1. 1 Materials & Prcesses Up Date Dr E H Blacklay 2 nd March 2016

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3. 3 NDT Personnel Competency Determination

4. 4 EN 4179 Aerospace Series - Qualification and Approval of Personnel for Non-Destructive Testing  Drafted and maintained by the Aerospace and Defence Industries Association of Europe – Standardisation (ASD-STAN)  European Commission approve through CEN (central European norms)  Issued by European National Standards organisations, for example, BSI  Identical to US standard NAS410 or should be

5. 5 EN 4179 & NAS410  In the late 1990’s ASD-STAN started to work with the US standards body AIA to harmonise EN4179 with its American equivalent. EN 4179:2009 and NAS410 Revision 3 dated March 2008 were fully harmonised.  December 2014 AIA published NAS410 Revision 4 coincidently ASD- STAN published prEN4179 edition P5.  ASD-STAN has not as yet submitted prEN4179 edition P5 to the European Commission for approval, thus it is still technically a draft standard and so there is dis-harmonisation between the officially recognised US and European standards.

6. 6 UK NAndtB Advisory AD-009  In order to ensure that the UK remains compliant with the harmonised versions of EN4179 and NAS410, at a meeting of the UK NANDTB on 10 March 2015, it was unanimously agreed that prEN4179 edition P5 December 2014 shall be the recognised standard for Qualification and Approval of NDT personnel applicable within the United Kingdom.  The UK NANDTB has agreed a period of six months from 10 March 2015 to make prEN4179 edition P5 effective.  Personnel certified to previous revisions of EN4179 need not recertify to the requirement of prEN4179 edition P5 until their current certification expires.

7. 7 Significant Changes  Re-definition of the role of Responsible Level 3 and National Aerospace NDT Board (NAndtB).  Removal of the reference to NAndtB in many sections of the standard.  4.1.2 - NDT Techniques “actions to be taken concerning additional training …….”  Division of Radiographic Testing into Film and Non-Film Radiography.  Vision requirements.  Reduction in the experience hours for Eddy Current, Ultra-Sonic and Radiography.  Requirement for “annual maintenance”.

8. 8 Vision Requirements  Tumbling E in accordance with ISO 18490, or 20/25 (Snellen) at 16" (40.64 cm) ) +/- 1" (2.54 cm), or Jaeger No. 1 at not less than 12” (30.48 cm)  Although the standard allows Jaeger and Snellen test methodologies the UK NAndtB policy is that all near vision examination must be in accordance with ISO 18490 - Tumbling E.

9. 9 CAA Concern  Has the requirement to comply with PrEN4179:2014 Edition P5 been flowed down to your sub-contractors out side Europe?  Are your foreign sub-contractors compliant with PrEN4179:2014 Edition P5/

10. 10 Recent NDT Developments and Associated Risks

11. 11 Aqueous Degreasing  Aqueous Degreasing has been qualified and introduced as a replacement for degreasing processes using Trichloroethylene due to REACH.  The Authority has recently been made aware that some aqueous degreasing solutions can deposit silicates on to the component surface. Occurrences have been observed when the degreasing has been performed outside the equipment manufacturers operationally guidelines. (Temperature and/or solution concentration)  If a silicate film is formed on the surface of a component that surface will not wet, thus effective penetrant or magnetic particle inspections can not be performed.

12. 12 LED UV Lamps  The use of LED UV Lamps either mains or battery powered is more prevalent in penetrant and magnetic particle inspections.  Currently there is no recognised national or international standard for these lamps.  The Authority concerns are: Wavelength of light, Working distance, Output Stability over the life of the source and life of the battery, Beam Uniformity and Beam Pattern.  A number of the OEMs have produced specification for these lamps and an international standard is being developed.

13. 13 REACH Registration, Evaluation, Authorisation & restriction of Chemicals EC 1907/2006  REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation & restriction of Chemicals EC 1907/2006.  European Regulator: European Chemical Agency ECHA based in Helsinki, Finland.

14. 14 REACH Registration, Evaluation, Authorisation & restriction of Chemicals EC 1907/2006  REACH provides for the management of Substances of Very High Concern (SVHC) through its processes of:  Identification  Notification  Authorisation/Ban  Restriction  Communication

15. 15 REACH Regulated Substances Lists  Candidate List: Chemicals identified as Substances of Very High Concern (SVHC) are listed as the first step of the Authorisation process. (163 Substances currently listed)  Annex XIV – Authorisation List: List of substances that are subject to ECHA authorisation otherwise will be banned on a defined date known as the “Sunset Date”. (31 Substances currently listed)  Annex XVII – Restrictions List: List of restrictions concerning the manufacture, sale, and use of SVHC (on their own, in mixtures or in articles). (63 listed restrictions which in some cases apply to multiple substances)

16. 16 Annex XIV – Authorisation List Examples SVHCUsesSunset date Dibutyl Phthalate(DBP) Bis-(2-ethylhexyl) Phthalate (DEHP) Paints, Sealants & Adhesives Feb 2015 TrichloroethyleneDegreasing and Cleaning April 2016 Chromium Trioxide Sodium Chromate/Dichromate Potassium Chromate/Dichromate Aluminium Anodising Pickling of Stainless Steels Passivation of Stainless Steels Sealing of Anodised Aluminium Chemical Conversion Coatings Hard Chrome Plating Sept 2017 Strontium Chromate Zinc Potassium Chromate Jointing Compounds Sealants External paints Bonding Primers Jan 2019

17. 17 Primacy of EHCA & EASA Regulations  Neither the REACH regulation implemented by ECHA nor those governing airworthiness overseen by EASA take precedent over the other.  For compliance with REACH the industry needs to either:  Use an acceptable alternative/replacement of the SVHCs listed in Annex XIV, or  Seek authorisation to continue to use the SVHCs listed in Annex.  But compliance with existing Airworthiness Requirements and procedures must be maintained.

18. 18 CAA Policy Alternatives and Replacements  Where the chemical/substance/mixture/compound contained in approved design/production/maintenance data is no longer available, the use of alternatives/replacements must be approved by the design organisation responsible for the original data.  Alternatives/replacements offered by supplier and stockists should only be accepted where objective evidence of design organisation acceptance (such as a formally issued alternative materials list) is available.  Statements by suppliers/stockists in company literature or on websites that replacement materials are authorised by design organisations, should not be taken at face value. CAA Information Notice IN-2013/155 “Registration, Evaluation, Authorisation and restriction of CHemicals (REACH)”

19. 19 Risk Example Chromic Acid Anodizing  Chromium Trioxide is the base chemical for solutions used for Chromic Acid Anodizing aluminium alloys.  Anodizing the surface of aluminium alloys increases the corrosion resistance of the materials.  Chromic Acid Anodizing has been used in the aerospace industry for over 50 years as it creates a soft passive layer that does not affect the fatigue properties of the component.  The surface developed enables structural adhesive bonding.  Additionally, Chromic Acid Anodizing allows anodic flaw detection (AFD) inspection for cracks, corrosion, and machining abuse directly after treatment.

20. 20 Risk Example Chromic Acid Anodizing -  There are many other anodizing surface treatments that produce passive layers with comparable corrosion resistance and don’t impair the fatigue resistance of the material. However,  Many produce a film that will not support structural bonding.  None allow a reliable effective AFD inspection for corrosion, cracks and machining abuse.

21. 21 CAA Concerns  Is there sufficient knowledge and understanding in the Approved Organisations sub-contractors to maintain compliance with both ECHA and EASA regulations?

22. 22 Further Information  REACH Interpretation guidelines; ASD May 2014 REACH Interpretation guidelines; ASD May 2014  An elaboration of key aspects of the authorisation process in the context of aviation industry; ECHA-EASA April 2014 An elaboration of key aspects of the authorisation process in the context of aviation industry; ECHA-EASA April 2014  Registration, Evaluation, Authorisation and restriction of Chemicals (REACH); IN- 2013/155 CAA Oct 2013 Registration, Evaluation, Authorisation and restriction of Chemicals (REACH); IN- 2013/155 CAA Oct 2013

23. 23 Additive Layer Manufacturing  ALM refers to a range of manufacturing methods which directly use digital 3D design data to build up a part in thin layers by depositing material. Typically in the manufacture of metallic parts the process feedstock is fine powder or wire which is fused using laser or electron beams. The result can be a part that needs little to no post process work.  As with castings, composites and welding the parts final mechanical properties are basically established during the fabrication process. Although with ALM post processing can have an effect.

24. 24 Industry Aspirations For ALM  Rapid Prototyping  Component Design Optimisation  Simplification of Part Production  Manufacture to Demand  Repair

25. 25 But One Has To Learn To Walk Before One Can Run

26. 26 Substantiation Against Certification Specifications  ALM methods are new fabrication methods that produce effectively new materials. Thus prior to establishment of ALM serial production facilities compliance with the design and construction certification specifications must be demonstrated, specifically:  CS XX.603 – Materials  CS XX.605 - Fabrication  CS XX.613 – Material Design Values  CS XX.619 – Special Factors

27. 27 Design Requirements - Materials  CS 25.603 - Materials The suitability and durability of materials used for parts, the failure of which could adversely affect safety, must: a) Be established on the basis of experience or test; b) Conform to approved specifications, that ensure their having the strength and other properties assumed in the design data.

28. 28 Interpretation XX.603  The properties and service performance of a material must be fully understood. (Aluminium Lithium alloys – strange fatigue crack growth and poor through thickness properties)  Issue a specification for the material in it’s in service condition that ensures the properties assumed in the design data are achieved.

29. 29 Design Requirements - Fabrication  CS 25.605 - Fabrication Methods a) The methods of fabrication used must produce a consistently sound structure. If a fabrication process requires close control to reach this objective, the process must be preformed under an approved process specification. b) Each new aircraft fabrication method must be substantiated by a test programme.

30. 30 Interpretation XX.605  All process variables that affect the properties and performance of the part must be determined and controlled.  A recent meeting here at the MTC it was stated that there are in excess of 50 parameters that can directly affect the properties of metallic ALM components.  Another consideration is also how does the operator’s competence, skill, knowledge affect the process. (21.A.145(a))

31. 31 Design Requirements – Design Values  CS 25.613 Material Strength Properties & Material Design Values a) Material strength properties must be based on enough tests of material meeting approved specifications to establish design values on a statistical basis. b) Material design values must be chosen to minimise the probability of structural failures due to material variability. …… ……

32. 32 Interpretation XX.613  Methodologies to establish static strength design values are given in ESDU 00-932 and MMPDS.  Examples of issues to be accounted for in the establishment of design values: Process consistency from machine to machine Anisotropy

33. 33 Design Requirements  CS 25.619 – Special Factors  The factor of safety prescribed in CS 25.303 must be multiplied by the highest pertinent special factor of safety prescribed in CS 25.621 through CS 25.625 for each part of the structure whose strength is – a) Uncertain. b) Likely to deteriorate in service before normal replacement; or c) Subject to appreciable variability because of uncertainties in manufacturing processes or inspection methods ……

34. 34 Regulators’ Wish a) Design Organisations involve EASA at the earliest opportunity during the development and implementation of ALM. b) Production Organisations inform the UK CAA at the earliest opportunity before implementation of ALM processes. EASA contacts: Dr Simon Waite Wolfgang Hoffmann Richard Minter CAA UK contacts: Dr Ted Blacklay Mark Barker Geoff Hackett

35. 35 Standard Fasteners (nuts and bolts)  EASA issued a Certification Memo in Feb 2015 covering the use of standard fasteners (nuts and bolts) within critical installations. EASA CM-S-003. StandardDescriptionPoints of Concern NASM21042 MS21042 NAS 1291 Nut Thin walled; not designed as a tension nit. Several cases of hydrogen embrittlement or physical defects leading to common cause failures including complete loss of bolt retention. Loss of locking capability

36. 36 Thank You for Your Attention Any Questions