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/
Slide 3 IAEG Supplier Declaration Training - Pilot
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)
Slide 7 IAEG Supplier Declaration Training - Pilot
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.
Slide 8 IAEG Supplier Declaration Training - Pilot
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
Slide 9 IAEG Supplier Declaration Training - Pilot
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…
Slide 10 IAEG Supplier Declaration Training - Pilot
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
Slide 11 IAEG Supplier Declaration Training - Pilot
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
Slide 12 IAEG Supplier Declaration Training - Pilot
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
Slide 14 IAEG Supplier Declaration Training - Pilot
• 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
Slide 15 IAEG Supplier Declaration Training - Pilot
Completing Responses: Part A
• Section A consists of basic supplier and point of contact information:
Slide 16 IAEG Supplier Declaration Training - Pilot
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
Slide 18 IAEG Supplier Declaration Training - Pilot
Completing Responses: Part B
• Section B consists of Part/Product information:
Slide 19 IAEG Supplier Declaration Training - Pilot
• 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.
Completing Responses: Part B
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).
Completing Responses: Part B
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.
If you are unsure of what response to give, refer to slide 19 Slide 22 IAEG Supplier Declaration Training - Pilot
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 B
If you are unsure of what response to give, refer to slide 19 Slide 23 IAEG Supplier Declaration Training - Pilot
Completing Responses: Part C • Section C consists of Substance information:
SUBSTANCES USED IN THE MANUFACTURING PROCESSES AS WELL AS SHIPPABLE PRODUCT CONTENT ARE COVERED
Slide 24 IAEG Supplier Declaration Training - Pilot
Completing Responses: Part C Inputting responses is virtually the same process as in Part B.
If you are unsure of what response to give, refer to slide 24 Slide 25 IAEG Supplier Declaration Training - Pilot
Completing Responses: Part C There are some sections which are auto-filled as well as
sections with dropdown menus.
If you are unsure of what response to give, refer to slide 24 Slide 26 IAEG Supplier Declaration Training - Pilot
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.
Slide 29 IAEG Supplier Declaration Training - Pilot
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