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July 16, 2008

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

eagan-mcknight
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July 16, 2008

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  1. Briefing for the Department of DefenseEU REACH: Registration, Evaluation, Authorization and Restriction of Chemicals July 16, 2008

  2. 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

  3. Aerospace industry work on REACH AIA (Aerospace Industries Association) & ASD (Aerospace and Defense Industries Association of Europe) • Standards • Development • Substance Declaration • Standard (SAE • & ASD Stan) • 2) Generic Aerospace • uses list • Interpretation • & • Communication • Defense Exemptions • 2) GHS • 3) Article Suggestions • 4) Other industry guides • Information • Technology • Supply Chain Data • Exchange • 2) External Repository • 3) Internal Database • Surveillance • of Substances • SVHCs tracking in • Products • 2) Authorization work • (SEAs etc) • 3) Obsolescence • management • Dissemination • & Training of • Suppliers • Training • domestically • 2) REACH Information • Packets • 3) Follow-Up • Registration • Shared SIEF work • (Third Party usage) • 2) Shared • Downstream user • Chemical Safety • Report work • 3) ‘Use’ Library

  4. 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

  5. REACH impacts • Increased costs due to circumstances including: • Reduced availability of substances, where suitable alternatives may not be available • Analysis and tracking of hazardous materials in articles • 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

  6. 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

  7. 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

  8. 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

  9. Questions

  10. Additional Slides

  11. Declarable Substances ECHA Candidate List High Risk Relevant to specific sector Aero, defense, Space… Annex XIV Substances in our Products and Processes All substances

  12. Substance Declaration Standard Standard provides a form for providing information on the chemistry of components (Published by ASD-Stan and SAE):

  13. 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

  14. 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

  15. 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

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