespective of hazard or risk posed by the substance , OR it will be illegal: zto PURCHASE the substancezto use the substance IN PRODUCTSzAuthorisationis the right to use a substance -including presence in an article if the substance is considered of very high concern zCommunication you must tell your customer if an article you sell to them contains SVHC at > w/w14 CANDIDATE LISTList of all substances thatmeet the criteriafor AuthorisationANNEX XIV LIST: List of Subs.

7 SUBJECT to AuthorisationECHA WORK PROGRAMME1,800 -2,500 Substances?Pressure on continued usePriority for replacement15zBanned / Targeted list of substances-To be used by companies for forward planning-Anticipating possible obsolescence and required R & T-OEMs can target B/T list substances for phase out EARLY Future-Proofing our industryAnnexXIV= substances submittedto authorisationBanned/ Targeted listNewly ClassifiedSVHCK nownSVHCP rioritySVHCALL REGISTERED SUBSTANCESH elping aviation businesses understand REACH16 Ranking for REACH authorisation Priorities?Still not finalisedbut will be something 1: Cat A substances (PBT, vPvBor equiv concern -other ) x wide dispersive usezPriority 2: Cat B substances (Carc& Mut1&2 non-threshold) x wide dispersive usezPriority 3: Cat C substances (rest) x wide dispersive use OR Cat A non-dispersive use zThen it becomes unclear (algorithm s complexity) 17 Substances of concern egR50/R53z Very toxic to aquatic organisms, may cause long-term effects in the aquatic environment zEg s:Alochrom, Ardrox, chromic acid, colbalt oxide, copper chloride, resins, paints, potassium cyanide, potassium permanganate, sodium chromate, sodium cyanide, thermal paints.

8 18 Other examples of substances of concern:zTrichloroethylenezChromium (6)zCadmiumzBerylliumzNickel oxideszPTFEzKevlar19 EnforcementzThe manufacture, import, sale, supply or use of substances without the appropriate registrationzUsing hazardous substances outside the terms of an authorisation or contrary to a restrictionzFailure to provide required information up and down the supply chainzFailure to comply with other duties regarding information, eg, workers or consumers rights of access to informationzFailure to comply with the duty to apply recommendations, eg, in safety assessmentszFailure to comply with the duties to co-operate and supply information (in a timely manner)20 Rolls-Royce Approach to REACH .

9 The most cost effective solution is for a centrally co-ordinated/consistent approach: zOne defined process for the GroupzFormation of a Corporate IPT >> Operations CouncilzREACH Executive appointed zPurchasing and laboratories have a key role to play (make to Print, Design Make and Consumables)zEngineering, Design, Manufacturing Operations, Repair & Overhaulz~ 12 FTEs currently 20 FTE by end 200721A voice for the REACH Task Force (lobbying >>> focus on implementation)zRIPszAlliances with other industry groups and trade associations22 Helping our Supply Chains Understand REACHzSignificant outreach and awareness raising including supplier workshopszASD (EU)-Paris Airshow launch of Implementation Guidelines zSBAC (UK) EWGzAIA (North America)23 the Issues.

10 CollaborationzThe aerospace sector globally is now working on several initiatives: -ARTICLES interpretation-Standard data to be collected from suppliers for REACH -Common standards/guidelines for our sector -Supporting trade association / professional institution workshops on REACH -Provision of international training-Sharing best practice across other sectors-RIPs-Cost sharingzWorking with DEFRA and HSE (CA) (in the UK)25 Working With the European Commission and ECHAzVarious companies across ASD, SBAC and GIFAS are representing our sector in REACH IMPLEMENTATION PROJECTS (RIPs)zThe RIPswill generate TECHNICAL GUIDANCE DOCUMENTS (TGDs) to help businesses find their way through the legal through Supply Chain US/EULarge, Complex Component ProducerEngineAirframerAircraftPlaterSte el alloy disc w/ AMS## NiCdplating, conversion coat, & Spec ## antigallant Supplier 1 Spec ##AntigallantForger/Part ProducerSteel alloy discChemicalProducer 1 PbChemicalProducer 2 CdO& Ni(SO3NH2) 4(Importer)CrO3( )ChemicalProducer 5(Importer)FeAirlineRepair shopSupplier 2 Steel alloyPreparation Importer (Supplier 1) Appoint only representative or provide info to importer to.