How far downstream is downstream? Phil Humphries Chair - ASD REACH Working Group on Authorisation. 19th June Slide 1
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1 2012 AerSpace and Defence Industries Assciatin f Eurpe The infrmatin in this dcument is the prperty f AerSpace and Defence Industries Assciatin f Eurpe (ASD) and may nt be cpied r cmmunicated t a third party, r used fr any purpse ther than that fr which it is supplied withut the express written cnsent f ASD Hw far dwnstream is dwnstream? Phil Humphries Chair - ASD REACH Wrking Grup n Authrisatin 19th June 2012 Slide 1
2 These phtgraphs are reprduced with the permissin f Rlls-Ryce plc, cpyright Rlls-Ryce plc 2010 Eurpean Aerspace and Defence Industry 137bn Eurs turnver 20 cuntries 2000 cmpanies 80,000 suppliers 676,000 emplyees Slide 2
3 Aerspace/Defence and REACH The Aerspace/Defence sectr fully supprts the intent f REACH Aerspace is als regulated by EC1702/2003 (EASA) which fcuses n prduct safety Prduct changes require substantive evidence f safety t maintain airwrthiness Alternative materials are being develped, but where nt validated, we must priritise airwrthiness Repair f existing prducts ften dependent n materials we d nt wish t use in the future Changes cannt always be made at shrt ntice Disruptin f existing substance supply is ur biggest cncern Slide 3
4 Authrisatin Cncerns Aerspace/Defence have sme key cncerns regarding REACH Aerspace/Defence are dependent n a number f substances that will require authrisatin Prven and safe alternatives research takes many years, is in prgress, but unlikely t be fully successful in the timescale Authrisatin is a new and cmplex prcess Supply chain cmplexity adds many challenges There are unreslved risks in the Authrisatin prcess Failure is nt an ptin We can nly d this nce, have n chice, and need time t get it right Slide 4
5 Hw far dwnstream are we? Slide 5
6 Supply Chain Cmplexity Chemical Cmpany Distributrs Chemical Cmpany Imprters Lng and Cmplex Supply Chains, 8 r mre layers Thusands f 1 st tier cmpnent suppliers Frmulatr Distributr Distributr Imprters Prcessrs SME SME SME SME SME SME Machinists SME SME SME SME Supplier Supplier SME Prduct Cmpany System Integratr Many mid-chain players are small SMEs & distributrs REACH knwledge in midsupply chain is pr N visibility frm ne end t the ther Cmmunicatin thrugh this supply chain is difficult and slw Slide 6
7 Applicants and Cnsrtium Limitatins Λ Apprach M/I is Applicant Cvers multiple industries with different risks & ecnmic drivers Aerspace element ptentially inseparable frm the rest V Apprach DU is Applicant Only Authrises DU and immediate supplier(s) Nt practical fr cmplex supply chains Hybrid/Cmbinatins Other ptins depending n supply chain and uses Structure and stakehlder management are key Engagement and cperatin f M/Is paramunt Slide 7
8 Crss-Sectr View Chrmium Trixide SUPPLY CHAIN ROLE Manufacture / Imprt Distributin Frmulatin Distributin Prcessing 9 Mnths t frm cnsrtium Preliminary reprt 94 pages, guiding structure nly Being structured arund Uses, nt prduct sectrs Aerspace nt distinct frm ther sectrs Unclear whether this will wrk Manufacture Sub-Assembly End Prducts PRODUCT SECTORS USES Slide 8
9 Cncerns expressed by the Aerspace/Defence sectr There culd be Business and supply chain disruptin due t: - Nn-registratin f substances r nn cverage f use - Nn-authrizatin f substance uses - Obslescence We must manage the administratin and flw f data t be exchanged thrughut the supply chain whilst ensuring cmpliance There are signiicant additinal R&T csts, in particular linked t the develpment/qualificatin f alternatives and the adaptatin f prcesses t match safety requirements (See cncern 6) Hrizn 2020? Slide 9
10 Hw yu can help If yu think yu might want t withdraw a substance let us knw befre yu d We may be able t help yur business case We will need time t find an alternative supplier We may supprt a ptential authrisatin applicatin Where we knw them, we have cntacted ur suppliers with ur uses fr registratin, but this may take a while t get back t yu. Please include ur uses r let us knw if yu are nt ging t Where we need authrisatin we need a lead applicant Manufacturers/distributrs/frmulatrs can cver all f the dwnstream uses, we can nly cver ne upstream supplier s uses Slide 10
11 Summary Aerspace/Defence are dependent n many substances, particularly Chrmates at this time fr safety reasns Prven and safe alternatives research takes years, is in prgress, but unlikely t be fully successful in the timescale Authrisatin is a new and cmplex prcess Supply chain cmplexity adds many challenges There are unreslved risks in the Authrisatin prcess We need t knw if the supply chain fr chemicals and substances we use is ging t change Yu can help 1 Cmmunicate! 2 Cmunicar! 3 Cmmuniquer! 4 Kmmunizieren! 5 Cmunicare! Slide 11
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