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REACH Department of Defense Briefing

July 16, 2008

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Agenda

• How the automotive industry is addressing REACH

• REACH impacts for military equipment

• What can be done to protect DoD capabilities  

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EU Chemicals-in-Products Regulations All Substances

30,000+ Substances

REACH (2007)

Increasing Complexity, Cost and Level of Information Divulged

Pb Hg Cd Cr+6

ELV (2003)

PBB PBDE

RoHS (2006)

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International Material Data System (IMDS)

– Developed in 2000 in response to EU’s End of Life Vehicles Directive

– 130,000+ users, secure transfer of confidential chemical substance information for vehicular components

– Automotive industry may use IMDS to track and manage SVHCs, but will not solve all problems

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Other tools and processes are being developed

• AIAG has established a collaborative relationship with global REACH Task Force and trained 750 suppliers in Detroit -- http://reach.aiag.org

• Supplier risk management methodology (Plan, Assess, Handle,

Monitor, Document..) being established. Risk factors include– Small market

– Small supplier capacity

– Complex supply chain

– Foreign headquarters deciding REACH strategy

– Product contains SVHC

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REACH Impacts for DoD

• Same risks from automotive as for other industries

• Increased costs

• Decreased availability of parts and materials

• Product delivery delays

• Alternatives meet military specs?

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REACH Impacts for DoD (cont’d)

• OEMs are currently specifying materials and parts for 2012 products, may not be able to remove banned substances (SVHCs) in time

• Generally a 3-5 year lead time needed for design• Testing and qualifying for military specs may take longer in some

cases

• Preliminary list of SVHCs (16 proposed per ECHA released June 30, 2008) may affect following automotive applications

• Plasticizers• Semiconductor materials• Fire retardants• Chromium pigments and dyes• Metal surface treatments• Adhesive additives

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REACH Impacts for DoD (cont’d)

• Installations are not part of the EU, thus REACH-exempt if vehicles are shipped directly to bases

• However, purchases from off-site, within customs area of the EU (plus Norway, Iceland and Liechtenstein) are subject to REACH.

• This could affect service part availability for vehicle maintenance

• Joint venture and foreign military sales may have increased requirements due to importing/manufacturing in the EU

• ITAR – what information should not be disclosed to foreign entities?

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What Can be Done to Protect DoD Capabilities ?

• Work within framework of REACH’s provisions• Propose defense exemptions for all allied states, especially

those with installations• Coordinate comment on proposed SVHCs (Aug 15 deadline

for current list)• Coordinate authorization activities for military applications

• Collaborate with industry• Identify suppliers of critical substances which are at risk,

using a standardized tool or process. Identify alternative substances and suppliers and communicate with industry on how to replace• Ensure confidentiality for suppliers to protect military

secrets• Provide funding for processes, tools, trainings

• Provide training/education for DoD agencies

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Questions ?

AJ Guikemareach@aiag.orghttp://reach.aiag.org

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Supplemental Slide (1)

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Proposed SVHCs per ECHA• 4,4'-methylenedianiline

4,4'diaminodiphenylmethane • Bis(2-ethylhexyl) phthalate;

di-(2-ethylhexyl) phthalate; DEHP

• Anthracene, pure • Arsenic pentoxide; arsenic

oxide • Diarsenic trioxide; arsenic

trioxide • Triethyl arsenate• Hexabromocyclodecane

(HBCD)

• Bis(tributyltin)oxide (TBTO) • Cobalt dichloride • Lead hydrogen arsenate • Sodium dichromate, dihydrate • 1-(1,1-Dimetyletyl)-3,5-

dimetyl-2,4,6-trinitrobenzen• Dibutyl phthalate; DBP • Alkanes, C10-C13, chloro

(short-chain chlorinated paraffins) (SCCPs)

• Benzyl butyl phthalate BBP • Cyclododecane