Aerospace Use Of Hexavalent Chromium And Soluble Nickel In Relation To REACh 7th October 2009 From a combined Goodrich and Rolls-Royce review of the implications of REACh for the aircraft industry Goodrich: J Henshaw; G Armstrong Rolls-Royce: A Page; J Watson; C Phillips; A Phillips © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Chromium And Nickel Compounds In Current Products The Aerospace industry Currently uses hexavalent chrome and nickel compounds in a number of flight critical applications for various reasons Has been researching viable alternatives for many years Has found that very few alternatives are successful in the aircraft environment Compared to other industries, requires a significantly longer time to introduce changes into existing products due to the extensive testing obligations to comply with airworthiness requirements. 2 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Chromium and Nickel Compounds In Current Products As an example Components supplied for an Airbus A 320 aircraft (typically engines, flight control actuators, landing gear etc) Original equipment deliveries planned until at least 2018 Fleet support required until approximately 2040 Supplied products include extensive use of: hard chrome plating; Chromic anodising; Sealing of anodising on aluminium alloys; passivation baths for stainless steel and cadmium plating; sacrificial paints using chrome phosphate; conversion coatings on magnesium and aluminium; nickel plating; tribomet coatings for wear and sealing; electrochemical machining. Problem The above products have been fully tested and certified for flight Changes require extensive retesting to prove that they represent a comparable safe alternative Introduction onto the aircraft / engine typically takes between 5 and 10 years Assuming that the alternative has already proved to be technically capable 3 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Aerospace Equipment Sector Cr6+ Use and Status Note: The original substances are not present in the final product 4 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Aerospace Equipment Sector Cr6+ Use and Status 5 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Aerospace Equipment Sector Nickel Use and Status Note: The original substances are not present in the final product 6 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Aerospace Equipment Sector Ni 2+(aq) Use and Status Note: The original substances are not present in the final product 7 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Example Data – Rolls-Royce Testing Status For Hexavalent Chrome Replacements Other aerospace companies have programmes in place with similar results 8 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Typical Uses Of Hexavalent Chrome And Soluble Nickel Primary and secondary flight control actuation Aircraft paints Engines Landing gear 9 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Materials In A Current Civil Engine Rolls-Royce Example Nickel 40% All Others 5% Steel 25% Titanium 30% Current Technology: All steel and all aluminium parts of an engine (the outer casing) are coated in mixtures containing hex chrome in at least one layer of the coating system: Usually in all 8 – 10 layers. Even if alternatives are available during manufacture, hex chrome is needed for product repair. 10 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Safe replacements are at various stages of technical approval Summary Changes to products are governed by legal airworthiness requirements which also define the requirements for retesting when changes are made Testing must be to the same standard and vigour as occurred for the original aircraft / engine airworthiness approval Safe replacements are at various stages of technical approval Many examples exist where safe alternatives have not yet been developed or proven Substance elimination under REACh must take account of the special needs of the aircraft industry due to the safety implications 11 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Conclusion With very few exceptions, hexavalent chrome and soluble nickel are not in the final product on aircraft. There is no exposure of them to the public. Exposures to downstream workers and during manufacture is restricted via a highly restricted and controlled environment. e.g. Component maintenance manuals and Nadcap Credible alternatives have not yet reached a stage of maturity to give confidence that they could be implemented within current estimates of the REACh time table. With enough research work, hexavalent chrome and soluble nickel compounds could be significantly reduced in future aircraft models provided that the alternatives can be proven to satisfy the demanding technical standards for airworthiness. Existing aircraft will need to be maintained for several decades with a safe and stable supply of spares. Validation of retrospective design changes is significantly more challenging than new product introduction If any of these substances are listed on REACh Annex XIV, then the aircraft industry will require exemption for existing aircraft programmes. 12 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Supporting Information Additional slides with further supporting information to the earlier tables follow this slide for use if required. 13 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Alternatives tested for hard chrome plating WC-Co-Cr applied by HVOF spray coating Limited application opportunities due to adverse impact on base material Successful in some applications Geometry constraints so not a universal substitute Very limited availability in supply base W-Co electroplated nano coating Potential option to produce hard surfaces for seals to run on Still in R&D phase – no commercial availability Not proven for seal running Diamond like carbon Not a viable option following testing due to poor adhesion and poor endurance – required coating thickness cannot be achieved PVD Coatings As for Diamond like carbon – not a viable option following testing due to poor adhesion and poor endurance – required coating thicknesses cannot be achieved. 14 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Alternatives tested for chromic anodising Sulphuric anodising Coating has to be 5 times thicker than chromic for equivalent corrosion resistance Fatigue properties of base alloy are damaged by this process Cannot be used on aluminium parts made from castings Can only be used on non fatigue sensitive parts made from bar or forging Boric Sulphuric Anodising Works well but still needs dichromate sealing for acceptable corrosion resistance Minimal reduction in fatigue properties Boeing IPR so cannot be used on Airbus products Keronite PEO Coating Thicker coating than chromic anodising Claims that it does not reduce fatigue properties - not proven 15 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL

Alternatives for Electroless Nickel Plating None yet evaluated The key attribute of the electroless nickel process is that it is electroless and so does not have the geometric constraints of electroplating or spraying processes (edge effects and line of site issues) Possibility for electroless Nickel-Boron plating but not readily available and not yet tested by GAS. 16 © Goodrich Actuation Systems Limited 2009 CONFIDENTIAL