1. REACH Chromates: Next Steps for Boeing's EU Supply Chain
Paul Hogben
Supply Chain Chemical Risk Management
Commercial Airplanes
June 23, 2016
Nadcap Chemical Processing Meeting
London, UK

2. Agenda Regulatory Chromates: Risk to Continued Production
Introduction
Requirements for Processors
Regulatory Update
Chromates: Risk to Continued Production
Substance Timelines
Chromates Used in Chemical Processing
Options for Users of Chromates
Chromate Authorisation Activity
Next Steps for Boeing’s EU Processors and Suppliers
Boeing Technology Update and Technical Support
Summary
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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 restrictions in the EU are biggest threat to production
Includes ban on use of aerospace-critical chromates (unless authorised)
Impact of obsolete materials is felt globally
Requires understanding chemical composition of materials used
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4. REACH: Requirements for Chemical Processors
Not all REACH regulations are explicitly stated here.
This summary is not intended to be guidance or legal advice.
Manage risks to EU supply chain
Trend towards increased reporting/ transparency
Current risk to EU production from Authorisation requirement for chromates
Chromate use restrictions pose imminent threat to EU production
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5. EU reporting requirements getting more challenging
REACH: Regulatory Update
ECJ ruling: “once an article always an article”
thresholds apply to each article in a complex product
ECHA guidance forthcoming
Streamlining and simplification of the authorisation process under consideration
for legacy spare parts (extension of dates also considered)
low volume parts
for parts that may require recertification if the composition changes (e.g., aerospace)
“Wurstfabrik” – delays
Many more SVHCs on the way (EHCA SVHC Roadmap)
Annex XIV lists 5 and 6 overdue
Sunset dates at least 3 years from inclusion in Annex XIV
Borates (incl. boric acid) no longer recommended for inclusion
Annex XVII potential restrictions
DecaBDE
Phthalates (BBP, DEHP, DBP, DIBP)
Lead stabilisers in PVC
Isocyanates
 European Chemicals Agency
EU reporting requirements getting more challenging
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6. 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
Not a systematic process
Example: <<Cadmium in plastics>>
Annex XVII
(Marketing and Use Restrictions)
EU Member States +
ECHA (Helsinki) +
EC (Brussels)
Added ~twice per year
168 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
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7. Chromates are critical to aerospace
REACH: Annex XIV Chromates
Example Uses in Chemical Processing
Chromates are critical to aerospace
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8. All options require significant coordination
REACH: Options for Users of Annex XIV Substances A)
Implement Alternative Materials and Processes
R&D for chromates is ongoing
Lack of universal substitutes
Engineering validation required
Timeline is challenging
Check with OEM for available substitute materials and processes
or B)
Obtain Authorisation to continue using restricted 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)
if neither, then C)
Move/Discontinue Work
Will processes/shops be consolidated?
Will capacity shift outside the EU? D)
Defense Exemptions
Possible substance-specific exemptions for national security reasons
All options require significant coordination
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9. Authorisation process requires continual support
REACH: Chromate Authorisation Activity
Chromium Trioxide Authorisation Committee (CTAC)
Applications for Authorisation (AfAs) filed: broad coverage for chromium trioxide
Use cases and details in press release, status on ECHA website
Many downstream uses covered by upstream importers/formulators
Next step: RAC/SEAC draft opinion expected by June 30, 2016
Downstream users will need to meet conditions of Authorisation
Risk Management Measures (RMMs) and Operating Conditions
Exposure and emission monitoring likely to be required
Notify ECHA of your uses covered by Authorisation
Chromium VI Compounds for Surface Treatment (CCST)
AfAs filed: chromates used in metal finishing operations, paints and primers
Use cases and details in press release; status on ECHA website
Next steps: Trialogue ~June, 2016; draft opinion ~December, 2016
Global Chromates Consortium for Aerospace (GCCA)
Formed by International Aerospace Environmental Group (IAEG) to cover gaps
AfAs filed: aerospace (and derivatives) use of chromates in surface coatings
Next step: Trialogue ~December, 2016
 European Chemicals Agency
Authorisation process requires continual support
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10. Excellent resource on Authorisation for chromates
REACH: Chromate Authorisation Activity
AeroSpace and Defence Industries Association of Europe (ASD) “Update on REACH Authorisation for Chromates”
Details the Applications for Authorisation filed
Describes consequences to the supply chain
Provides contacts and resources
Excellent resource on Authorisation for chromates
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23-June-2016
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11. You need to take steps to ensure continued operations
Chromates: What Boeing’s EU Processors Can do to Prepare
Know where you use chromates in materials and processes
Map your supply chain (for formulations containing chromates)
Communicate with supply chain to ensure continued availability of process chemicals
Are your uses of chromates covered in Authorisation applications?
Communicate with Customers/OEMs:
Risks in the supply chain? Help needed?
Alternative materials and processes available? Contact Boeing with questions.
Please respond to Boeing’s targeted inquiries
Questions about economics and/or operating conditions:  assists with AfA development/support
Prepare for REACH enforcement
Ensure conditions of authorisation are met at your facilities
Draft Risk Management Measures and Operating Conditions for Chromium Trioxide expected in June, (in response to CTAC AfA)
May require reducing/monitoring exposures and emissions
 European Chemicals Agency
You need to take steps to ensure continued operations
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12. You and your supply chain are responsible for Authorisation
Chromates: What Boeing’s EU Suppliers Can do to Prepare
Know where you use chromates in materials and processes
Map your supply chain (for formulations containing chromates)
Communicate with supply chain to ensure continued availability of process chemicals
Are your uses of chromates covered in Authorisation applications?
Manage the risk in your EU supply chain
Communicate with Boeing:
Risks in the supply chain? Help needed?
Alternative materials and processes available? Contact Boeing with questions.
Please respond to Boeing’s targeted inquiries
Questions about uses cases  drives R&D prioritization
Questions about economics and/or operating conditions  assists with AfA development/support
Prepare for REACH enforcement
Ensure conditions of authorisation are met at your facilities
Draft Risk Management Measures and Operating Conditions for Chromium Trioxide expected in June, (in response to CTAC AfA)
May require reducing/monitoring exposures and emissions
Develop Contingency Plans for Continued production
You and your supply chain are responsible for Authorisation
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13. Consult your Boeing representative for applicability
REACH: Boeing Technology Update
Surface Treatment of Aluminum
Technology unlikely to be available before REACH chromate sunset dates
Consult your Boeing representative for applicability
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14. 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
Boeing, FAA, and EASA don’t consider new products as alternatives until they are developed, qualified, certified AND implemented
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15. REACH and Chromate Authorisation require constant diligence
Summary
REACH chromate bans pose threat to aerospace production in the EU
Some chromate-free substitutes available, R&D ongoing
Check with OEM for viability
Authorisation needed to continue critical uses of chromates in EU
Technical support available
Processors and suppliers responsible for continued production
Diligence required to engage in, monitor, and respond to Authorisation process
Need to meet conditions of Authorisation:
risk management measures and operating conditions
REACH and Chromate Authorisation require constant diligence
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23-June-2016
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16. Thanks! Questions? Paul R. Hogben Boeing Commercial Airplanes
Supplier Management EHS
Boeing external REACH Q&A
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23-June-2016
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17. Copyright © 2016 Boeing. All rights reserved.