How should I approach REACH, CM, etc. as a job shop?

[Tyler]

I work for a very small job shop in the aerospace industry. Lately we have seen an increasing number of requests for REACH, CM, etc. declarations. I need help determining how best to manage compliance to these regulations.

As a job shop, we don't do any of the design ourselves. In a world that is fair, I would expect the designers to manage the compliance of their products, but that is not reality. Instead, we are tasked with trying to determine the chemical makeup of their products; a task I do not feel qualified for. To the best of my knowledge, the only area of concern with the products we manufacture is the special processes used (e.g., chem treat, passivation, anodize, paint, etc.). However, it is very difficult (if not impossible) for me to determine the compliance of our products for the following reasons.

• All outside processing is outsourced. We don't buy the specs for the special processes we have performed so I don't know what chemicals are used in the process.
• Since I have a very limited knowledge of these processes, I have no way of knowing if the process renders the product non-compliant with regulations. For example, we have a lot of products chem treated with hexavalent chromium, but I have no way of knowing if the hexavalent chromium is integrated into the material in excess of 0.1% of the weight of the product. My guess is it probably doesn't, but that's just a guess and I don't want to operate on assumptions.

I have tried asking our processors for this information but they have not been very helpful. They gave me information about the product(s) they use, but didn't tell me whether it contained an SVHC or integrated an SVHC into the product.

As a small job shop with limited resources, how would you advise we approach compliance, especially considering the lack of help from our suppliers. Are there resources out there that provide compliance information on common materials and special processes?

 

[greatwhitebuffalo]

Can you "flow down" those requirements to the external vendors by stating the processes must be compliant to the required regulation when you generate the PO? We handle it that way and request that the certification states compliancy.

 

[Tyler]

Can you "flow down" those requirements to the external vendors by stating the processes must be compliant to the required regulation when you generate the PO?

Not always. Sometimes we get these requests after the products have already been purchased. Only a few customers have specified that products must be REACH compliant on their contracts.

Even if I flowed down these requirements, I am not confident that I would get honest answers from my suppliers. It is surprising that so many of our processors seem to have no compliance programs in place. They are all NADCAP approved processors too.

 

[Ninja]

Been there...we charged for REACH declarations and sent the part/material out for testing (fee was testing cost plus).
Whether or not your resources are limited, flowing the cost of compliance to your customer makes it a wash for you...it's just another product you sell, price accordingly.
Never once had a customer push back... HTH

It's best if you speak real time with the compliance officer on the customer end first...that way there is no surprise when you say "you want a cert for a $2MM assembly, so we have to build another one just for testing...that will cost $2.5MM with shipping, testing fees and insurance."
...then ask them what they propose as a functional balance.

 

[Tagin]

There are companies (e.g., Assent Compliance, Greensoft) which provide the service of doing the compliance legwork: chasing down vendors for declarations, maintaining a database of this information, combining that data into something you can use for a declaration to a customer and so on. But they are not cheap services, and if your vendors are unresponsive to you, then hiring an external company won't help anyway.

The chemical analysis route makes sense, as long as you can reliably get your vendors to agree that they will not change any of the chemicals or materials used in the product you analyze. From the sound of it, its not clear if they would tell you if they changed any of the materials from batch to batch.

 

[Tyler]

Been there...we charged for REACH declarations and sent the part/material out for testing (fee was testing cost plus).

I like that. However, it would suck if we promised our customer a REACH compliant product only to discover after testing that it is not compliant. Seems like you would need to know ahead of time whether it is compliant.

The chemical analysis route makes sense, as long as you can reliably get your vendors to agree that they will not change any of the chemicals or materials used in the product you analyze. From the sound of it, its not clear if they would tell you if they changed any of the materials from batch to batch.

I do not think my suppliers would notify me of changes to chemicals used in their processes. As I said in my original post, we are a small aerospace manufacturer so most of our business is with other small aerospace companies.

I feel like the lower tiers of the aerospace supply chain tend to fly under the radar (no pun intended). So far, no one seems to be taking these regulations very seriously. Perhaps it is because the focus has been mainly on the first and second tier suppliers? Either way, these requirements now seem to be landing (again no pun intended) at the lower levels of the supply chain.

On a somewhat separate note, what do you do if you discover something is not REACH compliant? As it stands, I know that some chem treated parts are not REACH compliant; they deposit a small amount of hexavalent chromium onto the product. However, I found this communication on the use of hexavalent chromium in aerospace. The following excerpt is taken directly from that communication.

"There are several upstream applications for Authorisation that cover generic uses of chromium trioxide, as well as for specific aerospace and defence uses of chromium trioxide and other chromates. These applications were completed by the following consortia or other applicants (click link for additional information) to allow use of chromates by downstream users."

I highlighted in bold the part that stuck out to me. It sounds like even though chem treated products aren't REACH compliant, they are covered by an already existing authorization. Does that sound right? Is that how REACH works? Can you benefit from someone else's authorization? If so, do I need to reference the authorization for my customer? Or do I just need to declare the SVHC and let them figure it out?

 

[optomist1]

I urge you to seek out and complete courses on each...I recently completed several courses....they are worth the time and effort...as these topics are not necessarily simple...

Cheers Optomist1

 

[Tagin]

I highlighted in bold the part that stuck out to me. It sounds like even though chem treated products aren't REACH compliant, they are covered by an already existing authorization. Does that sound right? Is that how REACH works? Can you benefit from someone else's authorization? If so, do I need to reference the authorization for my customer? Or do I just need to declare the SVHC and let them figure it out?

On the page following that quote, it states a number of conditions that have to be met to continue using that chemical. So, it sounds like if you meet those conditions that chemical can be used in aerospace products. Whether or not your customer will accept a chemical covered by an upstream authorization is dependent on the customer. I'm not in aerospace so I'm not familiar with what difficulties that could present for your customer.

This "spec creep", as we call it in our company, is a problem: products that were designed years ago by the customer are suddenly now being given a requirement to meet all these compliance specs - ROHS, REACH, POP, BPR, CA PROP65, etc. If we can't get a compliance declaration from upstream, we just inform the customer. It was wishful thinking, at best, for them to assume such product would be compliant, and we as much tell them that.

 

[Ninja]

I like that. However, it would suck if we promised our customer a REACH compliant product only to discover after testing that it is not compliant.

FWIW, it's easy to maintain REACH compliance in my experience...as long as you don't intentionally add stuff that crosses the line, and perhaps spot test areas of high risk.
We made material out of a starting powder...we had the incoming powder tested for Pb upon receipt...then didn't intentionally add non-compliant stuff...never came close to failing on the final product.

Again, work together with your customer, the solution is likely easier than you currently fear.

 

[Tyler]

I urge you to seek out and complete courses on each...I recently completed several courses....they are worth the time and effort...as these topics are not necessarily simple...

Do you have any suggestions?

FWIW, it's easy to maintain REACH compliance in my experience...as long as you don't intentionally add stuff that crosses the line, and perhaps spot test areas of high risk.

The only problem is we are a build to print manufacturer; we don't control the designs. To be fully REACH compliant I need to know the chemicals used in the special processes and/or materials specified. I can't do that without the help of my vendors. What further complicates things is figuring out how to determine if something exceeds the 0.1% weight limit for SVHCs. For example, I don't know how much hexavalent chromium is deposited onto our parts when they are chem treated. Right now I am erring on the side of caution and just telling our vendors when an SVHC is present.

I think for now, my approach will be to request safety data sheets from my vendors, screen the chemicals by CAS number, and report any SVHCs that are used in raw materials or SVHCs that are added in coating/finishing processes. Thoughts?