Reminder – ECHA Consultation – Dechlorane Plus
30 November 2021: As notified in September (below), ERA received information regarding a proposed restriction from ECHA relating to the use of Dechlorane Plus (DP) in Europe that could potentially impact engine maintenance. In summary:
- The REACH Restriction Report for Dechlorane Plus currently proposes a broad Restriction for the substance without derogations.
- The possibility for an aircraft derogation was explored by the dossier submitted but has not been pursued further at this stage due to a lack of information regarding the criticality of DP in aerospace products.
- The AeroSpace and Defence Industries Association of Europe (ASD) has now provided comments to support a derogation. Amongst several points, the comments highlight that DP is used in formulations used in the EEA for both production and repair of aerospace and defence (A&D) products. It is believed that multiple uses may be relevant to airlines (formulations containing the substance are uses, for example, in the repair of engines in the EEA) and that there may be significant economic impacts associated if the Restriction is implemented as planned.
For the above reasons, IAEG REACH Work Group has prepared a presentation  for ERA (in addition to the downloads already made available) requesting airline stakeholders to:
- Consider the criticality of their (and their suppliers/sub-tiers) use of DP-containing formulations.
- Consider submitting comments to ECHA’s public consultation on Restriction Report; and
- If detailed comments cannot be compiled and approved in the short timeframe, consider submitting comments in support of ASD comments.
As noted above, the public consultation to submit comments on the Restriction Report will end on 3 January 2022.
21 September 2021: ERA has received information, through manufacturer member Pratt & Whitney Canada (PWC), regarding a proposed restriction from ECHA relating to the use of Dechlorane Plus (DP) in Europe that could potentially impact engine maintenance.
On 23 June, The European Chemicals Agency (ECHA) launched a public consultation on the substance ‘Dechlorane Plus’. ECHA proposes a restriction on the manufacture and placing on the market of DP. The consultation runs until 3 January 2022.
DP is used as a flame retardant in adhesives/sealants and polymers. Stakeholder consultation carried out for the preparation of this dossier indicated that DP is also used as an extreme pressure additive in greases. In these applications DP is used in motor vehicles, aircraft, electrical and electronic equipment, including consumer electronics. Other confirmed but minor uses are in explosives, and it is marketed for the use in fireworks.
DP was identified by ECHA as a Substance of Very High Concern (SVHC) in 2018 and whilst it is not chosen as an intentional ingredient by aerospace companies, it is present in certain products and designs due to a reliance on historical formulations that contain it.
The International Aerospace Environmental Group’s (IAEG) REACH Authorisation Work Group, chaired by PWC, has followed the DP story closely, due to its inclusion on ECHA’s 9th Recommendation List for Authorisation, as well as REACH Restriction & Stockholm Convention. Dechlorane Plus is used in critical formulations required for the manufacture and repair of aircraft hardware.
Usually, the airline community would consider this an OE specific issue, however in this particular instance, there is concern that the OEMS do not have a qualified alternative to offer to the airlines, and therefore the problem could be considered a joint one.
The Aerospace and Defense Industries Association (ASD) have submitted a response for the consultation, one which has had significant input from PWC. ERA members are recommended to review section 3 of the paper on on the non-use scenario which describe potential direct impact to jet engine aircraft maintenance.
Furthermore, as part of IAEG’s risk assessment activities, they are reaching out to airlines to make them aware of all of the regulatory activity around this substance. RPA, who is contracted by IAEG to assist in this activity, has developed a white paper on the regulatory issues surrounding DP and its relevance to the aerospace industry, as well as some supporting slides.
The REACH Work Group has indicated that they would like to collect information on airlines’ use of formulations containing DP to add to the list that our OEMs have already provided to RPA. To that end, they have included a spreadsheet for ERA airlines to populate and return, as described in the white paper.
In the Downloads section (members only) you can find the following:
- ERA-PWC Cover Letter
- ASD Restriction Response to ECHA
- IAEG DP White Paper & supporting slides
- IEAG DP Airline template
Your feedback is welcomed. Should you have any further questions or comments, please contact email@example.com