Transcript Document

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.
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Energy
Marine
Defence
 A global business
 £24bn order book
 £6.6bn annual
sales
 £663m R&D
 36,000 employees
 7,600 engineers
 Supporting four
market sectors
Civil
Rolls-Royce today
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October 2007
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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
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What REACH means to Rolls-Royce
Rolls-Royce as an importer
 Alloys are preparations (bar, billet,
specialist metallic powders etc)
 Processing chemicals (drums of
liquid and powder preparations etc)
 Importing finished articles (with no
intended substance release)
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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).
 Contracts on non-EU suppliers will
have to change to obtain information
to complete registration.
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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
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What REACH means to Rolls-Royce
Rolls-Royce as a downstream user
 Check whether SVHCs are in products
following manufacture, at > 0.1% 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)
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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
restrictive… write own CSR
Too
vague… write own CSR
Two
suppliers, 2 different RMMs?
REACH
RMM ‘Library?’
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October 2007
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What REACH means to Rolls-Royce
Rolls-Royce as a user of substances of
very high concern (SVHC)
Using SVHCs within alloys,
within process chemicals – and
unable to change quickly to
alternatives (in some cases,
there may be no alternatives)
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October 2007
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What REACH means to Rolls-Royce
Rolls-Royce as a user of substances of
very high concern (SVHC)
Rolls-Royce specifiers, purchasers,
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.
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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.
Industry Response:
 STOP supplying to companies with open topped / lidded
degreasers from 2010.
 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- and use only as a last resort
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October 2007
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What REACH means to Rolls-Royce
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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Issues within the supply chain
Supply chain…
Issue…
Changing formulations
Could invalidate aircraft
safety certification
(European Aircraft Safety
Agency, EASA)
Need to find and prove
alternatives to satisfy
certification
requirements
Withdrawal of
formulation
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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Issues within the supply chain
Supply chain…
Lack of information
about substances in
formulations
Issue…
Unable to check that
formulation is being
used legally
Lack of information
about substances in
dried coatings /
adhesives etc.
Unable to meet legal
obligations to provide
information on SVHCs to
customers
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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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.
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October 2007
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Getting organised internally
 Workshops for key stakeholders
 Workshop for HS&E Practitioners, Purchasing,
Engineering, 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
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October 2007
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Managing the Issues:
Collaboration

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The Aerospace sector globally is now
working on several initiatives:
- ARTICLES interpretation
- Standard data to be collected from
suppliers for REACH
- Common guidelines for our sector(s)
- Supporting trade association / professional
institution workshops on REACH
- Sharing best practice across sectors

Working with DEFRA and HSE
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Practical Steps to Implementing REACH
– What have we got to do?
 REACH
requires different areas
(Purchasing, Engineering and
Design, Manufacturing operations
and HSE), to work together inside our
companies (easy for SMEs!).
 REACH will require new information
to be collected within companies,
and to be passed up and down
supply chains (NOT easy for SMEs!).
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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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.
 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.

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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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.ppt
October 2007
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Step 3: build an material inventory
Make a list of all the materials used by your
business, 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.ppt
October 2007
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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
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Step 3: build an material inventory
You will need to identify, for each Tradename /
specification / constituent inside the
preparation…
Is it hazardous? (CMR, PBT, 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.ppt
October 2007
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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 2005,2006,2007 and average it.
 This is where off-the-shelf REACH software could
really help…

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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Step 5: Decide what to pre-register
 If you are an importer of >1tonne or more,
you have to pre-register.
 If you MANUFACTURE SUBSTANCES you
have to pre-register.
 If the substance is strategically vital and
your supplier will not guarantee they will
pre-register / register, 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.ppt
October 2007
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Step 6: Pre-register (by 30 Nov 2008)
There is lots of work involved in registering.

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, the EINECs number, your
company details, SVHCs etc.
 Set up an email address just to deal with the
information from pre-registration.

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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Step 7: SVHCs in PREPARATIONS
Cross reference your substance
inventories to your COSHH database /
MSDS information looking for CMRs,
vPvBs and PBTs (these could become
SVHCs on the ‘candidate list’, and then
added to Annex 14).
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
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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 > 0.1% weight by weight in
YOUR product.
 Then you have to NOTIFY the agency
and customers (Articles 7(2), Article 33).

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
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Step 9: Planning for Authorisation
vPvBs and PBTs with wide dispersive use will
probably be subject to authorization first and
MAY need registering, even below 1 tonne (but
not yet!)
 Check whether you REALLY NEED to use the
potential SVHC substance.
 REACH will change cost/benefit arguments.
 Your suppliers may soon be placing
requirements on you! (Trichloroethylene…!)

IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
© Rolls-Royce Plc
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Step 9: Planning for Authorisation
 Monitor Annex 14 and the Candidate list for the
substances you use.
 Where you have identified that you will be unable to
easily move away from using a candidate list /
Annex 14 substance,




Contact others in your industry in the same boat.
Talk to any industrial customers about the issue.
Find out the supplier’s plans for Authorization.
Start looking into alternatives (Align R&D programs).
 Authorization will start circa mid 2009.
 Get planning for it now!
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
© Rolls-Royce Plc
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In Summary
 There is loads to do, within the company and
within the supply chain, in a fairly short time
frame.
 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.
 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.
IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt
October 2007
© Rolls-Royce Plc