He warns that the SVHC list is rapidly increasing with more and more substances that are essential to provide maintenance and repair within recognized and proven safety standards. Cadmium is just one example of a new addition to the Reach list of substances of very high concern.
“Why should EU airlines and their maintenance, repair and overhaul organizations be required to obtain Reach authorization if it is the only means to comply with EASA's stringent aviation safety requirements,” De Vroey says.
AEA's question is valid. Yet, as Wunderlich stresses, “it is a situation we are actually facing for chromium trioxide and hexavalent chromium compounds.” These substances are crucial for maintenance and overhaul, and for manufacturing activities. Hexavalent chromium for example is widely used for hard-chrome plating in landing gears, engines and other components. There is no comprehensive substitute.
The authorization process for SVHCs is complex and without precedents. Due to comprehensive data and analysis requests, approval costs have been estimated at up to €5 million ($6.85 million) per substance and per use. In addition, the ECHA can refuse to grant authorizations. And, it can take 35-53 months for rulings on applications. This is a “completely unrealistic” timeline, AEA writes in its position paper on the EC proposal to add chromates to Reach Annex XIV.
Although significant research to identify suitable replacements for these materials has been underway by aircraft manufacturers, their suppliers and customers, no drop-in alternatives exist today or should be expected for a majority of aerospace uses in the near future. Many alternatives have been tested, but have not passed the performance requirements. Even if, in the near future, alternative solutions become available for new airplanes, legacy aircraft will need to be supported for another 40 years.
The industry has addressed the needs of the aerospace sector and its safety requirements regarding these substances with the ECHA, but thus far with no success. A high-level meeting between EASA and ECHA officials was scheduled for the end of January in the EASA offices in Cologne, Germany.
If EU member states do not withdraw the chromate proposal, thousands of jobs within the aerospace sector could be lost. “Airlines will likely bring their aircraft, engines and components to maintenance shops in non-EU countries, such as Turkey and Egypt, which are not confronted with the burden of Reach,” Wunderlich asserts, revealing that the majority of the parts that Lufthansa Technik maintains or repairs in its Hamburg facility are affected by the Reach legislation.