It is critical that the Aerospace & Defence (A&D) sector continues to function without supply chain disruption. This means certainty about the continued reliance on the use of chromates subject to authorisation is critical to each stakeholder in the A&D supply chain, and it is essential that every effort be made to ensure that disruptions will not occur within the supply chain in the future.
If you are a Downstream User located in the EU, you must submit to ECHA exposure and environmental data 12 months after Authorisation. The dates for collecting and reporting this information are included in the Authorisation decisions. You must also submit an explanation of the key functionalities which require the continued use of the chromates. In order to ensure that longer review periods are received as part of the re-authorisation of critical residual uses, the ADCR is looking for your support. As monitoring data and information on key functionalities have to be submitted to ECHA, future applications will be expected to include such data for the supply chains that will be covered by the authorisation Review Reports.
We therefore would ask companies in the A&D sector that rely on the use of the chromates to provide, under commercial confidentiality, the related exposure and environmental monitoring data, together with the explanation on key functionalities applicable to the substance authorisation that you are submitting to ECHA to fulfil your REACH Article 66 downstream user obligations.
All information that you provide will only be used in an anonymised and aggregated way.
Contact details for the technical services team are as follows:
Risk & Policy Analysts (RPA) at: adcr-info@rpaltd.co.uk
If you are a GB-based Downstream User, you would have been required to provide certain information to the UK HSE by the 1st of March 2021. This included:
The UK HSE has set up an email address for communication on authorisations:
ukreach.authorisation@hse.gov.uk
As it is expected that the UK authorities will also request the same monitoring data and information on key functionalities as ECHA, we would ask that you also supply such information (under commercial confidentiality) to the ADCR technical team. Please also clearly mark that you are a GB- based supplier.
All information that you provide will be treated as commercially sensitive and will only be used in an anonymised and aggregated way.
Contact details for the technical services team are as follows:
Risk & Policy Analysts (RPA) at: ADCR-info@rpaltd.co.uk