REACH: Preparing for Chromate “Sunset Dates” Paul Hogben Supply Chain Chemical Risk Management Boeing Commercial Airplanes Nadcap, Chemical Processing June 6, 2017

Agenda REACH Regulation Chromates: Risk to Continued Production Key Requirements for Chemical Processors Regulatory Update Chromates: Risk to Continued Production Impact to Chemical Processors Options for Users of Chromates Chromate Authorisation Activity Update Resources and Technical Support Summary: What EU Processors Can do to Prepare P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 2 Copyright © 2017 Boeing. All rights reserved.

Requires understanding chemical composition of materials used REACH: Introduction Registration, Evaluation, Authorisation, and Restriction of Chemicals European Union chemical management regulation (2007) Compliance applies within the EU Covers manufacturing, import, and use of substances: By themselves (e.g., strontium chromate) In mixtures (e.g., paints, sealants) In “articles” (e.g., landing gear assembly) Emphasis on Substances of Very High Concern (SVHCs) Substance use bans/restrictions in the EU are biggest threat to production Includes aerospace-critical chromates Banned on sunset dates unless “Authorised” for continued use Impact of obsolete materials is felt globally Requires understanding chemical composition of materials used P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 3 Copyright © 2017 Boeing. All rights reserved.

Action needed to reduce risk of production disruptions REACH: EU Compliance Requirements Not all REACH regulations are explicitly stated here. This summary is not intended to be guidance or legal advice. More information: IAEG WG8 Moving towards increased reporting/ transparency: AD-DSL, IPC-1754 Current risk to EU production from Authorisation requirement for chromates Action needed to reduce risk of production disruptions P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 4 Copyright © 2017 Boeing. All rights reserved.

Compliance and production in the EU are getting more challenging REACH: Regulatory Update ECJ ruling: “once an article always an article” Communication thresholds apply to each article in a complex product Draft guidance 4.0 April, 2017 sent to CARACAL Streamlining and simplification of the authorisation process under consideration For legacy spare parts (extension of dates also considered) For low volume parts For parts that may require recertification if the composition changes (e.g., aerospace) Gradual increase in substance listings Recent additions less impactful to Aerospace than chromates Pace will need to increase to implement SVHC Roadmap to 2020 Impact of future listings to Aerospace? IAEG WG5 assesses aerospace-critical substances and helps with supply chain mapping and intelligence Annex XVII potential restrictions Phthalates (BBP, DEHP, DBP, DIBP) Lead stabilisers in PVC Isocyanates (comments due Sep-2017)  European Chemicals Agency Compliance and production in the EU are getting more challenging P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 5 Copyright © 2017 Boeing. All rights reserved.

Chromates remain critical to aerospace REACH: Annex XIV Chromates Example Uses In Chemical Processing 7789-06-2 Chromates remain critical to aerospace P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 6 Copyright © 2017 Boeing. All rights reserved.

All options require significant coordination REACH: Options for Users of Annex XIV Substances A) Implement Alternative Materials and Processes Lack of universal substitutes R&D for chromates is ongoing IAEG WG2, industry associations, individual companies are active Check with OEM for available substitute materials and processes Engineering validation required Have contingency plans in case substitution can not be achieved or B) Obtain Authorisation to continue using Annex XIV substances Typically obtained by substance manufacturers/importers or chemical formulators If your use is not authorised by an upstream supplier – you will have to obtain your own authorisation 18 month process: no guarantee authorisation will be granted No mechanism for quick review or reapplication (if rejected) Details on Authorisation for chromates if neither, then C) Move/Discontinue Work Will processes/shops be consolidated? Will capacity shift outside the EU? All options require significant coordination P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 7 Copyright © 2017 Boeing. All rights reserved.

ECHA guidance documents and manuals on Authorisation: >500 pages REACH: Authorisation Status for Chromates (1 of 3) Chromium Trioxide Authorisation Committee (CTAC) Broad coverage for chromium trioxide (use cases and details in press release) Examples: surface treatment in aerospace (chromic acid), chrome plating, etc. Applications filed; ECHA opinions adopted Sep-2016 7 years continued use recommended for most uses Example opinion: surface treatment in aerospace European Commission final ruling expected Q4-2017 (after Sep-21, 2017 sunset date) If your uses are in your upstream supply chain’s applications for Authorisation (filed on-time), you can continue uses until the final EC ruling Upon EC ruling (approval anticipated), Downstream Users must fulfill obligations Comply with Risk Management Measures (RMMs) and Operating Conditions (OCs) Prescribed in “Section 9 and 10 of the CSR” (linked from ECHA opinion for each application for Authorisation) Examples: bio-monitoring, personal protective equipment, improved exposures, reduced releases to the environment, etc. CTAC guidance forthcoming: Good Practice Sheets for Downstream Users Purchase materials from Authorised sellers (e.g., Aviall, etc.) SDS should have Authorisation number and conditions of Authorisation (exposure scenarios) Notify ECHA of your use of Authorised substances After final decision, inform ECHA within 3 months of substance delivered to you (via webform, requires REACH-IT account) Expect national enforcement to follow: satisfy RMMS, OCs, etc. ECHA guidance documents and manuals on Authorisation: >500 pages P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 8 Copyright © 2017 Boeing. All rights reserved.

Please inform your customers if you intend to discontinue processes REACH: Authorisation Status for Chromates (2 of 3) Chromium Compounds for Surface Treatment (CCST) Coverage for certain metal finishing operations and uses of paints and primers Use cases and details in press release Examples: potassium and sodium dichromates in surface finishing, strontium chromate in paints/primers Applications filed; ECHA opinions adopted Dec-2016 7 years continued use recommended for most uses Example opinion: potassium hydroxyoctaoxodizincatedichromate in paints, in primer, sealants, and coatings European Commission final ruling expected Q4-2017 (after Sep-21, 2017 sunset date) If your uses are in your upstream supply chain’s applications for Authorisation (filed on-time), you can continue uses until the final EC ruling Upon EC ruling (approval anticipated), Downstream Users must fulfill obligations Comply with Risk Management Measures (RMMs) and Operating Conditions (OCs) Prescribed in “Section 9 and 10 of the CSR” (linked from ECHA opinion for each application for Authorisation) Examples: bio-monitoring, personal protective equipment, improved exposures, reduced releases to the environment, etc. Exposure scenarios must be flowed to Downstream Users within 3 months of EC decision Purchase materials from Authorised sellers (e.g., Aviall, etc.) SDS should have Authorisation number and conditions of Authorisation Notify ECHA of your use of Authorised substances After final decision, inform ECHA within 3 months of substance delivered to you (via webform, requires REACH-IT account) Expect national enforcement to follow Please inform your customers if you intend to discontinue processes P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 9 Copyright © 2017 Boeing. All rights reserved.

Different Authorisations may be needed for different parts REACH: Authorisation Status for Chromates (3 of 3) Not all aerospace uses of chromates are covered by CTAC and CCST International Aerospace Environmental Group (IAEG) formed to evaluate gaps Global Chromates Consortium for Aerospace (GCCA) formed Dossiers for known uses submitted Draft opinions expected June/July-2017; final ruling after sunset date Example: sodium chromate for conversion coating, titanium etch, and anodize seal Other applications for Authorisation Additional aerospace uses of chromates May be crafted for specialized companies Non-aerospace uses of chromates Example: formulations of mixtures Other candidate list substances Example: Trichloroethylene (TCE) as a solvent as a degreasing agent in closed systems Different Authorisations may be needed for different parts P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 10 Copyright © 2017 Boeing. All rights reserved.

REACH: Authorisation Resources ECHA links Opinions on Authorisation applications here. For each application (by use/substance): Opinions of the Risk Assessment Committee (RAC) Opinion of the Socio-economic Analysis Committee (SEAC) Section 9 and 10 of the Chemical Safety Report (CSR) ECHA guidance on Authorisation, including fulfilling obligations Your chemical supplier/distributor Should understand availability of chemicals Should provide Safety Data Sheets, indicating Authorisation status, etc. Authorisation holder (applicant, as listed on ECHA site) Example: Aviall (for several chromates) Original Equipment Manufacturer Example: Boeing (REACH Q&A and contacts here) Industry/Trade associations Example: IAEG WG5 Webinar on REACH Authorisation Example: AeroSpace and Defence Industries Association of Europe (ASD) - Authorisation Update Example: Surface Engineering Association – (SEA)  European Chemicals Agency P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 11 Copyright © 2017 Boeing. All rights reserved.

Technical Support for Boeing Hardware Information on materials and processes Check engineering drawings, substitution drawings, qualified products lists, etc. Request further information: impacted materials and processes, available substitutes, technology updates, substance Authorisation status, etc. Submit supplier request for change – eELR (external Engineering Liaison Requests) Points of Contact: Direct suppliers  Boeing Procurement Agent Special Processors  Boeing Supplier Quality representative Indirect supplier  your customer (i.e., flow up to Boeing direct supplier) All  Boeing REACH contact as listed in Boeing’s REACH Q&A Aviall  for chemical sales and support, including Authorised chromates example Boeing, FAA, and EASA don’t consider new products as alternatives until they are developed, qualified, certified AND implemented P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 12 Copyright © 2017 Boeing. All rights reserved.

You need to take steps to ensure continued operations Summary What EU Processors Can do to Prepare for Chromate Sunset Dates Know where you use chromates in materials and processes Environmental Management System, Safety Data Sheets fundamental to compliance If needed*, ensure continued availability of process chemicals Are your uses of chromates included in Authorisation applications? Communicate with your chemical suppliers/distributors: will formulations remain available? Communicate with Customers/OEMs: Risks in the supply chain? Help needed? Respond to targeted inquiries (e.g., from Boeing, IAEG) Questions about economics and/or operating conditions:  AfA development/support Prepare for REACH enforcement (for use of Authorised chromates beyond sunset dates) Fulfill obligations: Risk Management Measures (RMMs) and Operating Conditions (OCs) May require monitoring and reducing exposures and emissions Seek updated guidance: Authorisation consortia, OEMs, industry associations Purchase materials from Authorised sellers (e.g., Aviall, etc.) SDS should also have Authorisation number and conditions of Authorisation (exposure scenarios) Notify ECHA of your use of Authorised substances Expect national enforcement to follow * Alternative materials and processes available? Contact your OEM. P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 13 Copyright © 2017 Boeing. All rights reserved. You need to take steps to ensure continued operations

Copyright © 2017 Boeing. All rights reserved.

International Aerospace Environmental Group (IAEG) www.iaeg.com A non-profit organization of global aerospace companies created to collaborate on and share innovative environmental solutions for the industry WG1 Chemical Reporting WG2 Replacement Technologies WG5 REACH Process Authorisation WG8 REACH Registration 2018 Risk Management Copyright © 2017 Boeing. All rights reserved.

Chemical Support Aviall Amsterdam is an upstream Authorisation holder covering downstream European customers. Aviall (a Boeing Company) is a member of REACH Authorisation Consortia for: chromium trioxide (chromic acid) strontium chromate pentazinc chromate octahydroxide sodium chromate potassium hydroxyoctaoxodizincatedichromate 40 Global Locations, 1,500 Employees, Over 240 OEM Suppliers If your company is anticipating, or currently experiencing, material shortages due to chemical restriction/obsolescence, contact Aviall, we may be able to help Europe: +31(0) 252245950                john.dickhoff@aviall.com USA: REACH@Aviall.com Copyright © 2017 Boeing. All rights reserved.

Any process using chemicals in the EU is subject to REACH REACH: Impacted Special Processes Any process using chemicals in the EU is subject to REACH P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 4 Copyright © 2017 Boeing. All rights reserved.

Systematic and recurring process REACH: Timeline for Substance Bans Substance Nomination SVHCs (Substances of Very High Concern) aka “Candidate List” Annex XIV “Authorisation List” (Substance Use Bans) “Sunset Date” Banned from use (unless your use is authorised) 3+ months 1-2 years ~3 years Restricts use in EU, and placing articles on the EU market Less regular frequency Example: <<Cadmium in plastics>> Under review: phthalates (DEHP, BBP, DBP, DIBP) Annex XVII (Marketing and Use Restrictions) EU Member States + ECHA (Helsinki) + EC (Brussels) Added ~twice per year 173 current SVHCs Not restricted from use at this point… but triggers reformulation and obsolescence (and other compliance requirements) Added ~once per year Will be sunset (banned from use, unless your use is authorised) 31 current substances Phthalates 21-Feb-2015 Others, including chromates 21-Sep-2017 Chromium trioxide Acids generated from chromium trioxide Sodium dichromate Potassium dichromate Potassium chromate Sodium chromate Ammonium dichromate 22-Jan-2019 Strontium chromate Dichromium tris(chromate) Zinc potassium chromate Pentazinc chromate Systematic and recurring process P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 7 Copyright © 2017 Boeing. All rights reserved.