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Boeing Technical Journal

Advancing Environmental Technology with


IAEG and our Competitors
*Branton, Jennifer

Abstract – The international Aerospace Environmental One of the European Union regulations administered by
Group (IAEG), established in 2011, is an international ECHA is REACh (Registration, Evaluation, Authorization
organization that focuses on environmental issues and and restriction of Chemicals). Companies that manufacture
regulations within our industry. Boeing is one of the founding or import certain substances into Europe are required to
members of this organization along with eleven other industry
register with ECHA, and collect and report information on
leaders. With the ever-increasing number of regulations coming
out of ECHA in the EU and other countries such as China, substances imported or used above one metric ton per year.
Korea, South Africa, and Australia, there was a large need to ECHA evaluates the information that is submitted by
have a global organization representing our industry while companies and assesses the risk to human health and the
focusing on the myriad of laws and regulations impacting environment. A substance may be identified as a substance
health and the environment. This group seeks to drive continual of very high concern (SVHC) if it is carcinogenic,
improvement in the processes used by the aerospace industry, mutagenic, toxic for reproduction, or persistent or
thereby delivering consistently high quality products and bioaccumulative and toxic. Materials that are labelled as
regulatory compliance with reduced environmental impacts. SVHC may become subject to authorization under the
REACh regulation for continued use in Europe. When a
Working Group 2 (WG2) of IAEG focuses on replacement
substance is placed on the Authorization list it is assigned
technologies for hazardous materials. This paper reviews the
replacement technology efforts of WG2 and the new two dates: a last application date to apply for authorization
development technologies that were kicked-off in 2017. It will and a sunset date, which is the date when the substance can
discuss the initial five technology projects that are underway no longer be used within Europe without having been
and the different approaches being taken by the various granted approval to continue use through an authorization
projects as well as the advantages to Boeing and the challenges application.
we will face collaborating with our suppliers and competitors. REACh regulations do not only affect Boeing. They also
have an impact on the operations of Boeing’s Tier 1
Index Terms – Environment, Regulation, IAEG, EHS, EChA, suppliers, approved processors listed on the Approved
REACh Process Sources D1-4426, and maintenance repair operations
that airline customers employ to service Boeing aircraft.
Essentially Boeing’s entire supply chain may be affected. (1)

II. INTERNATIONAL AEROSPACE ENVIRONMENTAL GROUP


(IAEG)
I. INTRODUCTION The International Aerospace Environmental Group
(IAEG) is a trade association formed by major aerospace
The Environmental Team within Chemical Technology, companies. In response to the rising number of chemical
Boeing Research & Technology focuses on material regulations passed by the European Union and other
replacement technology needs driven by impending governing bodies, Boeing and other industry leaders founded
regulations. Chemical regulations can originate from any the IAEG. This organization focuses on the multitude of
number of countries that are implementing new policies. global laws and regulations impacting health and the
However, many of the regulations that impact the Aerospace environment. The founding members of this organization
Industry’s use of certain substances are initially brought include Airbus SAS, Airbus Group SE, The Boeing
forth by the European Chemicals Agency (ECHA) or the US Company, Bombardier Inc., Dassault Aviation, Embraer
Environmental Protection Agency (EPA). S.A., GE Aviation, Northrup Grumman Corporation, Rolls-

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BOEING TECHNICAL JOURNAL

Royce plc, Safran S.A., United Technologies Corporation agreements. The IAEG legal counsel and Executive
(UTC), and Zodiac Aerospace. (2) Committee reviews the collaboration agreements and
IAEG currently has ~50 member companies representing statements of work prior to the projects being routed to the
more than half of the aerospace industry with a combined participating companies for signatures.
annual turnover over $400 billion. Together these companies
seek to drive continual improvement in the processes used A. Hard Chrome Plating
by the aerospace industry, thereby delivering consistently The first of the technology exchanges focuses on hard
high quality products and regulatory compliance with chrome plating used by the Aerospace Industry. The
reduced environmental impacts. (2) collaboration includes participants from Boeing and 6 other
There are several working groups which have a variety of industry leaders.
focuses, ranging from monitoring & surveillance to reporting Chromic acid is used in the hard chrome plating process to
and replacement technologies. In particular, Working Group produce a thick hard chrome plating to be applied to steel or
2 (WG2) focuses on Replacement Technologies and has over other metal alloys. Hard chrome plating is applied directly to
40 participants representing more than 26 member a base metal by electrodeposition of a solution containing
companies. (2) chromic acid or potassium dichromate. The electrodeposition
The historical activities of WG2 include prioritizing the process makes it possible to apply hard chrome plating to
replacement technology needs and distributing performance parts with complex geometries. It is a cost-effective coating
requirement documents (PRD) to suppliers to request which is resistant to corrosion and to wear from sliding,
potential replacement materials for the replacement need at fretting, and environmental conditions. (3)
the top of the prioritization list. Although several alternatives have been developed for
The WG2 prioritization process was conducted by each hard chrome plating, none are direct drop-in replacements.
WG2 member company submitting five prioritized Thus, process modifications and design changes will be
replacement technology needs. Each company’s votes were required.
scored, and the needs with the highest priority were assigned The goal of this first technology exchange is to identify
more points than those with lower priority. The votes and environmentally compliant alternatives to hard chrome
scores of each replacement technology were tallied and plating. The statement of work includes exchanging
ranked. information available in the public domain as well as from
Three PRD’s have been prepared since the team was participants’ research experiences to identify alternatives for
established. The first two PRDs garnered little to no response hard chrome plating on standard parts and original
from the many suppliers that were targeted. The third PRD equipment manufacturer (OEM) designs.
was distributed to suppliers in early 2016. Responses were
received from 8 of the 9 suppliers contacted. However, none B. Chromate Conversion Coatings
of the proposed replacement materials submitted by
suppliers met all of the requirements listed in the PRD. The second replacement project is focusing on conversion
In late 2015, the IAEG Executive Committee approved a coatings that provide corrosion protection and electrical
change in the IAEG Charter to allow collaborative work conductivity to aluminum substrates in the Aerospace
between member companies under a collaborative Industry. The proposed solutions will be hexavalent
agreement. This was followed by a revision to the WG2 chromium-free. This technology exchange includes Boeing
charter to define how these collaborative activities could and ten additional companies.
proceed. The years of 2016 and 2017 were dedicated to The goal of this technology exchange is to review the
developing the process flow for new replacement technology proposed environmentally compliant alternatives to
efforts and establishing the initial projects’ statements of chromate conversion coatings and summarize performance
work and collaboration agreements. data provided by the participants and major suppliers. The
team will then propose next steps. As with the hard chrome
III. REPLACEMENT TECHNOLOGY PROJECTS plating replacement effort, this technology exchange is
planned for a brief period and is proposed to be complete
Five replacement technology projects were initiated in
after 5 months.
2017. The statements of work and collaboration agreements
were prepared for these projects and required approval and
signature from all participating companies. Four of the C. Bond Primer
Bond primers are used for a variety of applications and
projects are technical exchanges where subject matter
often contain strontium chromate which has a sunset date of
experts from the participating companies share and exchange
January 2019. In addition to corrosion resistance, bond
data regarding what technology worked and what did not
work for that project’s material replacement efforts. The primers enhance wetting capability for film adhesive contact
remaining project is a research and development effort to not and improve adhesion between the substrate and adhesive.
These properties result in widespread use over many
only share past research experiences and results, but to also
different applications. This project’s scope will only include
develop new replacement materials.
applications where at least two of the participating
The projects were defined by an approved statement of
companies use bond primer. This replacement effort is a
work and are being conducted under collaboration

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BOEING TECHNICAL JOURNAL

technical exchange and includes Boeing and 7 additional IV. ADVANTAGES & CHALLENGES OF COLLABORATIVE
companies. RESEARCH
This technology exchange will include information in the
As part of the REACh regulation it is necessary for all
public domain as well as member companies’ replacement
businesses in the aerospace industry that conduct business in
efforts. The deliverables of this project include identification
Europe to find replacements for the regulated hazardous
of applications and the functional requirements, exchange of
chemicals. Many of these materials pose a great challenge to
technical information regarding past replacement efforts, and
finding an alternative that performs well enough to pass the
identification of potential alternatives to current bond primer
performance requirements. Thus, these companies must all
systems.
apply for authorization to continue using the legacy materials
past their sunset dates. In order to receive authorization
D. Cadmium Plating on Industry Standard Parts
approval, the company must demonstrate that it has projects
Cadmium Plating on Industry Standard Parts is an R&D
in process to replace the material in question.
Replacement Technology effort. This replacement project
Working together on these technical challenges provides
focuses on cadmium plated fasteners and cadmium plated
several advantages to Boeing as well as its collaborators.
electrical connectors used by the Aerospace industry. There
Collaborative efforts among these companies can show that
are 8 WG2 member companies participating in this
there is an industry-wide effort to find alternatives to
replacement technology project, which includes Boeing.
hazardous materials and to be more environmentally
Cadmium functions as a sacrificial coating when it is
conscientious. Additionally, the cost savings can be
plated onto copper, aluminum, or steel substrates. A
significant for the participating companies; the collaboration
sacrificial coating corrodes before the substrate metal,
allows each of these companies to contribute a portion of the
thereby protecting it. Although some alternatives exist to
project financing rather than each individual company
cadmium plating, industry standard parts provide an
funding the entire effort independently.
additional challenge to replacement. (5)
Reaching agreement and alignment on the project
The design and manufacture of industry standard parts are
requirements by the numerous participating companies may
conducted per industry specifications. These parts may be
present a challenge. However, the project establishment
manufactured by many suppliers across different countries
process has worked well thus far and the synergy within the
and subsequently used by many different customers. Thus,
industry should reduce this risk.
no single company can change the industry design without
Boeing has been a participant with each of these projects
gaining agreement from the many other users and suppliers.
since they were initiated. Subject matter experts within
Investigating and implementing a replacement to cadmium
Boeing have been involved with each of the project teams.
plating of industry standard parts requires a united and
coordinated effort across the Aerospace Industry.
V. CONCLUSION
The output of this work will include a list of industry
standard parts that are within the scope of this project, a set Collaborative research among competitors can be difficult
of the technical, commercial and environmental and requires a careful balance of strategic sharing of
requirements of alternatives, and the resulting data produced proprietary information to advance the technology and
from the requirements testing of these alternatives. protection of proprietary information for competitive
advantage. Finding alternatives for some of the hazardous
chemicals poses a great technical challenge. This technical
E. Corrosion-inhibiting Epoxy Primers challenge justifies such a collaboration and sharing
Corrosion-inhibiting epoxy primers are used to protect proprietary information with our customers, suppliers, and
metals against oxidation. Oxidation occurs over time when competitors in order to advance the technology beyond what
metals are exposed to fluids, humidity, or dissimilar metals. any of the participating companies could do independently.
Like bond primers, epoxy primers also contain strontium We hope these initial collaborative projects will be the
chromate. This corrosion inhibitor had a sunset date of beginning of a great resource for the aerospace industry to
September, 2017, set by EChA and thus needs to be replaced overcome technical challenges and find solutions together
with an alternative (6). This challenge is being addressed for hazardous chemical replacements.
through a technology exchange project. The participating
companies include Boeing and 6 additional aerospace VI. REFERENCES
companies.
1. Regulations. (2016). European Chemicals Agency
This project team will exchange information on test
(ECHA). Retrieved 12/7/2016 from:
methods that have been used by the various team members
https://echa.europa.eu/regulations
for critical test requirements and establish a list of
fundamental key requirements for the aerospace industry. 2. International Aerospace Environmental Group
The project team will then create a list of available primer (2016). Retrieved 10/13/16 from
http://www.iaeg.com/
candidates that have the potential to meet the requirements.
3. Committee of Stainless Steel Producers. (1978).
The group will then consider expanding the scope to
Review of the Wear and Galling Characteristics
establish a test plan, and begin testing potential candidates.
of Stainless Steels. A Designers’ Handbook

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BOEING TECHNICAL JOURNAL

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https://www.nickelinstitute.org/~/Media/Files/Te
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