The impact of REACH on the aerospace sector - a DU s perspective & response

Transcription

1 The impact of REACH on the aerospace sector - a DU s perspective & response Nigel Marsh, Company Head of Environmental Management UK REACH Competent Authority Roadshows November/December 2007 Issue Rolls-Royce plc The 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 plc. This 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 companies.

2 A Downstream User s Perspective 2 The potential impact of REACH on the aviation sector and its global supply chain How Rolls-Royce is responding to REACH Concerns and advice on implementation

3 Rolls-Royce Group plc 3 Power for air, sea and land Annual sales 7+ billion ( 24bn order book) Customers; 500+ airlines, 4,000 corporate and utility aircraft and helicopter operators, 160 armed forces and more than 2,000 marine customers, including 50 navies. Energy customers in nearly 120 countries 38,000 employees in 50 countries A Global company with a Global Supply Chain

4 REACH scope 4 Importation Manufacture Placing on the market Use of substances Importation On their own In preparations In articles Trichlorethylene Paints, Sealants, Resins Systems, Components, aircraft

5 What REACH means to Rolls-Royce 5 Rolls-Royce as an importer (?) Alloys - preparations (bar, billet, specialist metallic powders etc) Processing chemicals (drums of chemicals and powder preparations etc) Imported finished articles (with no intended substance release) Contracts on non-eu suppliers will have to change to obtain information to complete registration.

6 What REACH means to Rolls-Royce 6 Rolls-Royce as a downstream user Making articles out of preparations, and using preparations / substances during manufacture and R&O Making some preparations (eg, thermal paints) Conducting Product and Process Oriented Research and Development (PPORD) with suppliers

7 What REACH means to Rolls-Royce 7 Rolls-Royce as a downstream user Check whether SVHC are in products following manufacture, at > 0.1% w/w Check all our uses are registered Substances used in PPORD will require notification to the Agency, and will probably avoid SVHCs (including candidate substances)

8 What REACH means to Rolls-Royce 8 Rolls-Royce as a user of substances of very high concern (SVHC) Using SVHCs within alloys, within process chemicals Unable to change quickly to alternatives (air worthiness) In some cases, there may be no alternatives

9 What REACH means to Rolls-Royce 9 Rolls-Royce as a user of substances of very high concern (SVHC) Rolls-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 Authorisation.

10 RR As a Downstream User 10 REACH is aimed primarily at manufacturers and importers of chemicals RR will mainly be a downstream user and therefore fall outside much of the REACH burden However, for strategic, niche/small market materials and targeted substances we will need to ensure that suppliers are REACH compliant We will be an importer of articles from all over the world and this brings responsibilities, especially when SVHC are involved We expect to have significant involvement in SEA

11 Some Aerospace Issues Low use speciality products may be removed from the market (uneconomic for the manufacturer to put through REACH) Some substances will be liable for Authorisation for continued use Will need to register any substances that we import into the EU where we are the only importer and may need to directly register novel uses of substances in our operations. We will also need to ensure that suppliers/rr companies complete pre-registration We may need to register/notify substances in imported articles (intended release??) Supplier awareness & security of supply? Costs of supply will most likely increase Data will need to be passed along the supply chain - exchange of information could have implications for commercial confidentiality and intellectual property rights Internal company resource to support REACH Development of lists of targeted substances/timetables and align elimination/substitution programmes Unique Industry issues - Product life cycles, safety and reliability 11

12 Purchasing impact of REACH 12 Changes will be needed in purchasing practice a new way of working Closer ties with engineering, design and manufacturing functions Cost, Quality, Delivery + REACH compliance May need to place contractual requirements on suppliers regarding a responsibility to register and obtain any relevant authorisations

13 REACH COMPLIANCE Continued access to substances: 13 Registration for an imported or manufactured substance is the right to bring onto the market irrespective of hazard or risk posed by the substance, OR it will be illegal: to PURCHASE the substance to use the substance IN PRODUCTS Authorisation is the right to use a substance - including presence in an article if the substance is considered of very high concern Communication you must tell your customer if an article you sell to them contains SVHC at >0.1% w/w

14 Priority for 14 replacement CANDIDATE LIST List of all substances that meet the criteria for Authorisation 1,800-2,500 Substances? Pressure on continued use ANNEX XIV LIST: List of Subs. SUBJECT to Authorisation ECHA WORK PROGRAMME

15 Helping aviation businesses understand REACH 15 Banned / 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 industry Banned / Targeted list Annex XIV = substances submitted to authorisation Priority SVHC Known SVHC ALL REGISTERED SUBSTANCES Newly Classified SVHC

16 Ranking for REACH Authorisation Priorities? 16 Still not finalised but will be something like.. Priority 1: Cat A substances (PBT, vpvb or equiv concern - other ) x wide dispersive use Priority 2: Cat B substances (Carc & Mut 1&2 nonthreshold) x wide dispersive use Priority 3: Cat C substances (rest) x wide dispersive use OR Cat A non-dispersive use Then it becomes unclear (algorithm s complexity)

17 Substances of concern eg R50/R53 17 Very toxic to aquatic organisms, may cause long-term effects in the aquatic environment Eg s: Alochrom, Ardrox, chromic acid, colbalt oxide, copper chloride, resins, paints, potassium cyanide, potassium permanganate, sodium chromate, sodium cyanide, thermal paints..

18 Other examples of substances of concern: 18 Trichloroethylene Chromium (6) Cadmium Beryllium Nickel oxides PTFE Kevlar

19 Enforcement 19 The manufacture, import, sale, supply or use of substances without the appropriate registration Using hazardous substances outside the terms of an authorisation or contrary to a restriction Failure to provide required information up and down the supply chain Failure to comply with other duties regarding information, eg, workers or consumers rights of access to information Failure to comply with the duty to apply recommendations, eg, in safety assessments Failure to comply with the duties to co-operate and supply information (in a timely manner)

20 Rolls-Royce Approach to REACH: The most cost effective solution is for a centrally co-ordinated/consistent approach: One defined process for the Group Formation of a Corporate IPT >> Operations Council REACH Executive appointed Purchasing and laboratories have a key role to play (make to Print, Design Make and Consumables) Engineering, Design, Manufacturing Operations, Repair & Overhaul ~ 12 FTEs currently 20 FTE by end

21 A voice for the industry.. 21 ASD REACH Task Force (lobbying >>> focus on implementation) RIPs Alliances with other industry groups and trade associations

22 Helping our Supply Chains Understand REACH 22 Significant outreach and awareness raising including supplier workshops ASD (EU)- Paris Airshow launch of Implementation Guidelines SBAC (UK) EWG AIA (North America)

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24 Managing the Issues: Collaboration 24 The 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 sharing Working with DEFRA and HSE (CA) (in the UK)

25 Working With the European Commission and ECHA 25 Various companies across ASD, SBAC and GIFAS are representing our sector in REACH IMPLEMENTATION PROJECTS (RIPs) The RIPs will generate TECHNICAL GUIDANCE DOCUMENTS (TGDs) to help businesses find their way through the legal maze

26 Chemical Producer 1 Pb Communication through Supply Chain US/EU Supplier 1 Spec ## Antigallant US EU Repair shop 26 Chemical Producer 2 CdO & Ni(SO 3 NH 2 ) 2.4H 2 O Chemical Producer 4 (Importer) CrO 3 (e.g.) Chemical Producer 5 (Importer) Fe Supplier 2 Steel alloy Forger/Part Producer Steel alloy disc Plater Steel alloy disc w/ AMS## NiCd plating, conversion coat, & Spec ## antigallant Large, Complex Component Producer Engine Airframer Aircraft Airline Preparation Importer (Supplier 1) Appoint only representative or provide info to importer to: pre/register by use provide SDS or reg #/auth/restrict info Information on substances intended to be released or SVHC on candidate list contained in article will need to be collected through specs, MSDS or contractual requirements Article Importer Register substances intended to be released For SVHC on candidate list, notify Agency provide safe use info Article D/U Register uses not covered by substance M/I For SVHC on candidate list, provide safe use info?? Pass identified uses and hazard/risk info to next actor in supply chain Courtesy of AIA

27 Some current concerns Business continuity continued access to materials Legal entities (defined locations) Importer Access to IT tools & IUCLID5 Data collection!! Pre-registration (for strategic substances) RIPs Representation at EU/ECHA level Supply chain awareness (7 000 UK Companies) Defence exemptions Enforcement Provision of information 27

28 Business Priorities Senior management commitment (& resource) Ownership appoint a champion Awareness Inventories of substances & preparations (& REACH responsibilities eg, Importer) SVHC Candidate List (0.1%) Identify priority substances Substitution programmes (R&D) Pre-registration (08) Checking that the supply chain are going to meet their obligations for registration Collaboration with partners, competitors and trade bodies 28

29 29 End of Presentation Thank you for listening CONTACT DETAILS: +44 (0) nigel.marsh@rolls-royce.com