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 Aerospace
uses list
Interpretation
&
Communication
1) Defense Exemptions
2) GHS
3) Article Suggestions
4) Other industry guides
Information
Technology
1) Supply Chain Data
Exchange
2) External Repository
3) Internal Database
Surveillance Dissemination Registration
of Substances & Training of
1) Shared SIEF work
Suppliers
(Third Party usage)
1) SVHCs tracking in
Products
2) Authorization work
(SEAs etc)
3) Obsolescence
management
1) Training
domestically
2) REACH Information
Packets
3) Follow-Up
2) Shared
Downstream user
Chemical Safety
Report work
3) ‘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 articles
o 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
All substances
Declarable Substances
ECHA Candidate List
High Risk
Relevant to specific sector
Aero, defense, Space…
Annex XIV
Substance Declaration Standard
Standard provides a form for providing information on the
chemistry of components (Published by ASD-Stan and SAE):
1. Requestor Item #
0
4. Prepared By: *
5. Weight of Item, as
Delivered, excludes
packaging (Actual weight,
not shipping weight - )*
2. Supplier Item #
3. Supplier Item Name
0
0
4a. Preparer's Title
4b. Preparer's Phone*
4c. Preparer's Email*
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 aircraft
Helicopters
Unmanned aerial vehicles
Space systems
Aircraft engines
Missiles
Material and related components
Equipment
Services
Information 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