IMF REACH Seminar Rolls-Royce Presentation 9 Oct07

© 2007 Rolls-Royce plcThe 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.

REACH, Rolls-Royce & the Supply Chain

Cathy Phillips, HS&E Materials

Rolls-Royce Group

October 2007

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IMF REACH Seminar Rolls-Royce presentation 9 Oct.ppt

Rolls-Royce today

A global business £24bn order book£6.6bn annual

sales£663m R&D36,000 employees 7,600 engineersSupporting four

market sectors

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What REACH means to Rolls-RoyceIssues we foresee within the supply chainWhat Rolls-Royce is doing to prepare for

implementation – within the companyManaging the supply chain issuesSummary

REACH, Rolls-Royce & the Supply Chain

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Rolls-Royce as an importer

What REACH means to Rolls-Royce

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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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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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


Rolls-Royce as a downstream user

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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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Using the new extended safety data

sheets

Legal requirement to use the RMM

specifiedToo restrictive… write own CSR

Too vague… write own CSR

Two suppliers, 2 different RMMs?

REACH RMM ‘Library?’



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Using SVHCs within alloys,

within process chemicals – and

unable to change quickly to

alternatives (in some cases,

there may be no alternatives)


Rolls-Royce as a user of substances of very high concern (SVHC)

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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.


Rolls-Royce as a user of substances of very high concern (SVHC)

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What REACH means to Rolls-RoyceExample: TrichloroethyleneTrichloroethylene 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 releaseCollaboration on socioeconomic analysis for

AuthorisationSignificant 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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Adobe Acrobat 7.0 Document

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Issues within the supply chain

Supply chain… Issue…Changing formulations Could invalidate aircraft

safety certification (European Aircraft

Safety Agency, EASA)Withdrawal of formulation

Need to find and prove alternatives to satisfy

certification requirements

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Issues within the supply chain

Supply chain… Issue…

Lack of information about substances in

formulations

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

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Issues within the supply chainSupply 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 / Failure to check that the

substance is being registered for their use

Substance could be lost due to supplier failure

to engage in the REACH registration process for

their use of a substance.

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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

Getting organised internally

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Managing the Issues: Collaboration 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!).

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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.

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Step 2: Get resource and planStart developing the action planFind 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

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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

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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?

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Step 3: build an material inventoryYou 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?)

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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…

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Step 5: Decide what to pre-registerIf 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…

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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.

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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?

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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).

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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…!)

Step 9: Planning for Authorisation

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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!

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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.

In Summary

Documents

IMF REACH Seminar Rolls-Royce Presentation 9 Oct07