Aerospace industry threatened by Brussels vote on REACH

(15 November 2005) -- A crucial vote is expected in the European Parliament on REACH (Registration, Evaluation and Authorisation of Chemicals) on Thursday. Ahead of this, SBAC has contacted MEPs and government Ministers in the DTI and DEFRA.

SBAC has encouraged an approach to substitution and authorisation that recognises the challenges faced by the aerospace sector and where substances including alloys and chemicals are used in a controlled manner in the workplace.


SBAC is concerned that a restrictive substitution and authorisation process may create significant compliance difficulties for the aviation industry and its supply chain. This has serious consequences for the global competitiveness of the sector and could have the unintended consequence of undermining innovation designed to achieve greater environmental performance.

SBAC recognises and supports the objectives of reducing the negative impact of chemicals on human health and the environment. Our concern is that an inappropriate approach to authorisation and substitution, that is unable to respond to the specific needs of the aerospace industry, will have the opposite effect.

For more information contact: Paul Everitt, Communications Director, SBAC
Tel: 020 7227 1021 / paul.everitt@sbac.co.uk

Notes
More detailed information can be found in the REACH update document below.
SBAC is the national trade association representing suppliers to the civil air transport, aerospace defence and space markets operating in the UK economy. It represents over 2500 member companies, assisting them in developing new business globally, facilitates innovation and competitiveness and provides regulatory services in technical standards and accreditation. To know more go to: www.sbac.co.uk
At present, the UK has the world’s largest aerospace industry outside the USA. UK based aerospace activity had a turnover of more than £17bn in 2004, supporting a highly skilled workforce of over 255,000 people.

REACH Update – November 2005
SBAC has contacted MEPs and UK government Ministers in the DTI and DEFRA ahead of a crucial vote in Brussels expected to take place on Thursday 17 November.

SBAC encouraged MEPs and Ministers to promote an approach to substitution and authorisation that recognises the challenges faced by the aerospace sector and where most of the potential exposures are in the manufacturing stage and controlled in the workplace.

Key Points
SBAC is concerned that a restrictive substitution and authorisation process may create significant compliance difficulties for the aviation industry and its supply chain. This has serious consequences for the global competitiveness of the sector and could have the unintended consequence of undermining innovation designed to achieve greater environmental performance.

SBAC recognises and supports the objectives of reducing the negative impact of chemicals on human health and the environment. Our concern is that an inappropriate approach to authorisation and substitution, that is unable to respond to the specific needs of the aerospace industry, will have the opposite effect.

Companies within the Aerospace sector are at the fore front of innovative engineering and use a wide range of advanced and specialist substances in various technologies and processes aimed at delivering products that meet the highest degrees of safety and reliability compatible with the environment.

SBAC has a number of serious concerns relating to the cost of implementation and the impact of the legislation on the availability of specialist chemicals and materials produced in small quantities but which remain crucial to both innovation and production. Confidentiality issues, innovation and the security of supply of chemicals are additional concerns.

Substitution and Authorisation concerns
It is an aim of REACH to identify substances of high concern that should be substituted for safer alternatives. SBAC believes that any process of mandatory or time limited substitution would be impossible to achieve without compromising the safety of aircraft, affecting product performance and therefore adversely impacting on the competitiveness of the industry.

Aircraft and aerospace products have a very long service life, thirty years or more, and are required to undergo stringent safety and engine certification processes. The introduction of any substitute would require extensive additional new safety certification and testing. This would be practically impossible to achieve in a short time period, since not only would the alternative substance have to be developed, but it would have to be tested in service and then put forward for safety and certification.

The emphasis of any formal process of substitution must be on those substances that pose a real threat through exposure to public health and the environment. Chemicals used by the aerospace sector are used in carefully controlled environments throughout the lifecycle of the product and pose little risk to human health and the environment. A mechanism must exist that recognises the unique operating circumstances of the industry.
Previous substitution attempts
There have been moves within aerospace to replace specific hazardous chemicals this has included attempts to move away from the use of hexavalent chromium, cadmium and lead. Substitutes have been developed in these instances but have been found to be inferior, and cannot be used without seriously compromising the safety of the product or affecting the performance of equipment in some vital areas.

It is the case that in some limited circumstances it will not be possible to substitute particular chemicals and it is crucial that they remain accessible to our industry without significant additional cost. The safety of employees remains paramount and robust occupational health provision and controls are in place to ensure that employees are not exposed to dangerous substances.
Maintenance Repair and Overhaul needs
Once a product is in service it is vital that manufacturers are able to fully service, maintain and replace components for the life of that product. Essential to this, is the continued access to all substances, at a competitive cost, necessary to achieve this. It would be a significant engineering challenge to introduce substitutes to components of an aircraft that is already in operation.

If there was a requirement to introduce a substitute within a specific time parameter this would pose an insurmountable challenge to the industry, which could lead to an incentive for airlines to access maintenance and repair services outside the EU. This is an alarming prospect for the whole UK supply chain and particularly those suppliers, including SMEs, who support the Maintenance Repair and Overhaul services. Maintenance, Repair and Overhaul is one of the major growth areas of the sector increasing by 11% per annum since 1996. It is a particularly globally competitive sector since airlines are at liberty to seek these services throughout the world.
Potential effects on environmental performance
An example of a substance that could be deemed hazardous to human health under REACH is Rhenium. This substance is used in the production of engines. When Rhenium is alloyed with several other elements to form Nickel based superalloys, it enables gas turbine blades to operate in hotter and more fuel efficient engines producing a significant reduction in greenhouse gas emissions. It is estimated that material developments such as this have contributed to roughly half of the 70% reduction in fuel burn for modern jet aircraft compared to those of the 1960’s. Rhenium is a very valuable element and is used sparingly and recycled and re-used wherever possible.

Under REACH the continued legal use and availability of a substance such as Rhenium remains uncertain. Substitutes for Rhenium are far less effective and would result in less efficient engines. Such an outcome would be a significant step backwards as far as the environment is concerned and could be the unintended outcome of a restrictive authorisation and substitution process.

Source : SBAC