REACH Aerospace Supply Continuity Management

Transcription

1 2013 AerSpace and Defence Industries Assciatin f Eurpe The infrmatin in this dcument is the prperty f AerSpace and Defence Industries Assciatin f Eurpe (ASD) and may nt be cpied r cmmunicated t a third party, r used fr any purpse ther than that fr which it is supplied withut the express written cnsent f ASD REACH Aerspace Supply Cntinuity Management 23 January 2013 ASD REACH Wrking Grup 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 1

2 Objectives f Wrkshp Cmmn understanding f the specific issues the Aviatin industry faces in managing the REACH Regulatin T ensure the sustainability f aircraft prductin and peratin in recgnitin f needs fr aircraft safety Develpment f partnership between EASA and ECHA t assist industry in managing the risks An agreed actin plan and wrking grup t get a tailred jint slutin fr the Aerspace industry Recgnising the urgency f this need 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 2

3 Key Salients relevant t REACH Very lw vlume f chemicals cmpared t ther industries Lng prductin timelines Regulated certificatin prcess The need t keep the prducts peratinal 30+ years Cmplex, internatinal supply chains Manufacture f highly cmplex articles Dependence n sme substances fr aircraft safety, including SVHC s We expect that the cnsequences f REACH will be significantly higher than fr ther sectrs 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 3

4 Aerspace and REACH The Aerspace Sectr fully supprts the intent f REACH In particular wrkplace and envirnmental prtectin Aerspace is regulated by EC216/2008 and EC748/2012 (EASA) which fcus n prduct safety: We always priritise airwrthiness Prduct changes require substantive evidence f cmpliance with safety standards Alternate materials are being develped, but where nt validated we cannt substitute Repair f existing prducts is ften dependent n materials we d nt wish t use in the future Prduct Changes can rarely be made at shrt ntice Shrt ntice change may result in unbearable limitatins! 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 4

5 What Industry is ding fr Itself Active trade assciatin REACH wrking grups Crss-sectr engagement Guidance Material Cmmunicatin f need t cmmunicate befre stp f supply Via Chemical manufacturers and Imprter trade assciatins Helping Authrities t understand issues resulting frm supply chain cmplexity Active cnsrtium develpment and engagement Supprting ur supply chains Cllabratin t find alternatives Frmatin f IAEG t develp internatinal supply chain reprting standards 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 5

6 Supply Chain cmplexity is a majr issue with REACH Chemical Cmpany Distributr Distributrs Frmulatrs Distributr Chemical Cmpany Imprters Prcessrs SME SME SME SME SME SME Machinists SME SME SME SME Supplier Supplier SME Prduct Cmpanies System Integratr Imprters Lng/Cmplex Supply Chains, 8+ layers N direct relatinship between tp and bttm Many mid-chain players are small with lw understanding Full chemistry is nt available in many cases - Frmulatrs and Design suppliers REACH depends n gd cmmunicatin thrugh supply chains 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 6

7 A Typical Real Supply Chain Map Chrmium Trixide Supplier (China) Chemical Imprter (EU) Cnversin Cat Frmulatr (EU) Cnversin Cat Distributr (EU) REACH Registrant REACH Dwnstream User Design- Make Supplier Nacelle (US) Subcmpnent Manufacturer (EU) Plating / Andize Shp (EU) REACH Dwnstream User OEM / Engine Manufacturer (US) OEM Airframe Manufacturer (EU) Custmer / Airline (Japan) Only the darker bxes have a direct rle in REACH Registratin and Authrisatin 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 7

8 Disruptin Risk Frm Registratin Csts and administratin f Registratin are placed n industry Prducers may withdraw prduct where return is lw Direct impact n the glbal Aerspace industry was narrwly avided in 2010 The Cmmissin prpsed a mechanism t resurrect brken supply chains This was rejected by member states Repeat is pssible in 2013 and prbable in AerSpace and Defence Industries Assciatin f Eurpe Slide 8

9 Authrisatin - Magnitude and Impact ~ 1 Millin Part Numbers affected by Chrmates Aftermarket as well as prductin Fr MRO, substitutes must be cmpatible with existing prduct Impact in standardisatin Changes must accunt fr differences in prduct and cntext May require different equipment r suppliers May take decades t substitute and industrialise Resurce/cst impact fr industry and regulatrs Sunset date Q insufficient time and ecnmically infeasible t substitute prductin and installed base The Aerspace industry is critically dependent n making Authrisatin wrk 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 9

10 Authrisatin with Multiple Sectrs SUPPLY CHAIN ROLE Sub-Assembly End Prducts Manufacture / Imprt Distributin Prcessing Manufacture Distributin Frmulatin This is Chemical Legislatin Authrisatin is by use AA/SEA specific t Prduct Sectr New, untested, n appeal Definitin f use is key Authrisatin useless withut supply Nn-Authrisatin fr sme sectrs can affect supply sustainability fr all USES PRODUCT SECTORS We must take care t get this right! 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 10

11 Authrisatin in Aerspace Authrisatins can flw dwn, but nly up ne level Mst chemicals used in industry are mixtures Substances: 1 Chemical Prducers: 10 s Frmulatrs: 10 s End-Users: 1000 s Applicatin Fr Eurpean Mixtures the Applicant must be the Chemical prducer r Frmulatr Whle supply chain benefits Will nt happen unless the majr manufacturers lead Analysis f Alternatives (AA) Sci-Ecnmic Analysis (SEA) Requires a cnsrtium and upstream engagement 2013 AerSpace and Defence Industries Assciatin f Eurpe Airlines 100 s Slide 11 Specify use Cmpnent Suppliers: 10,000 s Sub-System Prviders: 100 s Airframe/Engine Manufacturer 10 s Specify use Lead MRO Facilities 1000 s

12 Nn-Eurpean Mixtures Substances: 1 Chemical Prducers: 10 s If mixtures are imprted int Eurpe, have different ptins End-User applicatins are impractical if many users Sme Frmulatrs might apply as Only Representatives The best slutin is fr sme Imprters t apply if persuaded Hw d we ensure this and share csts? Airlines 100 s Specify use Frmulatrs: 10 s Imprter/ Distributrs: 100 s End-Users: 1000 s Cmpnent Suppliers: 10,000 s Sub-System Prviders: 100 s Airframe/Engine Manufacturer 10 s ORs Specify use Lead Applicatin MRO Facilities 1000 s 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 12

13 Reference date fr applicable rules In Aerspace, the applicable Airwrthiness requirements are frzen at Prduct Launch The relevant airwrthiness cde in effect n the date f applicatin fr type certificate Typically 5 years befre type entry int service This principle has been applied in ther Regulatin, e.g. fr Halns Haln phase-ut: Regulatin 744/2010 amending Reg 1005/2009 Cut-ff date means the date after which halns must nt be used fr fire extinguishers r fire prtectin systems in new equipment and new facilities fr the applicatin cncerned New equipment means equipment fr which, by the cut-ff date, neither f the fllwing events has ccurred: (a) signature f the relevant prcurement r develpment cntract; (b) submissin f a request fr type apprval r type certificatin t the apprpriate regulatry authrity. Similar principles shuld be applied in sme way fr REACH 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 13

14 Fast track and streamlined prcess fr Aerspace Authrisatins applicatins It is prpsed in all cases t simplify Authrisatin Cnditins f use in Safety Data Sheets must be applied Fr the fllwing cases, Authrisatin culd be granted via a substantially simplified prcess, fr Life f Type Existing Aircraft n lnger in prductin Aircraft still in prductin Fr substances nly used in new prgrammes prir t Applicatin fr Type Certificate, higher justificatin required It is prpsed EASA, ECHA and Industry will develp apprpriate guidelines fr Aerspace applicatin Jint actin needed, cmplete by June AerSpace and Defence Industries Assciatin f Eurpe Slide 14

15 Key Risks - Authrisatin Failure f Authrisatin - new, untested, n appeal Upstream cmpanies refuse t act as applicant E.g. due t legal expsure r capability SMEs fail t act r cease trading due t lack f awareness r csts including awareness f Authrisatin cnsrtia Insufficient time t manage Authrisatin cverage acrss, up and dwn cmplex supply chains Insufficient time t resubmit if applicatin rejected time windws, cmmittee wrk flw, nt guaranteed Supply chain cntractin Aerspace use vlumes insufficient t maintain cmmercial viability 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 15

16 2013 AerSpace and Defence Industries Assciatin f Eurpe The infrmatin in this dcument is the prperty f AerSpace and Defence Industries Assciatin f Eurpe (ASD) and may nt be cpied r cmmunicated t a third party, r used fr any purpse ther than that fr which it is supplied withut the express written cnsent f ASD BACK-UP 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 16

17 Authrisatin Simplificatin Analysis f Alternatives (AA) ECHA Cmmittees prepare pinins n Authrisatin applicatins Public cnsultatin challenges t alternatives analysis Prepare pinins n the Analysis f Alternatives Recmmend acceptability f case t supprt Authrisatin EASA Obligatins f Type Certificate Hlder include: Cntrl f design data, sentencing and apprval f change Validatin that changes meet the type certificatin basis Ensure capability f sub-cntractrs and ther parties Including 3 rd parties suggesting that alternatives are available T what extent can ECHA cntradict the psitin f the Type Certificate hlder? AA can be simplified t reflect respnsibilities f Type Certificate hlders and EASA 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 17

18 Authrisatin Simplificatin Sci-Ecnmic Analysis In Aerspace and Defence industry, nn-availability f key substances impact directly n: Sales, aftermarket and trade - thrughut the supply chain Maintenance f in-service prducts Operatinal limitatins t ensure prduct safety If Authrisatin rejected, limited ptins available Ecnmic impact will always be high fr many chemicals Sci-Ecnmic Analysis (SEA) shuld be simplified t reflect this 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 18

19 AEA CONCERNS RELATED TO REACH AEA presentatin at AEA-ASD-EASA-ECHA Meeting Clgne, 23 January 2013

20 AGENDA Airline Business AEA Facts and Figures Airline Business an Overview Maintenance Repair Organizatin (MRO) Business Assurance f Airwrthiness EASA Regulatins Aircraft Maintenance Prgram Develpment Lengthy prcess MRO Business Dealing with Chemicals Wrking Cnditins / E,H&S Standards AEA view n actual REACH Prcedures Authrizatin ut f MRO Perspective Case Study (Chrmium Trixide Cnsrtium) Multiple Prducts and Uses f SVHC Flexibility Supply Chain Cntinuity Substitutin ut f MRO Perspective Summary

21 AEA FACTS ANDFIGURESI 33 member airlines with 2,600 aircraft 11,000 flights/day 640 destinatins in 170 cuntries 93BN TOTAL TURNOVER 390,000 jbs 400 millin passengers (supprts 7.8 millin jbs) 6 millin tnnes f carg

22 AEA FACTS ANDFIGURESII Eurpe (clse t) the wrst perfrming regin f the wrld

23 AIRLINE BUSINESS AN OVERVIEW OEMs Airwrthiness Agencies Airline MRO L Required checks t maintain airwrthiness L L Ad hc supprt t recver airwrthiness Assure safety Keep aircraft in peratin Assure safety 24/7 supprt t bring aircraft back in peratin Safety - Baseline Aircraft n grund as sn as safety is affected High-quality and flexible MRO supprt necessary t get A/C back in peratin (arund the wrld, fr every used aircraft type & cmpnent) Safety -Business case Aircraft huge investment: assurance f airwrthiness necessary fr whle prduct lifecycle (> 30 years) Aircraft n grund: every minute means lss f revenue Rapid and mst time and cst efficient MRO service necessary (24/7, within internatinal cmpetitive envirnment)

24 MRO BUSINESS ASSURANCE OF AIRWORTHINESS high-quality flexible rapid efficient cmpetitive Highly regulated, cmpetitive & lw prfit margin envirnment Immediate supprt fr A/C when nt airwrthy (requires materials like primers, prepreg, resins at shrt ntice) Prduct diversity Large number f (Eurpean) aircrafts in the sky. New & ld aircraft / engine types Expensive airplane with lng life span due t cntinued maintenance, repair & mdificatins: 747 designed in 1960s, Heritage aircraft & engines: 707 designed in 1950s is still flying. Fkker 50/70 designed in 1980s All types f cmpnents (frm blts t engines) Quality f hardware is critical

25 CONTINUED AIRWORTHINESS- CHALLENGES Severe peratinal envirnment Temperature, humidity, pressure, altitude, lightning strike Oils, fuel, xygen, nitrgen, ht & cld air Electricity, battery, Light metals (a cnsists f 66,150 kg f aluminum), wiring, tubing, cmpsites Intense aircraft utilizatin Up t 16 hurs a day n an average passengers, catering, waste Variety f air freight live carg, perishables, ff-size, pharmaceuticals Structural damages, Spills & cntaminatins frm carg & passenger handling

26 EASA REGULATION FOROPERATOR& MRO IS ALL ABOUTSAFETY& AIRWORTHINESS Basic Regulatin 216/2008 (181) 748/2012 (269) 2042/2003 (449)

27 MAINTENANCE DATA CANNOT BE CHANGED BY MRO Maintenance and repair instructins are EASA apprved prcedures Pre-defined fr every aircraft type, engine and cmpnents Pre-defined materials - primers, paints, platings, prepregs, resins, etc. Different TCH/OEM use different prduct spec/prducts fr similar functins. MRO requirements are pre-defined fr whle prduct life span Old designs/materials ften require heritage materials fr repair & maintenance. Majrity f prcedure changes / materials substitutin cannt be made withut prf f airwrthiness and apprval by Agencies beynd MRO scpe

28 MAINTENANCE PROGRAM DEVELOPMENT LENGTHY PROCESS Many stake hlders Detailed analysis f millins f parts/cmpnents, znes/areas, wiring & tubing, etc. MPD wrk starts 4 years prir t certificatin and requires many thusand engineering hurs. Out-f-prductin aircraft/engine/cmpnent maintenance prgrams are difficult t change

29 MRB TECHNICAL INVESTIGATION& FOLLOW UP AT EASA

30 EXTRACT FROM AN MRB REPORT

31 MRO BUSINESS DEALING WITH CHEMICALS Chemical database maintained by MRO Well defined high standard H&S prcedures in cmpliance with natinal & Eurpean regulatins. Well trained emplyees Health &Safety Departments Dust & vapr extractin systems Persnnel Prtective Equipment Suitable SVHC strages Risk analysis & mitigatin prcess Fcus n aviding hazardus substances as much as pssible Sme peratrs have ISO qualificatins

32 AEA REVIEW OF ACTUAL REACH PROCEDURES AUTHORIZATION OUT OF MRO PERSPECTIVE Case Study Authrizatin Cnsrtium Cmpanies ut f Aviatin Industry jined Chrmium Trixide Cnsrtium t prepare authrizatin applicatin 154 Members, ut f several different industry sectrs Preparatin f authrizatin dssier, split int seven use grups Aim t share csts, but High wrklad t identify and cllect data -Insufficient Chemical Safety Reprt data frm chemical industry. Aviatin cmpanies have several uses in parallel => have t d the wrk a number f times (airwrthiness) requirements f aviatin cmpletely differ frm ther industry sectrs => increase f dssier parts which have t be develped n its wn fr aviatin N decrease f risks: Use definitin still nt clear Granted authrizatin nt assured Alternatives cannt be utlined as required by AA High investment f resurces fr an unsecure prcess (and just fr ne substance & ne use)

33 AEA REVIEW OF ACTUAL REACH PROCEDURES AUTHORIZATION OUT OF MRO PERSPECTIVE II Multiple prducts and uses f multiple SVHC Small amunts used (cmpared t ther industries) Specific and different uses One SVHC: multiple prducts Manifld uses fr ne prduct: each f these prducts have multiple functinal applicatins (different parts, cmpnents, structures) Burden f preparatin f authrizatin fr each use cannt be handled by single MRO cmpany (dwn stream user) Flexibility Unpredictable needs (lking at vlume and esp. type f material as depended n needed repairs) Prduct availability must be assured in shrt timeframe Ad hc prduct demand requires pssibility t an unlimited chsing f suppliers Need t change prducts/prcesses due t new MRO custmer Even in case f a granted authrizatin fr ne supply chain, risk f supply disruptin unacceptable

34 AEA REVIEW OF ACTUAL REACH PROCEDURES AUTHORIZATION OUT OF MRO PERSPECTIVE III Supply chain cntinuity Supply chain characteristics Cmplex and lng supply chain (Eurpean and Nn-Eurpean actrs invlved) MRO knws its distributr but in general n further actrs within supply chain Due t small vlumes, MRO demand des nt mean a business case fr (substance) manufacturers Due t REACH (especially authrizatin effrt) risk f supply chain disruptin increases E.g.: airwrthiness requires chrmate cntaining sealants => in case f prductin stp verhaul prcesses n any aircraft in peratin culd nt take place any lnger (in Eurpe) Even a high chance t get authrizatin fr aviatin uses mean a challenge fr supply chain cntinuity due t the high burden f authrizatin fr suppliers cmpared t small vlumes sld fr aviatin

35 AEA REVIEW OF ACTUAL REACH PROCEDURES SUBSTITUTION OUT OF MRO PERSPECTIVE Out f an AEA / MRO perspective substitutin wuld mean a majr change in existing fleet / ut f prductin aircraft Changes in given / apprved structures nearly impssible: structures, weights, electrnic, hydraulic are highly aligned with each ther Use f new chemicals (e.g. primer) n ld materials may have unexpected utcmes lking at material resistance and functin Heritage materials necessary t fulfill airwrthiness requirements f lder aircraft /engine types Obslescence prblems Aircraft / cmpnents designed fr lngevity => prducts value create business case fr maintenance and verhaul New materials with decreased durability may require (if apprved at all) shrter peratin cycles (higher demand fr MRO) => nt acceptable fr Airlines, t be scrutinized ut f an envirnmental and health and safety pint f view

36 SUMMARY AEA & REACH - DIFFICULTIES Airlines/Operatrs/MRO use many chemicals / frmulatins affected by REACH authrizatin prcedures Cmplex end users f (SVHC cntaining) chemicals Small SVHC quantities, but in multiple prducts and applicatins Authrizatin prcess is cmplex, time cnsuming & expensive, whereas Aircraft maintenance & repair tasks, including materials used in this prcess are EASA regulated. MRO cannt substitute alternate prducts with ut EASA apprval. MRO des nt have the expertise nr resurces t find alternate prducts. Eurpean MRO fllw high standard f H&S prcedures. Many f them have related ISO certificatins. SIMPLER AUTHORIZATION PROCESS IS REQUIRED FOR THIS INDUSTRY.

37 2013 AerSpace and Defence Industries Assciatin f Eurpe The infrmatin in this dcument is the prperty f AerSpace and Defence Industries Assciatin f Eurpe (ASD) and may nt be cpied r cmmunicated t a third party, r used fr any purpse ther than that fr which it is supplied withut the express written cnsent f ASD SUMMARY AND SUGGESTIONS Suggestins made herein are t initiate discussin and shuld in n way be viewed as final r cmplete 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 37

38 Summary Cncerns Safety is nt negtiable fr Aviatin Aviatin is strictly regulated t ensure safety and perfrmance All changes are heavily analysed and requires lng intrductin perids Alternatives take years t develp, every cntext must be cvered Alternative develpment is nt guaranteed Substitutes must be cmpatible with the existing fleet Wrk place safety is als nt negtiable, the key is safe use The REACH bslescence threat is real Authrisatin and Registratin - we cannt rely n cntinued supply withut interventin Inter-sectr supply dependence n cmmn supply chain sustainability Supply chain cntractin and lss f flexibility expected One substance, many applicatins, all must be managed The aftermarket is dependent n industry fr slutins Authrisatin is unavidable, untested, and difficult in ur supply chains Failure t reslve these issues will impact prductin, aftermarket and peratins, and the many businesses invlved 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 38

39 Suggestins made herein are t initiate discussin and shuld in n way be viewed as final r cmplete Summary Suggestins ECHA/EASA Simplify apprach t Authrisatin in Aerspace and Defence sectr (SEA and AA) Especially fr legacy and prductin prducts based n Type Certificate applicatin date (like Halns) Making best and apprpriate use f EASA / ECHA cmpetencies Jint actin t prduce agreed guidance Q EASA Cnsultatin in ECHA Cmmittees Making use f EASA as part f Eurpean administratin T prvide independent perspective where Aerspace-related Authrisatins are in questin (SEAC/RAC) On behalf f ther Airwrthiness authrities als? SEAC = Cmmittee fr Sci-Ecnmic Analysis, part f ECHA RAC = Cmmittee fr Risk Assessment, part f ECHA 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 39

40 Suggestins made herein are t initiate discussin and shuld in n way be viewed as final r cmplete Summary Suggestins ECHA/EC Fast-track Authrisatin prcess fr re-submittals Cnsider creative Authrisatin applicatin mdels T allw prduct sectrs t manage applicatins n behalf f chemical prducers and frmulatrs Supply Chain recvery prcess fr nn-registratin Reinvigrate discussins ref. CA Allw Aerspace industry t present case t CARACAL Cntact Grup fr Authrisatin prcess issues: Aerspace Industry representatin due t criticality f issues Pssible extensin t existing Directrs Cntact Grup, prvided that Aerspace industry is represented 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 40

41 Suggestins made herein are t initiate discussin and shuld in n way be viewed as final r cmplete Summary Suggestins - ECHA Accunt fr cmplex supply chain needs in prpsed Authrisatin timescales Bth sunset date and review perids Help Users and ptential Registrants t make cntact T allw users t identify need fr substance T allw ptential Registrants t check befre stpping supply Aid SME awareness f Authrisatin cnsrtia Disseminate knwn cnsrtia and cntacts n web-site 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 41

42 Objectives f Wrkshp Cmmn understanding f the specific issues the Aviatin industry faces in managing the REACH Regulatin T ensure the sustainability f aircraft prductin and peratin in recgnitin f needs fr aircraft safety Develpment f partnership between EASA and ECHA t assist industry in managing the risks An agreed actin plan and wrking grup t get a tailred jint slutin fr the Aerspace industry Recgnising the urgency f this need 2013 AerSpace and Defence Industries Assciatin f Eurpe Slide 42