New regulations stipulate requirements to be taken into account in choosing the materials, mechanical parts and processes used in the production of space objects. Some regulations, such as REACH, apply to the space industry just as they do to any other industry. Furthermore, most materials and processes used in space projects are commercial products, impacted by any changes or discontinuance decided by the manufacturers. This is why it is important to be familiar with these regulations and their impacts, to anticipate them and to take them into consideration in developing a product.
The four main regulations currently affecting materials, mechanical parts and processes are:
- the REACH regulations,
- the RoHS directive,
- export permits (ITAR, etc.),
- the “Loi sur les Opérations Spatiales”, which could give rise to requirements affecting the choice of materials and processes and which shall apply as from 2020 but should be taken into account from now.
There is no specific regulation-related clause in “AP-6%20-%20Informations%20liées%20à%20la%20%20réglementation_EN_jfg.doc” on product assurance for materials, mechanical parts and processes, as compliance with regulations is implicit.
B. Principles of preparation
REACH: an EU regulation involving the Registration, Evaluation, Authorisation and restriction of CHemical substances. Its aim is to improve the protection of human health and the environment from the risks that can be posed by chemical substances, while enhancing the competitiveness of the EU chemical industry.
It applies to all chemical substances and, therefore, to all substances (solvent, adhesive component, etc.), preparations (adhesive, paint, etc.), or articles (part, tape, etc.) found in the materials, mechanical parts or processes used in the manufacture of space products.
Depending on their degree of hazardousness, the chemical substances impacted by this regulation are:
- substances considered as Substances of Very High Concern (SVHCs), in which case they are required to be declared if their content represents more than 0.1% (by weight) of a product. The updated list of SVHCs is available at the following link: http://echa.europa.eu/web/guest/candidate-list-table.
- prohibited for certain types of use. This involves the restrictions on the manufacture, placing on the market and use of certain hazardous substances, preparations and articles, i.e., prohibiting or limiting the types of use set out in the restrictions, Annex XVII of the REACH regulation. The list of substances concerned is set out at the following link: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/restrictions/list-of-restrictions/list-of-restrictions-table.
- prohibited for all types of use. These substances are listed in Annex XIV of the REACH regulation, set out at the following link: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation/recommendation-for-inclusion-in-the-authorisation-list/authorisation-list. A temporary permit needs to be obtained in order to use them.
RoHS: Restriction of Hazardous Substances
Directive 2002/95/EC on the restriction of use of certain hazardous substances in electrical and electronic equipment (known as "RoHS”), in effect since 1 July 2006, limits the use of lead, cadmium, hexavalent chromium, mercury, polybrominated biphenyls, and polybrominated diphenyl ethers in certain electrical and electronic equipment.
1. Identification of the scope of materials, mechanical parts and processes concerned by the REACH regulation
The number of substances impacted by the REACH regulation increases year by year. The scope of materials, mechanical parts and processes which already are or will be impacted covers all families of materials, including organic materials (paints, composite adhesives, etc.), metallic materials (e.g., chromium-composite-based materials for surface treatments) and even materials used in electronics.
Launchers, satellites, probes and manned structures all use these hazardous materials. Authorisation or restriction of a chemical substance can lead to changes in a preparation or an article that contains this substance, or to discontinuation of production of the substance of the preparation or of the article that contains the substance. This type of obsolescence problem therefore needs to be taken into consideration in choosing the materials for launchers, satellites, probes and manned structures. Substances used for ground applications are also concerned, as are those used in implementation processes.
2. Identification of requirements
The requirements relating to the implementation of hazardous chemical substances are identified:
- In the CNES Special Administrative Terms and Conditions (No.DAJ.2011/0020016 Iss. of 01 October 2011) The paragraph in question is XVII.D. Risk analysis, which stipulates:
‘The contractor undertakes, throughout the duration of the contract, to conduct risk analysis commensurate with the considerations of the contract and to integrate this approach and its results to the project risk management. This analysis shall mainly consist in identifying first the substances which, in the context of current regulation and foreseeable changes thereto, are critical for the project, and second the actions to be implemented to limit the impact on the project in terms of performance, cost and time.
- In the Materials and Processes Product Assurance specification,
‘The materials chosen shall not contain substances listed in Annex XIV of the REACH regulation.
It is also preferable to avoid choosing materials containing substances on the "candidate” list or list of substances recommended for inclusion in Annex XIV. If chosen materials do contain any of these substances, they will need to be taken into account in the risk analysis.'
3. Analysis of potential risks
- Obsolescence: discontinued production resulting in unavailability of a material, mechanical part or process.
- Change to a product which alters its properties, requiring new qualifications,
- Quality: possible decreased performance with proposed acceptable replacements,
- Costs: scheduling, investments for re-qualifications, development,
- Legal: verifying the application of REACH requirements.
4. Definition of risk reduction actions
- To be well-informed about the REACH regulation and its impacts,
- To know and control REACH-related risk pertaining to the materials, mechanical parts and processes used in the manufacture of space objects, especially with regard to characteristics and procurement circuits.
- To contact suppliers in order to know the current REACH status of the materials, mechanical parts and processes that are typically used.
- To contact the people in charge of REACH aspects within prime contractor entities (e.g., for CNES, DCT/AQ/MP for orbital systems and balloons).
- When changes are implemented, plan a review to ensure that the performance parameters properly meet the requirements.
Remarks: A work group on REACH-related aspects has been set up between CNES, ESA and manufacturers from the space industry (Airbus Defence and Space, Thalès Alenia Space, Ruag, OHB, MAP, Heraklès, etc.); one of its tasks is to identify the materials and processes that present risks. For this purpose, a non-exhaustive list of the materials and processes used in the space industry has been drawn up. The potentially-hazardous chemical substances contained in these materials and processes have been identified using the safety data sheets.
This made it possible to establish a list of materials presenting REACH risks in the short, medium and long term. However, since it was derived from the initial list of materials identified as being used in the space industry, this list is non-exhaustive.
It is available for laboratories and manufacturers under contract with the CNES, via the materials database MATREX, or from materials and processes personnel at DCT/AQ/MP.
C. Standard content of the identification list of REACH risk materials
This section contains the general information which defines the product concerned, the corresponding phase, and the project to which it is attached.
2. Reference documentation
This consists of the bibliography required to prepare the list, particularly the references of the lower level lists, where applicable.
The terminology and acronyms used in the document shall be explained in this section.
This section shall briefly describe the product concerned and the equipment taken into account to prepare the list, and the state of knowledge of each of the lists of the lower level.
5. How to use the form
The different columns of the requested file are described in the “Read-me” worksheet of the form Identification of REACH risk materials - PAF - 8.