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REACH

Dr E H Blacklay28 October 2015

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What is REACH Aviation Sector Impact CAA Policy CAA Concerns Summary

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REACHRegistration, Evaluation, Authorisation & restriction of ChemicalsEC 1907/2006

REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation & restriction of Chemicals EC 1907/2006.

European Regulator: European Chemical Agency ECHA based in Helsinki, Finland.

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REACHRegistration, Evaluation, Authorisation & restriction of ChemicalsEC 1907/2006

REACH provides for the management of Substances of Very High Concern (SVHC) through its processes of:

Identification Notification Authorisation/Ban Restriction Communication

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REACHRegulated Substances Lists Candidate List:

Chemicals identified as Substances of Very High Concern (SVHC) are listed as the first step of the Authorisation process. (163 Substances currently listed)

Annex XIV – Authorisation List:List of substances that are subject to ECHA authorisation otherwise will be banned on a defined date known as the “Sunset Date”. (31 Substances currently listed)

Annex XVII – Restrictions List:List of restrictions concerning the manufacture, sale, and use of SVHC (on their own, in mixtures or in articles). (63 listed restrictions which in some cases apply to multiple substances)

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Annex XIV – Authorisation ListExamples

SVHC Uses Sunset dateDibutyl Phthalate(DBP)Bis-(2-ethylhexyl) Phthalate (DEHP)

Paints, Sealants & Adhesives Feb 2015

Trichloroethylene Degreasing and Cleaning April 2016Chromium TrioxideSodium Chromate/DichromatePotassium Chromate/Dichromate

Aluminium AnodisingPickling of Stainless SteelsPassivation of Stainless SteelsSealing of Anodised AluminiumChemical Conversion CoatingsHard Chrome Plating

Sept 2017

Strontium ChromateZinc Potassium Chromate

Jointing CompoundsSealantsExternal paintsBonding Primers

Jan 2019

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Primacy of EHCA & EASA Regulations Neither the REACH regulation implemented by ECHA nor

those governing airworthiness overseen by EASA take precedent over the other.

For compliance with REACH the industry needs to either: Use an acceptable alternative/replacement of the SVHCs listed in

Annex XIV, or Seek authorisation to continue to use the SVHCs listed in Annex.

But compliance with existing Airworthiness Requirements and procedures must be maintained.

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CAA PolicyAlternatives and Replacements Where the chemical/substance/mixture/compound contained in approved

design/production/maintenance data is no longer available, the use of alternatives/replacements must be approved by the design organisation responsible for the original data.

Alternatives/replacements offered by supplier and stockists should only be accepted where objective evidence of design organisation acceptance (such as a formally issued alternative materials list) is available.

Statements by suppliers/stockists in company literature or on websites that replacement materials are authorised by design organisations, should not be taken at face value.

CAA Information Notice IN-2013/155 “Registration, Evaluation, Authorisation and restriction of CHemicals (REACH)”

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CAA Concerns

Is there sufficient knowledge and understanding in the Approved Organisations sub-contractors to maintain compliance with both ECHA and EASA regulations?

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Further Information

REACH Interpretation guidelines; ASD May 2014 An elaboration of key aspects of the authorisation process in the context of aviation indust

ry; ECHA-EASA April 2014 Registration, Evaluation, Authorisation and restriction of Chemicals (REACH); IN-2013/15

5 CAA Oct 2013

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Summary