Briefing for the Department of Defense

EU REACH: Registration, Evaluation, Authorization and Restriction of Chemicals

July 16, 2008

What this presentation will cover

How the aerospace industry is addressing REACH

REACH impacts on military equipment and suppliers, including the defense exemption

What can be done to protect DoD’s capabilities

 

Aerospace industry work on REACH

AIA (Aerospace Industries Association) &

ASD (Aerospace and Defense Industries Association of Europe)

Standards Development

1) Substance Declaration Standard (SAE& ASD Stan)

2) Generic Aerospaceuses list

Interpretation&

Communication

1) Defense Exemptions2) GHS

3) Article Suggestions4) Other industry guides

InformationTechnology

1) Supply Chain DataExchange

2) External Repository3) Internal Database

Surveillanceof Substances

1) SVHCs tracking inProducts

2) Authorization work (SEAs etc)

3) Obsolescencemanagement

Dissemination& Training of

Suppliers

1) Trainingdomestically

2) REACH InformationPackets

3) Follow-Up

Registration

1) Shared SIEF work(Third Party usage)

2) Shared Downstream userChemical Safety

Report work3) ‘Use’ Library

REACH impacts

In Foreign Military Sales DoD likely having REACH obligations for providing data

DoD needing to ensure its uses are covered

REACH records becoming a source of commercial and military intelligence if the right protective measures are not in place

Disruption of supply chain due to lack of awareness

REACH impacts

Increased costs due to circumstances including:

o Reduced availability of substances, where suitable alternatives may not be available

o Analysis and tracking of hazardous materials in articleso Development and maintenance of data collection efforts for the

supply chain

Decision made by suppliers outside/inside the EU that production of certain substances is not economically feasible

Removal of EU banned substances from the product, changing product composition impacting design and requiring extensive testing, re-qualifications, change management controls, and drawing changes

REACH impacts – Defense Exemption

REACH applies to all defense products BIG and small including component parts and raw materials

There is no guarantee of a defense exemption

If there is no strong consistent defense exemption and/or some member states have defense exemptions but others do not, there will be inconsistency across the EU

Without a strong defense exemption, industry may be legally obliged to declare classified information to EU Authorities

When could DoD feel REACH impacts?

It could be anytime, a few scenarios:

During Foreign Military Sales

Maintenance/Sustainment of Military equipment at EU sites

If/when costs increase due to substance disclosure requirements, substitution of substances, registration fees...

If a company in the DoD supply chain decides to discontinue a substance or does not meet its REACH obligations

What can be done to protect DoD’s capabilities?

Participate proactively in crafting appropriate defense exemptions with EU member states

Establish a joint DoD/Industry team to identify critical substances and sources of supply, and research on environmentally-safe alternatives. Provide funding for research

Ensure education on the REACH requirements for OSD and its associated service offices

Develop means to flow REACH requirements to military contracts

Communicate REACH path-forward and data requirements to suppliers

Questions

Additional Slides

Substances in our Products and Processes

Declarable Substances

All substances

ECHA Candidate List

Annex XIV

Relevant to specific sector Aero, defense, Space…

High Risk

Substance Declaration Standard

Standard provides a form for providing information on the chemistry of components (Published by ASD-Stan and SAE):

1. Requestor Item # 2. Supplier Item # 3. Supplier Item Name    

0 0 0    

4. Prepared By: * 4a. Preparer's Title 4b. Preparer's Phone*   4c. Preparer's Email*

         

5. Weight of Item, as Delivered, excludes

packaging (Actual weight, not shipping weight - )*

5a. Unit (Drop Down (Lbs / Kg)

     

         

6. Item DOES NOT contain any chemicals listed below in amounts > 0.1% Wt %. Review all the substances found in the Item referenced in this request, and compare them to the CAS #s listed on Tab 5 - TR 9536. Choose the Checked box if this statement is true (Check Box). If this statement is TRUE, there is no need to complete the list on Tab 5 - TR 9536 Detailed List

Check box to the left if statement above is true    

7. Item DOES contain chemical(s) listed below in amounts > 0.1% Wt %. Review all the substances in the Item referenced in this request, and compare them to the CAS #s listed on Tab 5 - TR 9536. Choose the Checked box if this statement is true (Check Box). If this statement is TRUE, then Tab 5 - TR 9536 Detailed List, must be completed

Check box to the left if statement above is true  

Note: Additional requests for information to your suppliers of chemicals beyond MSDS data may be required to accurately complete this Substance Declaration. Not all substances will be identified on an MSDS. Also, proprietary constituents and % composition ranges listed in an MSDS may not be accurate enough for this declaration. We recommend using this same standard format for those requests down your supply chain.

 

Aerospace Industries Association

• AIA was founded in 1919, only a few years after the birth of flight

• Today, more than 100 major aerospace and defense companies are members of the association, embodying every high-technology manufacturing segment of the U.S. aerospace and defense industry from commercial aviation and avionics, to manned and unmanned defense systems, to space technologies and satellite communications

• In addition, the association has more than 175 associate member companies, all of which are leading aerospace and defense suppliers

Aerospace Industries Association

AIA represents the nation’s leading designers, manufactures, and providers of:

Military, civil, and business aircraftHelicoptersUnmanned aerial vehiclesSpace systemsAircraft enginesMissilesMaterial and related componentsEquipmentServicesInformation technology

Aerospace Industries Association

A Few Facts and Figures:

•Sales: 2007 sales reached $199 billion

•Foreign trade balance: The total for 2007 reached $60 billion. Exports totaled $97 billion and imports $37 billion

•Employment: Aerospace employment continues its steady climb. Employment reached 651,700 in the first quarter of 2008