iaeg · 1. introduction 2. aerospace & defense industry challenges 3. iaeg approach 4. pilot...

IAEG Material Declaration Pilot

Training

June 2, 2014 June 11, 2014

Agenda

1. Introduction 2. Aerospace & Defense Industry Challenges 3. IAEG Approach 4. Pilot Phase 5. Form Completion 6. Form Submission 7. Summary

Slide 2 IAEG Supplier Declaration Training - Pilot

Introduction About IAEG

IAEG formally incorporated in June 2011

• New trade association formed by major Aerospace and Defense companies.

• Focused on the multitude of global laws and regulations impacting health and the environment

• Formed to address the complexity and variability of these requirements and associated burden and cost for the Aerospace and Defense industry

http://www.iaeg.com/


http://www.iaeg.com/

1. Develop Understanding of Environmental Requirements Facing the World’s Supply Chain

2. Seek Harmonized Aerospace and Defense Industry Response

3. Foster Common Approach and Expectations for Supply Chain

4. Promote Development of Voluntary Consensus Standards

5. Create Forum for Dialog on Industry Approaches for Implementation of Environmental Requirements

Purpose of IAEG

1. Industry Standard for Reporting of Chemical Content

2. Priority Chemicals for Industry-Wide Focused Efforts

3. Green House Gases 4. Standard Environmental

Vocabulary 5. Authorization of

Substances for REACh 6. Supply Chain Maturity

Assessment

Global Aerospace & Defense Industry Common Approach 4

IAEG Work Groups

IAEG™ Members UPDATE

Airbus BAE Systems

Boeing Bombardier Aerospace

Dassault Aviation Dassault Falcon Jet

DNV Business Assurance EADS

Eaton Corp Embraer

GE Aviation Goodrich Corporation

Gulfstream Honeywell

Inventec Performance Chemicals

Israel Aerospace Industries Lockheed Martin

National Quality Assurance Northrop Grumman Phitek Systems Ltd.

Raytheon Rolls-Royce

SAFRAN Spirit AeroSystems

Thales United Technologies

Corporation Zodiac Aerospace

IAEG Supplier Declaration Training - Pilot

Aerospace Industry Challenges

Slide 6

• Increasing level of requirements all over the world: – Regulatory obligations for chemicals, chemicals in products

• Restrictions on asbestos, ozone-depleting substances, hexavalent chromium, mercury;

• Consumer / environmental protection, end-of-life / disposal restrictions, … – Related support costs

• Compliance management systems, product sustainability efforts…. • Related risks increasing for activities, products and services

– Comply with current requirements / anticipate and prepare for emerging requirements

• Bans / restrictions of some “high-risk” substances • Substance reporting requirements

• Need to leverage the best practices across all industries • Chemicals, electronics, automotive

IAEG Supplier Declaration Training - Pilot

Key Regulatory Drivers

• European REACH Regulation – Restricts uses and imposed reporting requirements for

certain hazardous substances, including in hardware product (“articles”)

– Cause of “material obsolescence” – decrease in critical material availability

• Restriction of Hazardous Substance (“RoHS”) – European and various other country “RoHS” regulations

limit material content of electronic/ electrical equipment – Limitations may have adverse impacts on article product

reliability (e.g. “lead-free” solder)


A & D Industry Challenges IAEG Contribution

• Develop the A&D industry process to obtain information on the chemical content of hardware products (also called “articles”) – Covers both the content of hardware products and critical substances used to

make them.

• Important to anticipate and manage emerging and existing regulatory and material obsolescence risks, while simultaneously meeting increasing aerospace and defense customer expectations.

• The process consists of information exchange through the A&D supply chain using a standardized template and list of chemical substances-of-interest.

Consistency of approach and reporting for your all aerospace and defense customers…We are doing this.


For countries/regions where industry manufacturers or

services products.

In Scope*

Criteria for inclusion in the IAEG RSL 2013 Scope: EU / USA / China / Canada / Brasil

ST1 old view for the RSL:N Not retained Substances targeted for their Hazardous properties but with no short/middle term visibility of actual regulatory requirements applying to AS&D industriesR Regulated Compliance Management Need - Substances having regulatory requirements appliquable currently to the AS&D industryI For Information, Anticipation Design Management Need - Substances having regulatory requirements not yet appliquable to the AS&D industry and/or foreseen to be regulated for this sector.

New LevelsL1 RestrictedL2 Declarable Compliance Management Need - Declaration requirements appliquable currently to the AS&D industryL3 For Anticipation Design Management Need - Substances having regulatory requirements not yet appliquable to the AS&D industry and/or foreseen to be regulated for this sector.

Geo AreaHazardous substances criteria+ Regulatory Ref

Condition for substance inclusion

Estimated number of Substances

ST1 viewfor the RSL

Expected priority Level

RationaleOther way to check compliance

(Y/N)Which one ?

Comments / Clarification

Brazil

No specific regulations or criteria have been retained

# # N

Brazil would adopt REACH as the regulation

controlling substances in Products

# Decision endorsed by Embraer (Tatiana Cortez)

Canada

Canada Virtual Elimination List (CEPA 1999 - Section 65)

Part of the Virtual Elimination Substances List

Currently around 2 families

(HBCDDs & PFOS)

R L1

Any substance on this list would be subject to regulations that will prohibit its use on its own, in mixtures, or sometimes in articles

SDS can be used to comply to requirements regarding

substance use on its own or in preparations.

For articles there is no current standard way

The Virtual Elimination Substances list is similar to REACh Annex 14 + Annex17.

Canada

Canada Toxic Substances List (CEPA 1999 - schedule 1)

- Subst part of the Toxic Substances List, Schedule 1;- Only subst with restrictions in articles

about 20 chems

R L1*

Toxic substances list is similar to the candidate list and Schedule 1 similar to priority candidates. -> For a discrimination of L1, L2 or L3 critieria, it shall be checked on a case by case with the related specific regulation

Canada

Canada Toxic Substances List (CEPA 1999 - schedule 1)

- Other Subst part of the Toxic Substances List, Schedule 1;

less than 172 chemicals or

chemical families

I L1*

Some of the substances on the TSL may have specific regulations prohibiting their use. In some cases prohibitions apply to process chemicals that may be used by our suppliers (ex PFOS) - we would need the supplier to disclose that use if it impacts the supply of the article to us

Curently no requirement of declaration to

downstream users.However some of the

substances on the TSL may have specific regulations

prohibiting their use including in articles

SDS can be used to comply to requirements regarding

substance use on its own or in preparations.

For articles there is no current standard way; in this case we

would need a declaration from article supplier that it does not

incorporate the substance.The RSL process is a good way

Document Decision.

MS Excel Spreadsheet

Regulated Substance List.

Used in Industry

AD DSL

Priority: L1, L2 or L3

Prioritized AD DSL

Via MS Access

Database

Company Use Lists

. . .

China Regs: EHS & Prod. Chem.

EU Regs: EHS & Prod. Chem.

US Regs: EHS & Prod. Chem.

. . .

Europe

Asia

Americas

Document Decision.

*Product and Key Process Regulations

IAEG Approach AD-DSL Overview


Three IAEG Priority Levels

Level “L” Classification

Examples of Regulatory Actions

L1 = Restricted-Subject to limitation • An existing, “in-force” regulation in

force with aerospace in scope that prohibits (e.g.,“sunset date”) certain chemical substances in article products

-> Ozone-depleting substances, asbestos, mercury compounds…

L2 = Declarable • A regulation is in force with aerospace

in scope and/or requires the disclosure of its presence in articles

-> REACh “Communication” requirement (Art. 33), EU Biocide Directive

L3 = Watch List • Substances that are regulated and

have the potential be banned or restricted or to require disclosure.

-> Radioactive substances…


IAEG Approach Template Definition

Data Elements

• Supplier Information • Product Part Information • Substance Information

AD-DSL

• CAS Number- and other reference information • Substance Name and Family • Regulatory Information- Reporting/Restrictions

Format with Logic

• Instructions • Connection of the Data Elements and AD-DSL • Reporting form with logic for process and data integrity

Multiple data elements associated with each section of the form


Purpose of the IAEG Pilot

• Test out the new template – Gain feedback on the process, form and AD-DSL

• E.g., Ease of use

– Make identified improvements prior to full deployment in the supply chain

Deliverables • Completed Template • Response to Survey

https://www.surveymonkey.com/s/D35HZXY


https://www.surveymonkey.com/s/3G3ZS3D


Pilot Phase - What’s In it For You?

• Benefits of your participation: – Access to personalized support and training before

standard deployment – Have an opportunity to share your thoughts and

concerns – Shape the standard and process to best meet the needs

of the industry – Anticipation of next set of customer requirements – Response recognized and accepted by A&D Industry

Substance information attributable to any one company will not be shared and will only be known to the submitter and the POC at the receiving company.

The receiving company POC will be responsible for summarizing your provided information for IAEG use to enhance the information exchange process

• Under IAEG’s proposed standard process, buyers and suppliers must have clear understanding on the appropriate use of the info contained in the Material Declarations exchanged – The IAEG draft standard includes ground rules on that topic (see

Terms of Use Agreement text)

• Our assumption is the Agreement will be part of aerospace supply chain contracts through incorporation of the standard by reference

• The Agreement for the Pilot is available for review on the IAEG website by accessing the “Supplier Portal” link.

Terms of Use Agreement


• Excel based format with logic and data validation • Separate tabs

– Terms of Use – Instructions and definitions – Supplier Data – Part Data – Substance Data – Product Family Information

• Please contact the member company that invited you with any questions.

Form Overview


Completing Responses: Part A

• Section A consists of basic supplier and point of contact information:


If you are unsure of what response to give, refer to 16 Slide 17 IAEG Supplier Declaration Training - Pilot

Completing Responses: Part A, continued

• To make adjustments or corrections to cells, simply click or double-click on the cell(s) and begin typing or pasting your information. Hit enter or click out of the cell to complete the response.

First click on incorrect cell. Then type in the correct information

If you are unsure of what response to give, refer to slide 16

Completing Responses: Part A


Completing Responses: Part B

• Section B consists of Part/Product information:


• Filling in your information is similar to the process for part A: simply click on the cell you want to fill out and begin typing.

• Some cells will have drop down menus. Click on the gray arrow to see the response options.

• Once you’ve finished, simply hit enter or just click on the next cell you want to work on.

• See the next few slides for examples.


If you are unsure of what response to give, refer to slide 19 Slide 20

• Tab B consists of two types of answer fields. Manual input responses, shown below (type in your responses) and drop down menus where you choose your response (shown on next slide).


If you are unsure of what response to give, refer to slide 19 Slide 21 IAEG Supplier Declaration Training - Pilot

Completing Responses: Part B Some cells will have drop down menus. Click on the gray

arrow to see the response options then click on the appropriate response to complete your answer.

Click on arrow to see possible responses.

Chosen response will appear in cell.


Cells with red arrows in the top right corner have extra information, directions, or other language options. Roll your mouse cursor over them to see what each says.



Completing Responses: Part C • Section C consists of Substance information:

SUBSTANCES USED IN THE MANUFACTURING PROCESSES AS WELL AS SHIPPABLE PRODUCT CONTENT ARE COVERED


Completing Responses: Part C Inputting responses is virtually the same process as in Part B.


Completing Responses: Part C There are some sections which are auto-filled as well as

sections with dropdown menus.


Product Family Process

Creation of Product Families

Declarable Substance

Profiles

Define Product Families

Assign parts to product

families

Collect Declarable

Substance Data on Product

Family Members

Establish Declarable

Substance Profile for a Product

Family

Report Findings

Product Family is a group of products that have definable characteristics which are expected to result in consistent material compositions. Products associated with a product family are called Product Family Members. A properly defined product family will have products that contain the same materials, including Declarable Substances. The material declaration data for a given product should closely track with other members of the Product Family.

Supplier Survey Questions

• PROCESS (Y or N, unless otherwise indicated) – The survey asks several questions regarding the process of obtaining the

declaration from suppliers.

• TEMPLATE (Y or N, unless otherwise indicated) – Use of the template will be critical going forward. We need your input as to

the ease of use of the template and any concerns you may have.

No export control, proprietary information- https://www.surveymonkey.com/s/D35HZXY Slide 28


Survey Results

• Measurement – Response to survey questions is measured on a

scale of 1-4, with 1 indicating least agreement, and 4 indicating most agreement.

– Responses below 3, require clarification comment/feedback.

• What will be done with the information? – Your feedback will help improve the documents and

process so the industry has a robust process that is understandable and common for our supply chain.


Schedule

• Conduct Training – Webinar 1 02 Jun 2014 – Webinar 2 11 Jun 2014 – Member Follow-up with Supplier re: training 25 Jun 2014

• Conduct Pilot Jun 2014 – 13 Aug 2014 – Suppliers complete template & survey – Member company review/validate supplier template – Member follow with supplier re: feedback on process – Member company completes survey

• Analyze Results 14 Aug 2014 - 27 Aug 2014 – IAEG review/analyze survey results

6/2/2014 30

Summary

• WIFM • Expectations

– Template Completion – Survey Completion – Review of Terms of Use

Deliverables • Completed Template • Response to Survey

https://www.surveymonkey.com/s/D35HZXY Slide 31 IAEG Supplier Declaration Training - Pilot

https://www.surveymonkey.com/s/3G3ZS3D


iaeg · 1. introduction 2. aerospace & defense industry challenges 3. iaeg approach 4. pilot...

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