COMMENTS AND RESPONSE TO COMMENTS ON AUTHORISATION

Transcription

1 COMMENTS AND RESPONSE TO COMMENTS ON AUTHORISATION Substance Bis(2-ethylhexyl) phthalate (DEHP) Broad information on use applied for (title): The processing of a stop-off formulation containing DEHP during the diffusion bonding manufacture of aero engine fan blades. Consultation Applicant Rolls-Royce plc Consultation period: 14/08/ /10/ Affiliation: BehalfOfACompany Other Kooperationsstelle Hamburg IFE GmbH Germany SubsIn Mixture Combat Boron Nitride Aerosol Combat Boron Nitride Aerosol is a special coating which prevents diffusion bonding can be used in titanium processing. Combat Boron Nitride aerosol consists of boron nitride powder dispersed in an acetone CLP No classification _13_Attachment.pdf 1(6)

2 carrier compounded with a small amount of binder. A plasticizer is not needed. In this case, it can be used as an alternative to Stopyt- 62A which contains DEHP. Rolls-Royce are aware of this compound but it did not pass the initial pre-selection screening requirements. We believe Boron Nitride is not suitable for superplastic forming as Rolls-Royce have found through investigation that it produces micro-cracks on the internal face of the blade material, therefore this alternative did not warrant inclusion in the AoA report. This was determined at the early stages of the searches undertaken on alternatives. Rolls-Royce are aware of other superplastic forming practitioners who use boron nitride as a stop off, however we believe there is the potential to form titanium nitride which on expansion may cause micro cracking as it is a hard layer not superplastic. Externally this would not be an issue, but internally we would expect greater affinity to form the nitride as oxygen is excluded. Details of the comments received from Kooperationsstelle Hamburg IFE GmbH have been reviewed by our technical teams. As mentioned in the response to Question 4, Rolls-Royce believes that the use of boron nitride on the internal faces of the blades is likely to lead to micro cracking for this reason any boron nitride based alternatives were discounted early on in the search for alternatives. 12 Affiliation: BehalfOfACompany SubsIn Mixture Boron- Nitride- Coating Grade HP Boron- Nitride- Coating Grade HP is CLP No classification _12_Attachment.pdf 2(6)

3 Other Kooperationsstelle Hamburg IFE GmbH Germany a special coating which prevents diffusion bonding can be used in titanium processing. It is a formulation based on boron nitride, blended with a refractory binder. A plasticizer is not needed. In this case, it can be used as an alternative to Stopyt- 62A which contains DEHP. Rolls-Royce are aware of this compound but it did not pass the initial pre-selection screening requirements. We believe Boron Nitride is not suitable for superplastic forming as Rolls-Royce have found through investigation that it produces micro-cracks on the internal face of the blade material, therefore this alternative did not warrant inclusion in the AoA report. This was determined at the early stages of the searches undertaken on alternatives. Rolls-Royce are aware of other superplastic forming practitioners who use boron nitride as a stop off, however we believe there is the potential to form titanium nitride which on expansion may cause micro cracking as it is a hard layer not superplastic. Externally this would not be an issue, but internally we would expect greater affinity to form the nitride as oxygen is excluded. Details of the comments received from Kooperationsstelle Hamburg IFE GmbH have been reviewed by our technical teams. As 3(6)

4 mentioned in the response to Question 4, Rolls-Royce believes that the use of boron nitride on the internal faces of the blades is likely to lead to micro cracking for this reason any boron nitride based alternatives were discounted early on in the search for alternatives. 11 Affiliation: BehalfOfAn Non-governmental organisation (NGO) ClientEarth Belgium Stopyt- 62G CLP According to the applicant this is a nonhazardous substance or mixture (page 25 analysis of alternatives). _11_Attachment.doc x The public consultation for Applications for Authorisation is defined in article 64.2 of the REACH Regulation. Its purpose is to gather additional information on possible alternatives for the uses applied for. The information submitted by interested third parties will be taken into account in the development of the opinion for the relevant Applications for Authorisation by the Committee for Risk Assessment (RAC) the Committee for Socio-Economic Analysis (SEAC). As a consequence Rolls-Royce do not intend to respond directly on comments not relating to possible alternatives. Any s relating to alternative substances have been answered within our responses to the RAC SEAC requests for additional information. 10 Affiliation: BehalfOfAn Please see attached document _10_Attachment.doc 4(6)

5 Non-governmental organisation (NGO) ChemSec Sweden The public consultation for Applications for Authorisation is defined in article 64.2 of the REACH Regulation. Its purpose is to gather additional information on possible alternatives for the uses applied for. The information submitted by interested third parties will be taken into account in the development of the opinion for the relevant Applications for Authorisation by the Committee for Risk Assessment (RAC) the Committee for Socio-Economic Analysis (SEAC). As a consequence Rolls-Royce do not intend to respond directly on comments not relating to possible alternatives. Any s relating to alternative substances have been answered within our responses to the RAC SEAC requests for additional information. 9 Affiliation: BehalfOfAn Non-governmental organisation (NGO) European Environmental Bureau (EEB) Belgium DEHP elimination _9_Attachment.doc The public consultation for Applications for Authorisation is defined in article 64.2 of the REACH Regulation. Its purpose is to gather additional information on possible alternatives for the uses applied for. The information submitted by interested third parties will be taken 5(6)

6 into account in the development of the opinion for the relevant Applications for Authorisation by the Committee for Risk Assessment (RAC) the Committee for Socio-Economic Analysis (SEAC). As a consequence Rolls-Royce do not intend to respond directly on comments not relating to possible alternatives. Any s relating to alternative substances have been answered within our responses to the RAC SEAC requests for additional information. 6(6)