Chemicals are an essential component of our daily lives, but some chemicals contain serious risks to health or the environment. The EU Registration, Evaluation, Authorization and Restriction of Chemicals Regulation (REACH) is an EU regulation (in force since 2007) adopted to improve protection of human health and the environment, while enhancing the competitiveness of the EU chemicals industry. Chemicals used in industrial processes, but also substances used in cleaning products, paints, textiles, electrical appliances etc. are subject to the REACH regulation, leading to an impact on most companies across the EU, including the entire supply chain of the aerospace and defence industry.
REACH places responsibility on industry to manage the risks from chemicals and to provide safety information on the substances. Companies must gather information on the properties and associated risks of their chemical substances and demonstrate their safe use. Companies need to register their substances, upon which the concerns for human health or the environment are evaluated by the authorities. The legislation calls for the progressive substitution of the most dangerous chemicals (Substances of Very High Concern) by suitable alternatives. If it can be demonstrated that risks are adequately controlled and/or proven that the socio-economic benefits of using the substance outweigh the risk and no suitable alternatives are available, authorisation can be granted for the use of the substance for a limited extended period of time.
The aviation industry products and components operate in highly challenging environments with extreme conditions of temperature and humidity. To withstand these challenges, the aviation industry makes use of high-performance chemical substances, some of which are considered to be of very high concern. In the industry’s compliance with REACH, a number of sector-specific characteristics demand particular attention, such as certification and regulatory controls associated with the introduction of alternative chemicals and design change; high standards of safety over long product lives; and the complexity of the supply chain for aircraft consisting of millions of component parts.
ASD’s REACH Implementation Working Group is committed to a high level of chemical safety, while ensuring supply chain continuity and minimise business uncertainty. In addition to being actively involved in registration and authorization of substances, the activities of the Working Group include identifying challenges and concerns related to the implementation of REACH; options for simplification and streamlining of the regulation; sharing best practices and providing recommendations and sectoral guidance.
In addition to a wide range of issues associated with REACH, the Working Group also deals with related legislation such as the global Stockholm Convention on Persistent Organic Pollutants (POPs); the Biocidal Product Regulation (BPR), concerned with the use of biocidal products protecting humans, animals and materials against harmful organisms, like pests or bacteria; and the Regulation on Classification, Packaging and Labelling of Chemicals (CLP).