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

2. 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
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3. 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
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4. 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
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5. 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Draft guidance 4.0 April, 2017 sent to CARACAL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
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6. Chromates remain critical to aerospace
REACH: Annex XIV Chromates
Example Uses
In Chemical
Processing
Chromates remain critical to aerospace
P. Hogben, Nadcap CP-Berlin, 6/6/2017 | 6
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7. 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
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8. 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 Q (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
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9. 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 Q (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
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10. 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
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11. 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
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12. 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
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13. 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
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You need to take steps to ensure continued operations

14. Copyright © 2017 Boeing. All rights reserved.

15. International Aerospace Environmental Group (IAEG)
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
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16. 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)
              
USA:
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17. 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
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18. 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
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