July 31, 2015 by Olivia Tran

Many different chemicals are used in the aviation industry for a wide range of different uses, many crucial in maintaining aircraft and passenger safety. The substances used in each application have been developed based on years of experience, and are proven to be effective and reliable. Some of the substances used in such applications are, however, known to be hazardous to humans and the environment.

REACH (Registration, Evaluation and Authorisation of CHemicals) was implemented in the EU in 2007 with the aim of assessing all chemicals in the European market and to limit the use, production and importation of chemicals posing a significant risk to humans and the environment. REACH is viewed as a model for the reform of other international chemical regulations, such as the Toxic Substances Control Act in the U.S.

The main difficulties in implementing REACH for the aviation industry are the complexity of the supply chain for chemicals, and the availability of reliable substitutes. While the REACH regulation applies to manufacturers, importers and downstream users of the chemicals in the EU, the supply chain is global and intertwined with multiple layers. Importers and downstream users of chemicals in the EU thus may have to trace chemicals back to international manufacturers and producers. In addition, any new alternatives and substitutes will need to be as effective as the substance they are substituting, and this is difficult to demonstrate when the original substance has many years of efficacy and safety data behind it. Limited experience with new substances leads to perceived safety risks (among the industry and, potentially, passengers), slow uptake and a lack of innovation for suitable alternatives.

A number of chromate substances which are important to the aviation industry have been placed on the REACH authorisation list. These chemicals must be substituted with a different chemical or authorisation from the EU must be obtained for specific uses of the chemical before the deadline. The authorisation list and specific deadlines can be found here.

wca are experienced in all aspects of REACH registration, including data gap assessment, exposure and hazard assessment and modelling, risk characterisation and dossier preparation and submission. We have consulted with manufacturers, importers and downstream users and have worked with numerous consortia on preparing registrations for metals, greases and hydrocarbons. wca also have experience in socio-economic assessments and risk assessments for the authorisation and continued use of chemicals for trade associations and regulators.

If you would like to know more about our services and how we can help you manage your chemical safety and regulatory obligations, please do not hesitate to contact us.