REACH, Rolls-Royce & the Supply Chain

Cathy Phillips, HS&E Materials Rolls-Royce Group
© 2007 Rolls-Royce plc The information in this document is the property of Rolls-Royce plc and may not be copied or communicated to a third party, or used for any purpose other than that for which it is supplied without the express written consent of Rolls-Royce plc. This information is given in good faith based upon the latest information available to Rolls-Royce plc, no warranty or representation is given concerning such information, which must not be taken as establishing any contractual or other commitment binding upon Rolls-Royce plc or any of its subsidiary or associated companies.

Rolls-Royce today
 A global business  £24bn order book  £6.6bn annual sales  £663m R&D  36,000 employees  7,600 engineers  Supporting four market sectors
Defence

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Civil

Energy

Marine

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc

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REACH, Rolls-Royce & the Supply Chain
 What REACH means to Rolls-Royce  Issues we foresee within the supply chain  What Rolls-Royce is doing to prepare for implementation – within the company  Managing the supply chain issues  Summary

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc

4 What REACH means to Rolls-Royce Rolls-Royce as an importer  Alloys are preparations (bar.ppt October 2007 © Rolls-Royce Plc . specialist metallic powders etc)  Processing chemicals (drums of liquid and powder preparations etc)  Importing finished articles (with no intended substance release) IMF REACH Seminar Rolls-Royce presentation 9 Oct. billet.

5 What REACH means to Rolls-Royce Rolls-Royce as an importer  Rolls-Royce will have to be involved in pre-registration/registration if we import > 1 tonne of a substance (which could be in several imported preparations).ppt October 2007 © Rolls-Royce Plc . IMF REACH Seminar Rolls-Royce presentation 9 Oct.  Contracts on non-EU suppliers will have to change to obtain information to complete registration.

6 What REACH means to Rolls-Royce Rolls-Royce as a downstream user  Making articles out of preparations. and using preparations / substances during manufacture  Making some preparations (eg thermal paints)  Conducting Product and Process Oriented Research and Development (PPORD) with suppliers IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .

at > 0.7 What REACH means to Rolls-Royce Rolls-Royce as a downstream user  Check whether SVHCs are in products following manufacture.ppt October 2007 © Rolls-Royce Plc .1% w/w  Check all our uses are registered  Substances used in PPORD will require notification to the Agency. and will probably avoid SVHCs (including candidate substances) IMF REACH Seminar Rolls-Royce presentation 9 Oct.

8 What REACH means to Rolls-Royce Rolls-Royce as a downstream user  Using the new extended safety data sheets  Legal requirement to use the RMM specified Too Too restrictive… write own CSR vague… write own CSR Two suppliers.ppt REACH October 2007 © Rolls-Royce Plc . 2 different RMMs? RMM ‘Library?’ IMF REACH Seminar Rolls-Royce presentation 9 Oct.

within process chemicals – and unable to change quickly to alternatives (in some cases. there may be no alternatives) IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .9 What REACH means to Rolls-Royce Rolls-Royce as a user of substances of very high concern (SVHC) Using SVHCs within alloys.

IMF REACH Seminar Rolls-Royce presentation 9 Oct. designers and technical experts will need to work with customers (who may specify SVHC use) and suppliers (who may have a technical necessity to use SVHC) to prove the need for each SVHC within any Authorisation.ppt October 2007 © Rolls-Royce Plc . purchasers.10 What REACH means to Rolls-Royce Rolls-Royce as a user of substances of very high concern (SVHC) Rolls-Royce specifiers.

11 What REACH means to Rolls-Royce Example: Trichloroethylene Trichloroethylene is a CMR which is very likely to be subject to Authorisation sooner rather than later.and use only as a last resort IMF REACH Seminar Rolls-Royce presentation 9 Oct.  MSDS Risk Management Measures will require totally enclosed degreasers with no release  Collaboration on socioeconomic analysis for Authorisation  Significant cost increases will occur Effect: We must continue to try to find safer alternatives.ppt October 2007 © Rolls-Royce Plc . Industry Response:  STOP supplying to companies with open topped / lidded degreasers from 2010.

12 What REACH means to Rolls-Royce IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .

13 Issues within the supply chain Supply chain… Issue… Changing formulations Withdrawal of formulation Could invalidate aircraft safety certification (European Aircraft Safety Agency. EASA) Need to find and prove alternatives to satisfy certification requirements IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .

14 Issues within the supply chain Supply chain… Lack of information about substances in formulations Lack of information about substances in dried coatings / adhesives etc. Issue… Unable to check that formulation is being used legally Unable to meet legal obligations to provide information on SVHCs to customers IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .

IMF REACH Seminar Rolls-Royce presentation 9 Oct.15 Issues within the supply chain Supply chain… Issue… Too specific or too general information on uses in the Chemical Safety Report Checking that substances are being used legally will be a laborious exercise Failure to register / Substance could be lost Failure to check that the due to supplier failure to substance is being engage in the REACH registered for their use registration process for their use of a substance.ppt October 2007 © Rolls-Royce Plc .

Purchasing.ppt October 2007 © Rolls-Royce Plc .20 Getting organised internally  Workshops for key stakeholders  Workshop for HS&E Practitioners. Chemists…  Workshop for Vice Presidents and Directors  Workshop for the business in North America  Plans for supply chain workshops with ASD / SBAC  Creating an implementation plan  Planning to establish an Integrated Project Team (IPT) at a corporate level and subsidiary IPTs for each of the most affected businesses IMF REACH Seminar Rolls-Royce presentation 9 Oct. Engineering.

Sharing best practice across sectors  Working with DEFRA and HSE IMF REACH Seminar Rolls-Royce presentation 9 Oct.Common guidelines for our sector(s) .Managing the Issues: Collaboration  21 The Aerospace sector globally is now working on several initiatives: .Supporting trade association / professional institution workshops on REACH .ARTICLES interpretation .Standard data to be collected from suppliers for REACH .ppt October 2007 © Rolls-Royce Plc .

ppt October 2007 © Rolls-Royce Plc . IMF REACH Seminar Rolls-Royce presentation 9 Oct.  REACH will require new information to be collected within companies. Engineering and Design. Manufacturing operations and HSE). to work together inside our companies (easy for SMEs!). and to be passed up and down supply chains (NOT easy for SMEs!).29 Practical Steps to Implementing REACH – What have we got to do?  REACH requires different areas (Purchasing.

 IMF REACH Seminar Rolls-Royce presentation 9 Oct.  If you want to maintain access to chemicals & raw materials. you need to get other departments to take on the implementation of REACH  So first you need to brief senior managers and then brief your top suppliers.30 Step 1: The end of ignorance  What should you do about it? Most of your supply chain is probably ignorant about REACH.  Your senior managers are probably ignorant about REACH.ppt October 2007 © Rolls-Royce Plc .

ppt October 2007 © Rolls-Royce Plc .31 Step 2: Get resource and plan  Start developing the action plan  Find out:  What is imported .Collating the information on how much is imported (looking at purchase orders over the past 3 years)  What is not imported. but is still strategically important .Checking that the supply chain are going to meet their obligations for registration IMF REACH Seminar Rolls-Royce presentation 9 Oct.

32 Step 3: build an material inventory Make a list of all the materials used by your business.ppt October 2007 © Rolls-Royce Plc . if you do not already have a list: Your PURCHASING people need to find out… The tradenames / specs of the chemicals you buy  Where and who you buy them from (import?)  How much you buy  IMF REACH Seminar Rolls-Royce presentation 9 Oct.

33 Step 3: build an material inventory Your LABS / MATERIALS People need to find out…  The substances in each of the materials (EINECs/ELINCS/CAS numbers)  Is it vital to your product or to a manufacturing process? IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc .

vPvB) – COSHH Inventories  What is your business risk (will the supplier register it or will you have to?)  IMF REACH Seminar Rolls-Royce presentation 9 Oct. for each Tradename / specification / constituent inside the preparation… Is it hazardous? (CMR.34 Step 3: build an material inventory You will need to identify. PBT.ppt October 2007 © Rolls-Royce Plc .

ppt October 2007 © Rolls-Royce Plc .35 Step 4: turn the materials inventory into a substance inventory SOMEONE (You? Purchasing? Labs?) needs to… Rearrange all the data you have by tradename / specification to be listed by substance  Check that each substance has either an EINECs or ELINCs number (if not – this is very bad)  Sum the amount of each substance you have bought in 2005.2006.  This is where off-the-shelf REACH software could really help…  IMF REACH Seminar Rolls-Royce presentation 9 Oct.2007 and average it.

36 Step 5: Decide what to pre-register  If you are an importer of >1tonne or more. you may choose to either: Find a supplier who will do it for you  Preregister it yourself to minimise your business risk…  IMF REACH Seminar Rolls-Royce presentation 9 Oct. you have to pre-register.  If the substance is strategically vital and your supplier will not guarantee they will pre-register / register.  If you MANUFACTURE SUBSTANCES you have to pre-register.ppt October 2007 © Rolls-Royce Plc .

your company details.  Consider sharing a ‘Third Party Representative’ The Data and Information Technology issues: Download IUCLID 5 software (its free) from the ECHA website  Fill it in with the basic information – which tonnage band.  IMF REACH Seminar Rolls-Royce presentation 9 Oct.37 Step 6: Pre-register (by 30 Nov 2008) There is lots of work involved in registering.ppt October 2007 © Rolls-Royce Plc . the EINECs number. SVHCs etc.  Set up an email address just to deal with the information from pre-registration.

vPvBs and PBTs (these could become SVHCs on the ‘candidate list’. Are any of these substances ‘strategically important?’  Would you have unhappy customers if you changed?  IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc . and then added to Annex 14).38 Step 7: SVHCs in PREPARATIONS Cross reference your substance inventories to your COSHH database / MSDS information looking for CMRs.

ppt October 2007 © Rolls-Royce Plc . Article 33).  IMF REACH Seminar Rolls-Royce presentation 9 Oct.1% weight by weight in YOUR product.39 Step 8: SVHCs in Articles You may buy articles and incorporate them in your product and you might make articles: Both could have SVHCs. You need to know HOW MUCH of WHICH SVHC is in each article you buy…  Only then can you work out if what you sell has > 0.  Then you have to NOTIFY the agency and customers (Articles 7(2).

 Your suppliers may soon be placing requirements on you! (Trichloroethylene…!)  IMF REACH Seminar Rolls-Royce presentation 9 Oct. even below 1 tonne (but not yet!)  Check whether you REALLY NEED to use the potential SVHC substance.ppt October 2007 © Rolls-Royce Plc .40 Step 9: Planning for Authorisation vPvBs and PBTs with wide dispersive use will probably be subject to authorization first and MAY need registering.  REACH will change cost/benefit arguments.

41 Step 9: Planning for Authorisation  Monitor Annex 14 and the Candidate list for the substances you use.ppt . Start looking into alternatives (Align R&D programs).  Get planning for it now! October 2007 © Rolls-Royce Plc IMF REACH Seminar Rolls-Royce presentation 9 Oct.  Where you have identified that you will be unable to easily move away from using a candidate list / Annex 14 substance.  Authorization will start circa mid 2009.     Contact others in your industry in the same boat. Find out the supplier’s plans for Authorization. Talk to any industrial customers about the issue.

 If you supply to the aviation industry in the UK / EU expect to see contract changes. requests for information and sector specific REACH workshops as we get organised for REACH.  A mass of information needs to flow up and down supply chains for REACH.  We are collaborating and intend to help our industry and our supply chain deal with REACH as cost-effectively as possible. within the company and within the supply chain. IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt October 2007 © Rolls-Royce Plc . in a fairly short time frame.42 In Summary  There is loads to do.

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