By Stephanie R. Laboo | Linda M. Thomas
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Global chemical regulations have entered a new era requiring more transparency and greater data from not only manufacturers and importers but also downstream users for both civil and defense operations.
Most product sectors do not have sufficient information systems in place to retrieve and store chemical data that is needed to meet current and future regulatory requirements and customer inquiries. To continue transitioning from a reactive regulatory strategy to a proactive strategy will require significant investment in securing agreements with the supply chain, investment in capital for the proper information technology infrastructure, investment in documenting proper configuration management protocols (drawing callouts), and investment in documenting processes that ensure targeted chemicals are not introduced into new products.
Adopting a proactive strategy can create long-term value for Boeing.
In this paper, we are focusing on global environmental legislative agencies, for example the U.S. Environmental Protection Agency (EPA), whose mission is to “protect human health and the environment” through developing and enforcing environmental regulations, and helping its stakeholders understand these requirements. Another important regulatory agency of interest to Boeing is the European Chemical Agency (ECHA), whose mission is to implement the European Union’s chemicals legislation, which “helps companies to comply with the legislation, advances the safe use of chemicals, provides information on chemicals, and addresses chemicals of concern.”
Over the last decade, these regulator agencies, along with agencies in many other countries, are passing legislation and regulations requiring companies to know the chemical composition of their products that are supplied in commerce.
Of the hundreds of environmental regulations being adopted throughout the world, new rules on chemicals, substances and materials are the most abundant. Although most of these regulations typically target the uses for everyday household consumer goods, aerospace manufacturing, including supplier operations and also in service fleet operations, could be impacted. Simply stating that supply chain complexities, unawareness to materials purchased by buyers and cost burdens is no longer being accepted by regulatory agencies as a reason for exemptions.
Figure 3 illustrates several proposed and released chemical regulations dating back to 2004 that have had an impact on the manufacture, operations and maintenance of aerospace products.
As an example, the Canadian EPA, U.S. EPA, and the Stockholm Convention have proposed regulations phasing out the manufacturing, import and use of specific brominated flame retardants (for example decabromodiphenyl ether or decaBDE). These flame retardants have been used in plastics, sidewall panels, carpets, curtains and other textiles in the interior of the airplane, as well as in electrical connectors and components.
The Boeing Company spent significant amounts of money in labor hours searching for all of the uses of these chemicals in Boeing-designed parts, communicating with the supply chain to ensure they know their uses must be phased out, conducting research and development to find alternative products, certifying these new products, preparing specification updates, and at times creating configuration control of modified parts and assemblies.
For Boeing to contain the costs of mitigating chemical and material obsolescence, the engineering community must be more strategic about selecting materials and products when designing aircraft products. In addition, the company must become more aware of the chemical constituents used in Boeing-designed and supplier-designed components. And so, we explore ideas to make more progressive material choices to alleviate downstream regulatory burdens.
Using materials and processes already qualified and certified for airworthiness and also being quite familiar with their properties helps the company reduce costs and increases quality. Using familiar processes also allows for better information to be used to predict maintenance cycles for customers and determine reparability. Although these are all benefits, many of these familiar products utilize compounds that are being phased out by environmental agencies all around the world. Many of these processes do have an alternatives process that has been qualified for years, yet old technologies are called out in designs or allowed as options. Examples of this are shown in Table 1.
Environmental trends tend to show that once one country or region starts to ban or restrict a compound, many countries follow suit with similar or identical regulations. Quickly removing the use of targeted materials from current designs will alleviate the need to spend money on regulatory mitigation in the future when additional countries and regions follow suit and enact similar regulations.
To effectively mitigate chemical risks, chemical compounds are identified in the materials and processes specifications that are used on Boeing-designed parts. These processes and products are then searched in a database to find out which programs and functions have drawings that are impacted if the compound is taken out of commerce or restricted in any way.
However, material and process specification searches can be challenging because of nonstandard data input methods. Even more difficult are direct product callouts. Companies continually buy out or merge with other companies and change the name of products, or products are no longer manufactured for various reasons and need to be replaced. Finding every drawing using a specific product is imperative to ensure the right callouts are established and production is not disrupted.
As one example, Henkel AG & Company, a manufacturer of numerous adhesives, sealants and chemical finishes, has acquired product lines or entire companies such as Loctite (1997) and the adhesives and electronic materials businesses from AkzoNobel (2008). Starting in 2012, Henkel launched a rebranding initiative to consolidate the names of all the products they acquired. Although product compositions or formulations did not change, callouts and specifications on drawings that utilize these materials needed to be searched and updated to reflect the new product name.
Traditionally, Boeing has relied on upstream suppliers of parts and materials to be compliant with government environmental regulations. The assumption when parts and materials are received is they are environmentally compliant with local regulations and are installed on Boeing products. A slight shift in this approach has occurred within the last five to six years because of regulations such as European Union’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), legislated through the European Chemical Agency, where countries want to know the final chemical composition of products entering their country.
Companies can no longer be unaware of the manufacturing processes of upstream suppliers and must be actively knowledgeable of product compositions that come in contact with the general public. This information goes beyond high-level chemical safety data found in safety data sheets. Some suppliers are either reluctant to provide this information or at times simply do not have the information because of the depth of their own supply chain.
How can additional chemical information be obtained and retained effectively without compromising confident business information? How can we achieve transparency in the supply chain? Currently, teams throughout the company are working with an outside consortium to help answer this question.
The International Aerospace Environmental Group is a trade association formed by major aerospace companies around the globe that focuses on global environmental laws and regulations impacting the civil and defense industry. In collaboration, the group developed the list of 2,000 chemicals used by the industry that are targeted for phase-outs or bans by environmental agencies all over the world. This list is periodically updated in an effort to stay ahead of developing regulations and legislations.
Because it is a targeted list, it can be used to negotiate transparency with the supply chain to disclose specific chemical constituents without requesting full disclosure. In addition to supply chain usage, the list can be used to ensure alternative technologies are not being researched and developed with chemicals targeted for ban or phase-out in the future.
Stephanie R. LaBoo is a chemical engineer and manages chemical and materials risk for aviation safety and regulatory affairs in Boeing Commercial Airplanes.
Linda M. Thomas is a Boeing Technical Fellow for chemical risk assessment, consulting on a variety of commercial derivative and military programs.