REACh gives concern to aerospace sector

REACh (Registration, Evaluation and Authorisation of Chemicals) is probably the most important piece of European Union legislation for twenty years. Coming into force 1st June 2007, it requires business to ensure that chemicals used are safe.

One of the overriding principals is to encourage the replacement of hazardous chemical materials with safer options. Ultimately this legislation is designed to improve the protection of human health and the environment. Manufacturers and importers of are required to provide detailed information on material properties and register with the Helsinki based European Chemicals Agency ECHA.

The UK Surface Engineering Association SEA recently held a briefing session at the House of Lords in Westminster, hosted by Lord Hoyle and supported by Paul Wynn of the Institute of Metal Finishing. The purpose of the visit was to inform the Lords on progress with REACh and the specific concerns of surface treatment applications in the Aerospace industry.

Representing the sector was J. Henshaw of Goodrich, who highlighted a review on the use of "Hexavalent Chromium and Soluble Nickel in Aerospace" which has been conducted by Goodrich and Rolls-Royce.

Whilst the industry agrees these material are of high concern, they are not present in the final product. They are also used in a number of flight critical applications for safety reasons and cannot be substituted given the status of current alternative technologies. It was also pointed out that the sector requires significantly longer introduction times due to extensive testing requirements to prove airworthiness.

There is anecdotal evidence around Europe, that a number of countries and organisations are lobbying for these materials to be listed into Annex XIV as substances of high concern and an acceleration of the process. If realised, it is likely they may be eliminated from use within 36 to 48 months, which would be disastrous for Aerospace and surface finishing as a whole.

There is a real danger that through ignorance, Eurocrats and ECHA will incorrectly eliminate the use of substances vital to our industry and manufacturing. Therefore bodies representing surface finishing have a responsibility to lobby the European Commission,  ECHA and member state governments to avoid these kind of mistakes.

Clearly Aerospace will require exemption for existing aircraft programmes if the materials did find there way onto Annex XIV. The Goodrich/Rolls Royce work shows that Hexavalent Chromium and Soluble Nickel are not present in the final components and thereby do not represent a danger of exposure to the public. Furthermore it has been established that alternatives are yet to reach a stage of maturity to enable the Aerospace sector to implement their use in safety critical applications.