ESA s role & activities to support Cr(VI) replacement T. Rohr ESA REACH Officer ESA HQ, Paris 02/12/2013
REACH impact on ESA Legislative aspects May lead to unforeseen liabilities Technical aspects May lead to unforeseen obsolescence Standardisation May lead to incomplete communication of PA requirements through supply chain Communication Various ESA programs may have a different strategy to tackle REACH ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 2
Assembly complexity REACH Impact Technical Aspects Possible obsolescence of qualified materials and processes: Change in materials/substances compositions Alterations of manufacturing processes Removal of materials/substances from the European market Unanticipated risks, e.g. missing of deadlines for registration Very long life-cycles (e.g. launchers 20-30 years, satellite series, platforms) need to actively manage the risk (cost trade-off) Unit Module System Obsolescence becomes a major issue with REACH, and requires appropriate management. Material, Component ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 3 Remedy costs
# Materials affected Risk assessment a joint effort short term RISK long term Cross-check of joint materials list (industry + agencies) with reference black lists. 350 300 250 Current long term estimates indicate ~ 20% of our materials may be affected. Sustainability of supply chain is at risk and requires adequate obsolescence management. 200 150 100 50 0 REACH Annex XIV + recom. REACH Candidate list SIN list (1) 2012 2013 Joint M&P WG with participation of system integrators, equipment manufacturers, suppliers, space agencies performs risk assessment based on a joint materials database. Perform risk assessment of identified materials and processes taking into account the status in the REACH process, diversity of uses, availability of alternatives, etc. Reduce programmatic risks and costs by early replacement Propose corrective actions (replacement qualification, R&D, REACH authorisation, etc.) (1) The SIN list (www.sinlist.org) is an NGO driven project to speed up the transition to a toxic free world. List 2.1 consists of 626 chemicals that are identified as Substance of Very High Concern (SVHC) based on the criteria established by REACH. ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 4
Image: ESA Herschel/SPIRE Applications of Cr(VI) compounds Examples of Cr(VI) applications cover Chromic conversion coating Corrosion protection for Al and Mg alloys, e.g. Alodine 1200S (CrO 3 ) Primers Corrosion inhibition, adhesion promotion, e.g. structural primer BR 127 (SrCrO 4 ) Greases Corrosion inhibition (Na 2 CrO 4 ) Chromic acid anodisation Corrosion protection, thermal control (CrO 3 ) Sealing after chromic acid anodisation Improvement of corrosion protection (K 2 Cr 2 O 7 ) etc. Need qualified replacements before reaching the sunset date Sep 2017. Various commercial solutions are available Coordinated test/qualification programs ongoing Problem: Latest application date for authorization for CrO 3 is 18 months before sunset date Development of authorization dossier takes 1.5 2 years Need to decide about (joint) authorization now ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 5
Alodine 1200S replacement ESA/NASA Test matrix definition (Pre-screening concluded, comprehensive testing until 2015) Substrates (3 x 10 ) Configurations 2024-T3, 2024-T8 Pre-treatment only 6061-T6 Best pre-treatment + primer (considering ESA/NASA systems) 7075-T6, 7075-T73 Best Pre-treatment/primer + topcoat (considering ESA/NASA systems) Sep 2017 Pre-treatments Primers Topcoats Alodine 1200 Super Koropon Deft APC Topcoat Iridite 14-2 ANAC / Mg Rich MAP Aero Static B Alodine 5900 Hentzen (Type II - 7176KEP / 16709 CEH) MAP AQ Static Iridite NCP VpCI-373 MAP Mastic AS Metalast TCP-HF Deft 084 (High Solid) Metalast TCP-HF EPA Hentzen (Type I - 16708TEP / 16709 CEH) SurTec 650 chromital TCP Deft 098 (Waterborne) SurTec 650C / V MAP Aero WP Xbond 4000 MAPSIL SILICo Alodine 5923 plus PM 820 Alodine 160/161 Interlox 5705 MAPSIL SILICo Alodine EC2 Corrlink 30A Deft RECC ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 6 MS&T CECC EonCoat
High risk items Chromates 2/2 Why a dual approach: Testing/qualification for replacement + prepare for authorisation Need qualified replacements before reaching the sunset date Sep 2017. Baseline is replacement and various commercial solutions are available. Coordinated test programs on-going, very complex, lack of processes robustness of alternatives Focus on high priority applications for Alodine 1200 (ESA/NASA, CNES/Astrium) and BR 127 (CNES/TAS) and selected uses. Partly promising results but outcome of performance testing yet open Universal solution (e.g. Alodine 1200) not likely Gradual, quantitative (?) replacement Need possibly to face some performance loss PA and standardisation Expect complex industrialisation processes must work under industrial conditions Problem: Latest application date for authorization for CrO 3 is 18 months before sunset date, development of authorization dossier takes ~ 2 years Need to decide about (joint) authorization now Costs of test programs to date (without industrialisation) mainly carried by agencies Costs for preparation of authorisation planned (without submission) mainly carried by industry Both are in a similar order of magnitude ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 7
General view Most ESA activities are contracted to industry with a variety of business models (R&D contracts, satellite platforms with payloads provided by 3 rd parties, launch service, satellite procurement agent, etc.). Contract clauses require compliance to REACH. REACH is a challenge for European space industry as a whole and solutions are required that are available to all players Need to ensure availability of technology without impairment of quality and reliability. The main objective is the availability of qualified alternatives before reaching the sunset date. ESA has started an extensive test program jointly with NASA and takes provisions to make funds available within appropriate R&D funding schemes (e.g. CleanSpace). Thisis coordinated with complementary test programs funded by CNES. Test programs are focusing on highest priorities, not all uses can be covered now. Promising results during pre-testing, however, no universal solution in sight, need possibly to accommodate performance loss, expect very complex industrialisation. ESA s main objective within the task force is the role as coordinator and facilitator o o Create awareness across European space industry and establish a solid baseline for the TF (scoping phase). Understand the industrial landscape and provide feedback and recommendations to the TF as well as ESA technology programs ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 8
Conclusions Primary aim to replace as soon as possible Need to consider long-term programs (launchers, satellite series) to ensure production capabilities and repair/maintenance capabilities without loosing qualification status of applied materials and processes. Supply chain disruptions can become very resource intensive and economically problematic. Need to accommodate a very large number of configurations and applications, no universal replacement solutions in sight, some very challenging. Cannot afford impairment of quality or reliability of hardware, but may need to accommodate performance loss compared to hexavalent chromium systems. Consensus for need to prepare for authorisation of critical uses of chromium trioxide and possibly other substances. Both, testing/qualification of replacements as well as preparation for authorisation are resource intensive. All efforts should be coordinated and conducted jointly including all necessary stakeholders (industry, agencies, suppliers, authorities, and possibly international partners). Space industry is affected by REACH as a whole and we need open solutions on a collaborative basis. ESA Presentation T. Rohr ESA HQ, Paris 02/12/2013 Slide 9