ANALYSIS OF ALTERNATIVES FOR DEHP USE NON-CONFIDENTIAL REPORT

Photo of Wide Chord Fan Blade Assembly on Trent 1000 Engine © 2008 Rolls-Royce Group plc

ANALYSIS OF ALTERNATIVES FOR DEHP USE

NON-CONFIDENTIAL REPORT

Legal name of applicant(s): Rolls-Royce plc

Substance: bis(2-ethylhexyl) phthalate (DEHP)

Use title (use 1 of 1): The processing of a stop-off formulation containing DEHP

during the diffusion bonding and manufacture of aero engine

fan blades

Report Prepared by: WSP Environmental Ltd

Report Status: Final Report - Non-Confidential

Report Date: 20th May 2013

Rolls-Royce plc 2 Alternatives Analysis Report for DEHP Use

© Rolls-Royce plc 2013

The information in this document is the property of Rolls-Royce plc and may not be copied, communicated

to a third party, or used for any purpose other than that for which it is supplied, without the express written

consent of Rolls-Royce plc.

While the information is given in good faith based upon the latest information available to Rolls-Royce plc,

no warranty or representation is given concerning such information, which must not be taken as establishing

any contractual or other commitment binding upon Rolls-Royce plc or any of its subsidiary or associated

companies.

Trent® is a registered trademark of Rolls-Royce plc

This report has been prepared by WSP, with reasonable skill, care and diligence within the terms of the

Contract with the client, incorporating our General Terms and Conditions of Business and taking account of

the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and

others in respect of any matters outside the scope of the above. This report has been prepared for the client and we accept no responsibility of whatsoever nature to any third parties to whom this report, or any part

thereof, is made known or has access to the report. Any such party relies on the report at their own risk.


Contents 1. Summary ...............................................................................................................4

2. Analysis of Substance Function ............................................................................5

3. Identification of Possible Alternatives ..................................................................12

3.1. List of Possible Alternatives ..........................................................................12

3.2. Description of Efforts Made to Identify Possible Alternatives ........................15

3.2.1. Research and Development....................................................................15

3.2.2. Data Searches ........................................................................................15

3.2.3. Consultations ..........................................................................................15

4. Suitability and Availability of Possible Alternatives ..............................................16

4.1. ALTERNATIVE 1: GG4400 B2 ......................................................................16

4.1.1 Substance ID and Properties ...........................................................................16

4.1.2 Technical Feasibility ........................................................................................16

4.1.3 Economic Feasibility ........................................................................................17

4.1.4 Reduction of Overall Risk due to Transition to the Alternative .........................17

4.1.5 Availability ........................................................................................................17

4.1.6 Conclusion on Suitability and Availability for Alternative 1 ...............................17

4.2. ALTERNATIVE 2: Dag MS-401LR ................................................................18





4.2.5 Availability ........................................................................................................20


4.3. ALTERNATIVE 3: Stop-flo No2 .....................................................................21





4.3.5 Availability ........................................................................................................23


4.4. ALTERNATIVE 4: Stopyt-62G ......................................................................24





4.4.5 Availability ........................................................................................................27


5. Overall Conclusions on Suitability and Availability of Possible Alternatives ........28

6. Appendix A: Project Plan for Alternative Analysis Programme 30

7. Glossary ..............................................................................................................32

8. References ..........................................................................................................34


1. Summary DEHP (bis(2-ethylhexyl) phthalate) is used by Rolls-Royce within a mixture called ‘Stopyt-62A’ which is purchased from Morgan Technical Ceramics – Wesgo Metals Division, a US company. Stopyt-62A as a mixture provides key functionality in a diffusion bonding process in the manufacture of aero-engine fan blades, a vital safety critical component. Fan blade technology is a particular source of competitive advantage for Rolls-Royce and this particular process is common across much of the Rolls-Royce civil engine product range and some of the defence engine product range.

Each Rolls-Royce engine undergoes a rigorous development and validation programme in order to obtain approval from the European Aviation Safety Agency (EASA), amongst other aircraft safety regulatory bodies, which provides type-certification of aircraft and components. The process to develop, test and validate alternatives to Stopyt-62A will require an extensive programme of work and involve significant research and development costs. As such, the work to identify an alternative is on-going and this report presents the relevant information that is currently available at the time of submission of this report. Currently, there are four identified mixtures/formulations which may be considered potential alternatives to Stopyt-62A in the future subject to the on-going investigation. These are:

1. GG4400 B2

2. Dag MS-401LR

3. Stop-flo No2

4. Stopyt-62G

With regard to each of these formulations/mixtures, some analysis has already been conducted or is being progressed but significant further work is still required in order to confirm the optimum solution to take forward to validation. The analysis that is being conducted covers: availability and suitability; risks to human health and the environment; and, technical and economic feasibility. From the list above two substances can be discounted for further analysis on technical grounds of their suitability. These are GG4400 B2 and Dag MS-401LR. Of the remaining substances (i.e. Stop-flo No2 and Stopyt-62G) further analysis has been programmed.

Rolls-Royce attended a Pre-submission Information Session (PSIS) meeting with the European Chemicals Agency (ECHA) on the 14

th November 2012. Following clarification of the processes and guidance on

Application for Authorisation at the PSIS, Rolls-Royce identified that there will be no need to provide a Substitution Plan as a separate report for submission, on the basis that adequate control could be demonstrated and no qualified substitute exists at the time of submission.

The research on alternatives to date indicates that Stopyt-62G is the most likely alternative to Stopyt-62A. Provided that it fulfils all technical and economic feasibility requirements, Stopyt-62G may be incorporated into a future Substitution Plan which will provide the list of actions required for transferral to this alternative and the timing for those actions.

It is anticipated that the remaining work to develop an alternative would incur significant research and development (R&D) costs for Rolls-Royce and take between 5-10 further years to complete. This is based on Rolls-Royce’s recent experience of engine validation and flight test costs.

Much of the information related to the Analysis of Alternatives for DEHP use contains Intellectual Property, commercially sensitive information, share price or investor sensitive information or plans about future product developments. All of which have value to stakeholders or competitors. There may also be site-specific Rolls-Royce worker exposure data which may be sensitive and breach Data Protection rights if released publicly. The specific areas of confidential information that are provided in the Confidential Annex are referenced as required throughout this report.

Reference to section in Confidential Annex to Analysis of Alternatives

Additional confidential information is presented in: Confidential Annex to Analysis of Alternatives for DEHP Use, Section 1: Summary, Page 5.

The confidential information that is provided is the research and development costs to complete the programme of work to identify an alternative.


2. Analysis of Substance Function Overview

The Rolls-Royce wide-chord fan blade (WCFB) manufacturing process uses Stopyt-62A which contains DEHP. WCFBs are designed to be hollow in order to save weight. This employs a unique manufacturing process developed by the Group and employed at the manufacturing facility.

First generation wide-chord fan blades, used on older engine families, use a titanium honeycomb sandwich structure, where the honeycomb is diffusion bonded between two solid sheets. The next generation of fan blades, for the latest Trent range of engines, features an internal structure that is created during a process that diffusion bonds and super-plastically forms three sheets of titanium. Hollow design allows significant weight savings to be made in the fan blade, especially at larger fan sizes, and a follow on weight saving in the fan disc, structure and containment features.

The Rolls-Royce wide chord fan blade is perhaps the best example of the application of titanium, coupled with advanced processing techniques, to give a significant service advantage. Modern blades are manufactured from three sheets of titanium representing the two outer skins and the internal corrugated structure. A bonding stop-off agent (Stopyt-62A) is applied, to define the internal structure, and then the three pieces are bonded in a high temperature pressure vessel. The blade is twisted and the cavity inflated at very high temperature using an inert gas in a shaped die to yield its final aerofoil shape. The total process results in bonds with properties equivalent to the parent material and an internal stiffening structure which bears its share of the centrifugal load. Compared to the original solid clapper design this gives a fan module which is 24 per cent lighter, an overall engine weight benefit of 7 per cent, with a significant increase in foreign object damage (FOD) resistance over competitor designs (Rolls-Royce 1995, 2012b).

According to the fan blade design approved by European Aviation Safety Agency (EASA), a specific pattern of the Stopyt-62A liquid is printed onto the titanium fan blades using a silk screen. This process is proprietary to Rolls-Royce and is covered by a number of internationally registered Patents (Rolls-Royce 1995, 2012b) having been developed and perfected by the company over the last 20 years.

The active ingredient in the Stopyt-62A is Yttria (Yttrium(III) Oxide) which prevents diffusion bonding in the printed areas of the blade. DEHP is added to the Stopyt-62A as a plasticiser to ensure a smooth and even coating of Yttria is printed onto the blade. The DEHP also modifies surface tension and plasticity of the dried Yttria ensuring that it does not crack or flake-off the blades. The DEHP content of the Stopyt-62A also ensures that the required bake out temperature is achieved prior to diffusion bonding.

Process Description

The wide-chord fan blade (WCFB) manufacturing process involves several stages of production. The manufacturing stages that are relevant to the application and function of Stopyt 62A are:

• Screen printing of panels

• Assembly and sealing of panels

• Bake out

• Diffusion bonding

• Inspection of bonds

• Superplastic forming of the blades

During screen printing of panels, Stopyt 62A is poured on a screen and printed on to the panel. The panels are then stacked and the edges are welded together. The assembly is placed in an autoclave and heated so as to “bake out” the binder from the material which may prevent diffusion bonding. The location of diffusion bonds is controlled by applying the stop-off material (Stopyt 62A) to preselected areas. The sealed assembly is then placed in a pressure vessel and is heated and pressed to diffusion bond the work pieces together to form an integral structure. Diffusion bonding occurs when matt surfaces are pressed together under temperature and pressure conditions for a period of time that allows atom interchange across the interface. After inspection, the assembly is then put into an autoclave and heated again with pressurised fluid between appropriately shaped dies. The work pieces then become superplastically formed to produce an article matching the shape of the dies.


Tasks Performed by Substance and Substance Function Data

In analysing the substance function, consideration has been given to the task performed by Stopyt-62A (rather than DEHP alone) as it is the mixture that provides the key functionality in the diffusion bonding process. The manufacturing process has been rigorously optimised and validated around the properties of the mixture. The specific contribution of the DEHP is as a plasticiser but it is the properties of the Stopyt-62A mixture as a whole that are relevant. Stopyt-62A has been subject to rigorous investigations and tests and any alternative will also be required to pass these rigorous investigations and tests so that the design organisation can provide the necessary evidence to EASA that the alternative satisfies the product type design certification basis.

A summary of the substance function information is provided in Table 1 below together with a synopsis of customer and legal requirements relating to the validation and introduction of alternatives.


Table 1: A summary of the substance function of Stopyt-62A (with DEHP in the mixture)

Functional Aspect Information

Task performed Stopyt-62A is used in diffusion bonding of the titanium blades under high pressure and temperature ensuring only specific areas of the blades are bonded together to give the correct strength and stiffness whilst retaining a light-weight hollow structure. DEHP is a plasticiser within the approved Stopyt-62A mixture. The stages of application of Stopyt-62A to achieve the necessary product quality are as follows:

� Manual handling, shaking and opening of Stopyt-62A bottle:

� Transfer and sampling of Stopyt-62A:

� Pouring Stopyt-62A for printing and use of wipes:

Exposure to operators can occur at the stages above the diffusion bonding and superplastic formation stage, by inhalation and / or dermal exposure. Risk management measures are in place that include use of closed systems, extraction booths, restricted operating times, employee training and personal protective equipment (chemically resistant gloves, coverall and eye protection).

Critical properties and quality criteria

Substance ID and Properties (Stopyt-62A)

Chemical Name: Stopyt-62A

Classification of the mixture:

CLP/GHS Classification (1272/2008): The mixture has been self-classified as:

■ Flammable liquid (cat 2)

■ Acute toxicity – inhalation (cat 4)

■ Eye irritant (cat 2)

EU Classification (67/584/EEC):

■ Toxic to reproduction (cat 2)

■ Specific target organ toxicity- single exposure (cat 3 – narcotic/respiratory irritant)

Composition and Information on Ingredients:

Chemical name CAS Number / EINECS Number / REACH Reg. Number

% (w/w) EU Classification (64/548/EEC)

CLP/GHS Classification (1272/2008)

Yttrium Oxide 1314-36-9 / 215-233-5 <50% Not dangerous Not hazardous

Methyl isobutyl ketone 108-10-1 / 203-550-1 10-50% F; R11 Xn; R20 Xi; R36/38, R66

Flam. Liq. 2 (H225) Acute Tox. 4 (H332) Eye Irrit. 2 (H319) STOT SE 3 (H335)

Isopropyl alcohol 67-63-0 / 200-661-7 30-40% F; R11 Xi; R36 R67 Flam. Liq. 2 (H225) Eye Irrit. 2 (H319) STOT SE 3 (H336)

Di(2-ethylhexyl)Phthalate 117-81-7 / 204-211-0 <10% Repr. Cat. 2; R60-61 Repr. 1B (H360FD)



Note: Morgan Technical Ceramics, Wesgo Metals Division that supplies Stopyt-62A, stated that DEHP was 100% pure and is present at only 5% w/w (+/- 2%)

Substance ID and Properties (DEHP)

■ Chemical Name: bis(2-ethylhexyl) phthalate (DEHP)

IUPAC Name: bis(2-ethylhexyl) phthalate

CAS Number: 117-81-7

EC Number: 204-211-0

Classification of the substance:

LP/GHS Classification (1272/2008):

■ Reproductive toxicity (Category 1B) ■ Acute aquatic toxicity (Category 1)

■ Chronic aquatic toxicity (Category 1)

EU Classification (67/584/EEC):

■ May impair fertility. May cause harm to the unborn child

Function Conditions Estimated fate of Stopyt-62A: Majority is thermally destroyed during bake out with the remaining amount disposed of by a licensed contractor as hazardous waste. Negligible amounts are discharged to the site effluent system and to atmosphere (as verified by monitoring and analysis).

Process and performance constraints

The process and performance constraints are summarised as follows:

� Overall assembly process duration

� Bake out temperature and vapour pressure

� Plasticity of Yttrium Oxide printed pattern

� Drying technique and time

� Ease and effectiveness of screen cleaning

� Avoidance of screen damage

� Standard inspection covering c-scan, binocular checks, chisel tests and micro checks

� Fine edge definition

� Colour for visual inspection

� Compatibility with superplastic forming process

� Bond efficacy

� Contamination prevention



Is the function associated with another process that could be altered so that the use of the substance is limited or eliminated?

This is a key Rolls-Royce patented process that is used in the wide-chord fan blade (WCFB) manufacturing in the UK. There are no other processes that could be altered so that the use of the substance is limited or eliminated other than a direct substitution or a different technological approach to applying the stop-off agent.

What customer requirements affect the use of the substance in this use?

WCFBs are a critical component in the Rolls Royce manufacturing process and a reliability sensitive part which is subject to extreme stress conditions in normal operational service. They have to withstand operational incidents and failure events, and deform/fail within well-defined safety driven parameters. The customer requirements are driven by the industry standards to achieve airworthiness and environmental certification of aircraft and related products as detailed in the regulations below.

Are there particular industry sector requirements or legal requirements for technical acceptability that must be met and that the function must deliver?

European Regulations

The use of Stopyt-62A is required to comply with Commission Regulation (EU) No 748/2012 of 03 August 2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisations.

The design process using Stopyt-62A in WCFB manufacturing process is part of the Type Design of a range of products, in accordance with (EU) No 748/2012 paragraph 21A.31 as follows:

� 21A.31 Type design

(a) The type design shall consist of:

1. The drawings and specifications, and a listing of those drawings and specifications, necessary to define the configuration and the design features of the product shown to comply with the applicable type-certification basis and environmental protection requirements;

2. Information on materials and processes and on methods of manufacture and assembly of the product necessary to ensure the conformity of the product;

3. An approved airworthiness limitations section of the instructions for continued airworthiness as defined by the applicable airworthiness code; and

4. Any other data necessary to allow by comparison, the determination of the airworthiness, the characteristics of noise, fuel venting, and exhaust emissions (where applicable) of later products of the same type.

(b) Each type design shall be adequately identified

Stopyt-62A has been subject to investigations and tests as defined by paragraph 21A.33.

� 21A.33 Investigation and tests

(a) The applicant shall perform all inspections and tests necessary to show compliance with the applicable type-certification basis and environmental protection requirements.

(b) Before each test required by paragraph (a) is undertaken, the applicant shall have determined:

1. For the test specimen:

(i) That materials and processes adequately conform to the specifications for the proposed type design;



(ii) That parts of the products adequately conform to the drawings in the proposed type design;

(iii) That the manufacturing processes, construction and assembly adequately conform to those specified in the proposed type design; and

2. That the test equipment and all measuring equipment used for tests are adequate for the test and are appropriately calibrated.

(c) The applicant shall allow the Agency to make any inspection necessary to check compliance with paragraph (b).

(d) The applicant shall allow the Agency to review any report and make any inspection and to perform or witness any flight and ground test necessary to check the validity of the declaration of compliance submitted by the applicant under 21A.20(b) and to determine that no feature or characteristic makes the product unsafe for the uses for which certification is requested.

(e) For tests performed or witnessed by the Agency under paragraph (d):

1. The applicant shall submit to the Agency a statement of compliance with paragraph (b); and

2. No change relating to the test that would affect the statement of compliance may be made to a product, part or appliance between the time compliance with paragraph (b) is shown and the time it is presented to the Agency for test.

(EU) No 748/2012 sub-part D defines the responsibilities of the design organisation with respect to changes of the type design.

Changes are classified as minor or major. Both require an application for approval of a change to a type design to be made. The change in manufacturing process for fan blades is likely to be classified as a major change.

There is other legislation that is applicable to aviation safety includes:

■ Commission Regulation (EC) No 216/2008 of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency

■ Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks

These legislative requirements are to ensure airworthiness by ensuring that product changes will require substantive evidence of compliance with safety standards and approval by the Agency. Therefore alternatives may not be substituted where they are not validated. This implies that product changes will not be possible at short notice.

Other European and National Regulations

There will be other legislation associated with environment, health and safety including chemical exposure, occupational health, control and storage, personal protective equipment, fire safety etc. for the introduction of new chemicals.

Rolls-Royce Standards

For the introduction of new processes and techniques, there are a number of phases at Rolls-Royce known as Manufacturing Capability Readiness Levels (MCRL) that need to be attained. The MCRLs are a sequence of carefully defined stages of manufacturing and process maturity. This is aimed at managing the complex process of development and introduction of new manufacturing capabilities within Rolls-Royce.

MCRL is a key process principle within the Rolls-Royce manufacturing capability acquisition process – a framework of best practice principles for acquisition of manufacturing capability.



For the introduction of alternatives substances / techniques to Stopyt-62A, the MCRL may need to be attained. The phases are summarised as:

■ Phase 1: Technology Assessment and Proving: • MCRL 1: Process concept proposed with scientific foundation • MCRL 2: Applicability and validity of concept described and vetted, or demonstrated

• MCRL 3: Experimental proof of concept completed

• MCRL 4: Process validated in laboratory using representative development equipment ■ Phase 2: Pre-production

• MCRL 5: Basic capability demonstrated using production equipment

• MCRL 6: Process optimised for capability and rate using production equipment ■ Phase 3: Production Implementation

• MCRL 7: Capability and rate confirmed via economic run lengths on production parts

• MCRL 8: Fully production capable process qualified on full range of parts over significant run lengths

• MCRL 9: Fully production capable process qualified on full range of parts over extended period (all Business Case metrics achieved)



Additional confidential information is presented in: Confidential Annex to Analysis of Alternatives for DEHP Use, Section 2: Analysis of Substance Function, Table 1, Page 7 and 8. The confidential information that is provided is as follows:

■ Further details of the tasks performed in the application of Stopyt-62A under:

• Manual handling, shaking and opening of Stopyt-62A bottle

• Transfer and sampling of Stopyt-62A

• Pouring Stopyt-62A for printing and use of wipes

■ Critical properties and quality criteria providing key process parameters

■ Function Conditions providing manufacturing data associated with the quantity of material used per number of wide-chord fan blades produced

3. Identification of Possible Alternatives

3.1. List of Possible Alternatives

Factors Affecting Suitability of Alternatives

Each Rolls-Royce engine type undergoes a rigorous development and validation programme in order to obtain approval from the European Aviation Safety Agency (amongst other aircraft safety regulatory bodies) which provides type-certification of aircraft and components. Stopyt-62A which contains DEHP is used in the precision manufacture of the fan blades for Rolls-Royce engines. Taking into account the work to date, the remaining process to develop, test and validate DEHP-free alternatives to Stopyt-62A is estimated to require a further 5 to 10 years and involve significant research and development costs. This is based on Rolls-Royce’s recent experience of engine validation and flight test costs. Rolls-Royce has developed a project plan, detailing the tasks involved in the development, testing and validation stages (see Appendix A).

The key technical and economic criteria which affect the suitability of alternatives to Stopyt-62A (i.e. replacement with a DEHP-free diffusion bonding stop-of agent) are as follows:

■ Ability to print a precise pattern on the titanium blade

■ Yttria pattern is held firmly in place until diffusion bonding takes place

■ High diffusion bond strength achieved in non-printed areas

■ Quick drying time to meet printing and assembly window

■ Minimal product contamination

■ Highly reproducible printing results

■ Plasticiser that is less toxic than DEHP

■ Plasticiser that is compatible with the other process solvents used

■ Bake out temperature required

■ Plasticiser with correct wettability with our alloy of titanium

■ Cost-effective solution to maintain competitiveness

■ A substantial and lengthy air-worthiness validation programme is required

■ Extensive non-destructive, destructive and flight testing may be required


Based on recent engine development and validation programmes, Rolls-Royce’s experience indicates that the time required for substitution of DEHP is likely to be in the 5-10 year timeframe with significant testing and validation costs (see example below). Therefore, Rolls-Royce will seek authorisation for continued use of DEHP beyond the sunset date of 21st February 2015 as permitted under the REACH Regulations. This is a business critical requirement for Rolls-Royce. Failure to obtain authorisation would result in major disruption to our global aircraft engine manufacturing output, with the possibility of all European manufacturing being relocated to outside Europe in the medium-term. It is noted that our key aero-engine competitors are General Electric (GE) and Pratt & Whitney who whose equivalent facilities are both based in the United States and are affected by REACH to a lesser extent.

Figure 1: Example of Rolls-Royce’s Engine Test Programme Requirements

© 2013 Rolls-Royce Group Plc

Delivering a new engine that provides the lowest fuel burn, lowest emissions and noise signature, as well as the thrust required for all variants of the 787, is a complex task and one that is only achievable through a robust development programme. The extensive programme that Rolls-Royce undertook resulted in the Trent 1000 powering over three quarters of the total 787 flight test experience. The result is the Trent 1000 which is the first engine certified at the full 74,000lb thrust and the first engine certified for 330 minute Extended Twin Operations (ETOPS).

In April 2004, Boeing selected the Trent 1000 to power the Boeing 787 Dreamliner. The Trent 1000 first engine run took place on 14 February 2006, which was achieved on time, to a schedule set two years earlier. This marked the end of the initial design phase and the beginning of the rigorous testing and validation required to meet all airworthiness criteria. The Trent 1000 achieved its airworthiness certificates on schedule on 7 August 2007. The total duration of testing and validation was 3½ years but this was using an already validated manufacturing process for the fan blades.


Alternatives Assessment Milestones

Rolls-Royce is currently developing alternatives for Stopyt-62A. Key milestones include:

■ Analysis of DEHP free alternatives including:

• Validation strategy definition and requirements

• Production readiness and manufacturing capability assessment

■ Analysis and validation of Alternative 4 ( Stopyt-62G) including:

• Initial laboratory assessment

• Materials and component testing

■ Analysis and validation of Alternative 3 (Stop-flo No2) including:

• Assessment of trial results and improvements

• Assessment of risks to fan blade performance and production volumes

• Assessment of solution and process modifications required

• Detailed development program with costing and board approval

• Introduction of solution and process modifications

• Production scale testing of fan blades

• Destructive testing of fan blades

• Flight testing of fan blades

• Submission of design approval changes to EASA

• Approval by EASA for safety critical fan blade modification

• Introduction of full-scale production of fan blades using DEHP-free alternative

Note: Initial tests on Alternative 4 (Stopyt-62G) have already been conducted. Alternative 4 appears to pose the lowest technical risk as an alternative for Stopyt-62A with few changes envisaged to the process techniques used for its application. Alternative 3 (Stop-flo No2) requires additional testing steps since its composition is significantly different to Stopyt-62A.

An overall timetable has been developed by Rolls-Royce and extends to a 5-10 year time horizon and will be

dependent on the success of early trials with Stopyt-62A alternatives. See Appendix A for further details.

The four substances identified as potential alternatives to Stopyt-62A are:

1. GG4400 B2

2. Dag MS-401LR

3. Stop-flo No2

4. Stopyt-62G

The details of the search for possible alternatives to identify these substances are provided in the sections that

follow.


Additional confidential information is presented in: Confidential Annex to Analysis of Alternatives for DEHP Use, Section 3: Identification of Possible Alternatives, 3.1 List of Possible Alternatives, Factors Affecting Suitability of Alternatives, Page 9. The confidential information that is provided is as follows:

■ Manufacturing data specifically associated with:

5-10 year programme of work

Significant R&D costs


• Drying times

• Bake out temperature

■ Research and development costs to complete the programme of work to identify an alternative

3.2. Description of Efforts Made to Identify Possible Alternatives

3.2.1. Research and Development

Rolls-Royce has previously worked with University technology centres to identify potential alternatives. On-going collaborative research is being conducted with the Asia Pacific University with support from a specialist supplier. A further alternative is currently being pursued but as it is at the very early conceptual stage, details have not been included within this assessment. In addition, in-house research and development at Rolls-Royce continues on the potential alternatives.


There is no confidential information in this section of the report.

3.2.2. Data Searches

Rolls-Royce has been actively searching for potential alternatives over several years. These have included literature and internet searches and communications with specialist industry bodies and manufacturers. Stop-flo No2 was identified as a potential alternative from a literature review.



3.2.3. Consultations

Rolls-Royce has been actively consulting and working with suppliers, sector associations and academic bodies over several years to identify suitable alternatives to Stopyt-62A either directly through consultation with suppliers or initial data searches that led to consultation within the supply chain. In addition, Rolls-Royce has approached specialist bodies such as the British Ceramics Institute and other industry organisations such as BAE Systems and Pilkington’s European Research Centre. This work has resulted in the identification of a number of potential alternatives from several suppliers as follows:

Acheson

The Acheson Colloids water based stop-off, GG4400 B2 which was initially trialled in 1997 without success.

The Acheson, Dag MS-401LR, which has recently undergone early trials without success. Dag MS-401LR was identified from consultation with the Rolls-Royce Hucknall site, as it is employed in a diffusion bonding process with function and application method similar to Stopyt-62A.

Johnson Matthey

The Johnson Matthey, Stop-flo No2 is currently undergoing early trials.

Morgan Technical Ceramics – Wesgo Metals Division

The Morgan, Stopyt-62G is currently being investigated as potential candidate for Stopyt-62A substitution. Stopyt-62G uses glycerol instead of DEHP as the plasticiser.




4. Suitability and Availability of Possible Alternatives

4.1. ALTERNATIVE 1: GG4400 B2

4.1.1 Substance ID and Properties

The investigation into the use of GG4400 B2 was conducted in 1997 and the original Material Safety Data Sheet is no longer on file at Rolls-Royce. Efforts to obtain a new MSDS indicate that this product is no longer on the market and therefore the substance ID and properties are not available to ascertain the risks from an environmental and health perspective.



4.1.2 Technical Feasibility In 1997, Rolls-Royce investigated a water based stop-off as an alternative to Stopyt-62A, with the aim of reducing emissions of Volatile Organic Compounds (VOCs). The implementation of a water based stop-off would eliminate the use of a non-aqueous solvent in the screen cleaning process. The driver at the time was the requirement to install an abatement system should the amount of VOCs consumption exceed 5 tonnes per year. At the time, it was estimated that conversion to a water based stop-off (such as GG4400 B2) would significantly reduce environmental impacts and provide a significant savings on materials. It was also expected that the frequency of screen cleaning would be reduced hence allowing greater throughput. Trials were conducted using GG4400 B2. From this work that was undertaken, the following conclusions were reached:

■ Screen cleaning equipment would require adaptation for use with water

■ Screens cleaned easily with stop-off removed from pores in mesh. There was no damage to screens

■ Accelerated drying equipment would be minimal, as the drying time was good

■ Good edge definition was achieved

■ Pressure tests indicated that the bond on the water based stop-off printed blade was of a lower strength. The bond strength was thought to be affected in one of several ways:

• Water in the binder contaminated the bond

• Increased binder evolution contaminated the bond

• Higher bake out caused binder / water to diffuse into the bond

• Binder remaining after the bake out contaminated the bond

All three test blades that were made up with GG4400 B2 were found to fail earlier than Stopyt-62A printed blades, leading to an unacceptable safety risk for aero-engine performance. On the basis of this further work using GG4400 B2 as an alternative to Stopyt-62A was abandoned.




4.1.3 Economic Feasibility

At the time of the work in 1997, an analysis of the financial benefits was also undertaken. Although, the economic feasibility was favourable with modest project costs for investigation and installation and material savings that would achieve a pay back of less than two years, GG4400 B2 was discounted on the grounds of technical feasibility.

Reference to section in Confidential Annex to Analysis of Alternative

Additional confidential information is presented in: Confidential Annex to Analysis of Alternatives for DEHP Use, Section 4: Suitability and Availability of Possible Alternative, 4.1 Alternative 1: GG4400 B2, 4.1.3 Economic Feasibility, Table 2, Page 12. The confidential information that is provided is as follows:

A cost analysis table of the use of GG4400 B2 as a possible alternative for Stopyt that includes cost data on:

■ Project costs covering:

• Man hours

• Chemical analysis

• Materials

■ Installation costs

■ Material usage costs

4.1.4 Reduction of Overall Risk due to Transition to the Alternative

Not evaluated further as the alternative has been discounted on the grounds of technical feasibility.



4.1.5 Availability




4.1.6 Conclusion on Suitability and Availability for Alternative 1

GG4400 B2 is not a candidate for substitution due to the shortfalls in technical suitability. Using GG4400 B2 in place of Stopyt-62A would present unacceptable safety risk for aero-engine performance.


4.2. ALTERNATIVE 2: Dag MS-401LR


Table 3: Substance ID and Properties of Dag MS-401LR

Functional Aspect Information on Dag MS-401LR

General Information

Description of Dag MS-401LR and associated technology required to achieve the function of the Stopyt-62A

Dag MS-401LR has been considered as a possible alternative for Stopyt-62A and not DEHP which would also potentially employ an alternative or modified technology for its application. Dag MS-401LR supplied by Acheson is an Yttria based stop-off which was identified from consultation with the Rolls-Royce Hucknall site, as it is employed in diffusion bonding process with function and application methods similar to Stopyt-62A. Process modifications needed to achieve the function of Stopyt-62A were found to be incompatible with the clean room (see Section 5.2 below).

Substance ID and Properties

Chemical Name and Composition Dag MS-401LR is the trade name. The composition is:

Hazardous Substance

CAS No.

EC No.

Content %

Symbol(s) R-phrase(s)

2-butoxyethyl acetate

112-07-2

203-933-3

25-50 Xn 20/21

solvent naphta (petroleum), light aromatic

64742-95-6

265-199-0

1-5 Xn + N 10-37-51/53-65-66-67

Classification and Labelling Information

Risk phrase: 20/21, 52/53

Safety phrase: 23C, 36/37, 43E

Physico-Chemical Properties Physical form: Blue fluid

Boiling point: >147oC

Flash point: 73oC

Density: 1700kg/m3

Exposure / Work Place Controls Exposure Limits and guidelines for glycerol

Substance Index Number MAC TGG 8 in ppm

2-butoxyethyl acetate

607-038-00-2 20

solvent naphta (petroleum), light aromatic

649-356-00-4 -




4.2.2 Technical Feasibility

As part of an affordability initiative to significantly reduce the cost of the screen printing process by better screen utilisation, a reduction in screen and Yttria costs, a competitive tendering was issued by Rolls-Royce in 2002 to use an alternative stop-off agent.

As part of this initiative, Dag MS-401LR supplied by Acheson was identified as an alternative to Stopyt-62A. It was identified from consultation with the Rolls-Royce Hucknall site, as it is employed in diffusion bonding process with function and application methods similar to Stopyt-62A.

Trials were conducted using Dag MS-401LR. A fan blade printed with Dag MS-401LR and subsequently diffusion bonded was evaluated using the WCFB gated bond quality assessment regime. Forced drying was also trialled using infra-red heating. From this work that was undertaken the following conclusions were reached:

■ It was established that the post-screen print drying time is significantly longer than Stopyt-62A. The chemical characteristics of the binder in Dag MS-401LR are designed to keep the media wet to enable multiple printing without the need for screen cleaning. The natural drying time was excessive which is against the philosophy of minimising potential contamination of surfaces to be bonded.

■ There would be change in the process with the need for forced drying techniques which was not compatible with a clean room. Accelerated or forced drying poses a risk to product integrity.

■ The colour of the Yttria was white making visual inspection difficult as the titanium surface and Yttria had a small contrast. This was resolved by adding blue dye.

■ The screens would need to be cleaned with BGA (Butylglycolacetate) requiring as a minimum a change to the existing process but more likely a new screen cleaning process. Also more time would be incurred in wiping down and drying out the screens as a result of the new cleaning process.

■ The Yttria is quite viscous and designed to be applied to the screens once for approximately 30 prints. The fact that the screens are not washed after each print would lead to a greater chance of contamination.

■ Problems were encountered during the superplastic forming operation with a blockage of resin material, the source being the binder not allowing high pressure argon through the gas entry slot.

■ The greater viscosity of the Yttria would likely lead to frequent blockages in the pipes feeding the bake out machine. This would lead to greater production downtime and maintenance costs.

■ Although the WCFB bond quality standard was met with no bond defects found, it was concluded that there was a high risk associated with potential contamination of the diffusion bonded face and therefore product integrity could be jeopardised.

On the basis of these findings, further work has been abandoned using Dag MS-401LR as an alternative to Stopyt-62A. The process using Dag MS-401LR did not allow for a repeatable high strength diffusion bond, leading to an unacceptable safety risk for aero-engine performance.












4.2.5 Availability





This is not a candidate for substitution due to the shortfalls in technical suitability. Using Dag MS-401LR in place of Stopyt-62A would present an unacceptable safety risk for aero-engine performance. In addition, an evaluation of the substance properties shows that the solvent in the mixture is subject to mutagenic and carcinogenic classifications under the Classification, Labelling and Packaging of Substances Regulations, therefore also making it potentially undesirable as an alternative to DEHP on health grounds.




4.3. ALTERNATIVE 3: Stop-flo No2


Table 4: Substance ID and Properties of Stop-flo No2

Functional Aspect Information on Stop-flo No2

General Information

Description of Stop-flo No2 and associated technology required to achieve the function of the Stopyt-62A

Stop-flo No2 is a feasible substance alternative only (and not an alternative technique or technology). It is predicted that no process changes will be necessary to implement this alternative but this will be confirmed as further tests are completed. Stop-flo No2 is a white colour, water based product with the consistency of emulsion paint intended for use as a braze “Stop-off”. It is supplied by Johnson Matthey. As Stop-flo No2 is not a direct substitution for DEHP in Stopyt-62A, the assessment is based on a comparison of the mixture as a whole.

Substance ID and Properties

Chemical Name and Composition Stop-flo™No.2 Paint is the trade name. The composition is: Substance CAS No. EINECS

No. % Concentration

Yttrium oxide

1314-36-9

215-233-5

50 to 80

Denatured ethanol

64-17-5

200-578-6

7 to 8

The supplier reports that water makes up nearly all of the remainder.


EC Classification: Non hazardous

Physico-Chemical Properties Boiling range: 70 to 100°C Vapour density: Heavier than Air (Air =1) Solubility in water: Binder and solvent are soluble. Inert material is not soluble. Specific gravity (H2O =1): 4-6 Melting point Inert material: >1800°C Evaporation rate: Slower than ether Appearance and odour: White viscous liquid, alcoholic odour.

Exposure / Work Place Controls EH40/2005 Workplace Exposure Limits for substances within the mixture

Substance Long Term (8 hour) TWA

Short Term (15 minutes) TWA

Ethanol 1920 mg/m3 -

Dust (inhalable) 10 mg/m3 -

Dust (respirable) 4 mg/m3 -

Yttrium 1 mg/m3 3 mg/m3

TWA: Time Weighted Average





Stop-flo No2 supplied by Johnson Matthey has been identified as a Yttria based stop-off alternative to Stopyt-62A. It was identified from a literature search and the supplier was contacted to request a sample for a laboratory trial to assess suitability for further work. The supplier has reported that the typical application would be to prevent the flow of filler metal in a brazing application of titanium in a furnace and that the product shelf life would nominally be 6 months. A sample has recently been received from the suppliers and it will be used to undertake initial laboratory printing trials which if successful will allow further trials to be conducted with blades. The initial laboratory trials will assess drying times, a critical property criteria that will be need to be achieved should Stop-flo No2 be taken forward for any further work. If this is successful then a screen printing trial will be conducted on a Trent 1000 blade. Follow on trials will be performed that will include assessment of bake out and heat treatment. If these trials prove successful then additional blades will be manufactured and further trials will be designed.

The process may need to be modified as Stop-flo No2 is completely different in its composition and therefore properties. Where there is a design change, there will be a need for the change to go through the Rolls-Royce Manufacturing Capability Readiness Levels (MCRL). The project plan has been developed with built in relevant stages of MCRL. See project plan in Appendix A to understand how the testing of Stop-flo No2 is scheduled within the overall programme.




The use of Stop-flo No2 would lead to a significant increase in material costs at the current comparable purchase prices of the same quantity for each substance. However, in terms of the overall production costs, this is not a large increase as the quantity consumed per annum is relatively small.

Trials will confirm if the factors such as process manufacturing time, amounts of usage per unit area of application etc. remain the same. On completion of key trials it will be possible to determine the costs of material usage and if applicable, costs for process modification if these are needed.

If technically successful, assessment of the overall economic feasibility for the implementation of the use of Stop-flo No2 will also evaluate if there are any indirect costs such as costs associated with substance supply, maintenance, energy, training, regulatory compliance (including testing and validation to EU standards), water use, cleaning, waste disposal, health and safety etc. Where the costs may indicate the alternative substance is not potentially economically feasible, the assessment will review if there may be any changes that will make it economically feasible. In addition, if there are any pass-through costs to customers or downstream user costs as a result of transfer to an alternative, these will be identified. Any potential liabilities or intangibles such as benefits that can be quantified will be assessed. Furthermore there may be costs associated with the transfer to the new substance e.g. down time and disruption to existing operations which will be evaluated.





Not as yet evaluated. Further work in assessing the reduction of overall risk will be carried out once the outcome of the technical feasibility trials is known. If it is considered to be technically feasible, human health or environmental impacts will be assessed in more detail. The initial review indicates that denatured ethanol within the mixture is registered under REACH and the subject of Classification, Labelling and Packaging of Substances Regulations.



4.3.5 Availability

No problems are anticipated around availability of this alternative. Stop-flo No2 is supplied by a major chemicals manufacturer, Johnson Matthey. The supplier has confirmed the ability to supply in the quantities that may be needed by Rolls Royce in the future.




On the basis of initial findings, Stop-flo No2 is a potential candidate for substitution of Stopy-62A. However, significantly more testing is required to confirm its technical feasibility.




4.4. ALTERNATIVE 4: Stopyt-62G


Table 5: Substance ID and Properties of Stopypt-62G

Functional Aspect Information on Stopypt-62G

General Information

Description of Stopyt-62G and associated technology required to achieve the function of the Stopyt-62A

Stopyt-62G is a feasible substance alternative only (and not an alternative technique or technology). There are currently no significant process changes envisaged to implement this alternative. Stopyt-62G is used as a barrier to the flow of molten metal alloys during brazing (soldering) processes to protect holes and non-braze areas from coverage and clogging. It is supplied by Morgan Technical Ceramics - Wesgo Metals. It is similar to Stopyt-62A, also supplied by Morgan Technical Ceramics - Wesgo Metals, the difference being that Stopyt-62G contains Glycerol instead of DEHP. All the other components and compositions are exactly the same. Glycerol has a similar boiling point to DEHP (DEHP 385

oC / Glycerol 290

oC) which allows for a

similar performance in the bake out process. As Glycerol is a direct substitution for DEHP in Stopyt-62A, details for both glycerol and the overall mixture have been provided below.

Substance ID and Properties (Stopyt-62G)

Chemical Name and Composition Component Concentration (%)

CAS No. EINECS No.

Yttrium Oxide <50 1314-36-9 215-233-5

Isopropyl Alcohol

30-40 67-63-0 200-661-7

Glycerol <10 56-81-5 231-111-4

Methyl Isobutyl Ketone (MIBK, Hexone)

10-20 108-10-1 203-550-1


Labeling requirements under European Union Directive 67/548/EEC consist of the following: Methyl Isobutyl Ketone R11, R20, R36/37, R66, R67 S2, S9, S16, S29, S24-25

Di (2-ethylhexyl) Phthalate T: Toxic R60, R61, S53, S45

Physico-Chemical Properties Appearance: off-white to light pink liquid

Odour: Slight solvent

Flash point data: 52-54oF / 11-12

oC

Data provided directly by supplier from lab tests:

pH: 8

Melting point (mp): 2435°C (solid)

Boiling point: 28-196°C at 1 atm (volatiles), 4300°C (solid)



Auto-ignition temperature: 390-449°C (volatiles)

Flash-point: 12-218°C (volatiles)

Explosion limits: lower and upper 0.3-12.7 % (volatiles)

Dynamic viscosity: 18 cps = 1.8x10-3 Pa-s

Kinematic viscosity: 16.8 cSt=1.68x10-5 m-s

Vapour pressure: 1.3-33 mmHg (volatiles)

Density: 1.07 g/cc

Solubility in water and solvents: 100% (for volatiles) and 0% (for solid)

Exposure / Work Place Controls Component OSHA PEL 8-hr TWA ACGIH TLV 8-hrTWA

Yttrium Oxide 1 mg/m3 1 mg/m3

Isopropyl Alcohol 400 ppm 400 ppm 500 ppm (ceiling)

Glycerol 15 mg/m³ (total dust) 5 mg/m³ (respirable fraction)

10 mg/m³(mist)

Methyl Isobutyl Ketone (MIBK, Hexone)

100 ppm 50 ppm 75 ppm (ceiling)

Substance ID and Properties (Glycerol)

Chemical Name and Composition Glycerol

IUPAC Name Propane-1-2-3-triol

EINECS / EC Number 200-289-5

CAS Number 56-81-5


Classification of the substance or mixture:

Not a hazardous substance or mixture according to Regulation (EC) No. 1272/2008.

This substance is not classified as dangerous according to Directive 67/548/EEC.

Label elements

The product does not need to be labelled in accordance with EC directives or respective national laws.

Physico-Chemical Properties Melting point: 18oC

Boiling point: 149oC at 5.3hPa

Density: 1.262g/cm3 at 25

oC

Vapour pressure: 0.0033hPa at 50oC

Water solubility: 14.4 kPa at 25oC

Flash point: 177oC (open cup)

Auto flammability: 370oC

Flammability: non flammable

Explosive properties: not explosive

No oxidising properties



Viscosity (25oC): 1410 mPa.s

Exposure / Work Place Controls Exposure Limits and guidelines:

Substance OSHA PEL 8-Hr TWA

ACGIH TLV 8-Hr TWA

UK EH40 WEL 8-hr TWA

Glycerol 15 mg/m³ (total dust)

5 mg/m³ (respirable fraction)

10 mg/m³(mist)

10 mg/m³

TWA: Time Weighted Average




Stopyt-62G has been identified from consultation with the existing supplier of Stopyt-62A, Morgan Technical Ceramics - Wesgo Metals Division. The Stopyt product range was originally developed as a braze inhibitor for use in metal welding and brazing operations. It was originally registered as a brand in 1992 and various formulations have been marketed since. The key difference between Stopyt-62A and Stopyt-62G is that in Stopyt-62G, DEHP is replaced with Glycerol as the plasticiser within the mixture. The suppliers reported that the reason that Glycerol was chosen is because it has a similar boiling point to DEHP. The similar boiling points might allow similar performance in the bake out process. The suppliers undertook tests with Glycerol which met their requirements for general metal fabrication customers (but not specifically aero-engine customers) which led to Stopyt-62G being commercialised. Stopyt-62G has a product shelf life of 12 months.

A production trial with Stopyt-62G has been performed with fabrication of a one-off Trent 700 wide-chord fan blade (WCFB), which passed initial evaluation testing and metallographic examination thus demonstrating initial feasibility of this substance. The fabrication of WCFB for Low Cycle Fatigue (LCF) testing is in progress.

In the main the process parameters remain unchanged. There may be a requirement to alter the initial mixing stage as early tests indicate that Stopyt-62G takes longer (up to 20 minutes longer), however it is thought that this could be overcome by revising the mixing technique. Other than that it is understood that the process stages and production times for Stopyt-62A and Stopyt-62G should remain the same.

However, to further confirm suitability, the bake out parameters including temperature of Stopyt-62G will need to be determined prior to any test pieces being produced and an alternative furnace capability is currently being reviewed.

It is considered that the process will be the same as that for Stopyt 62A.




The trials using Stopyt-62G to date have shown that minimal changes to the current production process are necessary and so no capital plant or additional operational costs will be incurred. In addition, the supplier, Morgan Technical Ceramics - Wesgo Metals Division has confirmed that the cost per quart of the alternative is


exactly the same as the existing Stopyt-62A mixture. Nonetheless, a detailed evaluation will be conducted establishing the capital and operating costs (both direct and indirect) for substitution.




The overall risk due to the transition to alternatives is not fully evaluated. As part of the trials, risks associated with the use of the alternative, Stopyt-62G will be identified and assessed against the existing Stopyt-62A. Transition to the alternative will eliminate the presence of the Annex XIV substance, replacing it with non-hazardous glycerol in the same quantity within the mixture as DEHP, thereby reducing both the human health and environmental impacts associated with its use.

A robust risk review exercise will be undertaken as part of the Project Plan that has been developed to achieve product readiness. This will look at human and environmental risks along with those impacting the product.

As part of the risk review process to achieve product readiness, some key risks have been identified associated with technical, environmental, health and safety concerns, with initial actions planned for Stopyt-62G.

Mitigation actions are planned including trials to address some of the risks identified.


There is no confidential information in this section of the report

4.4.5 Availability

Stopyt-62G has been developed by Morgan Technical Ceramics Wesgo Metals, the supplier of the currently used Stopyt-62A specifically to meet demands for a braze inhibitor without DEHP. Glycerol has a similar boiling point to DEHP and as such results in a similar bake out performance.

The availability of Stopyt-62G has been confirmed by the supplier to be the same as that for Stopyt-62A and can be supplied in the quantities required by Rolls-Royce in the future. The product will be imported into the EU by Rolls-Royce.




Based on known information to date, Stopyt-62G is a credible alternative to the currently used Stopyt-62A. This will be confirmed once the programme of testing is complete. Success in any such programme of work is not guaranteed and this is reflected in the timescales mentioned in this document.




5. Overall Conclusions on Suitability and Availability of Possible Alternatives

The substances that have been discounted for technical reasons as alternatives to Stopyt-62A are:

1. GG4400 B2

2. Dag MS-401LR

There is one substance that requires completion of initial investigations to determine if it would be taken forward for further consideration:

3. Stop-flo No2

The substance that has already been taken forward for further consideration is:

4. Stopyt-62G

To summarise the findings based on the information that is currently available, the alternatives to Stopyt-62G have been ranked based on a simple scoring system for each category (if determined to meet the criteria a score of 1 is given, if not determined to meet the criteria, a score of 0 is given). The ranking is based on current data and where there is no information or where assessment has not been undertaken due to the substance being discounted at an early stage, a score of 0 is provided. As such the information provided in Table 6 below is only indicative and may change with the on-going alternatives assessment work that is being carried out.

Table 6: Ranking of Alternative Substances

Alternative Technical Feasibility

Economic Feasibility

Reduction of Overall Risk due to Transition to the Alternative

Availability Total score

Ranking

(1=highest)

1. GG4400 B2 0 1 0 0 1 3

2. Dag MS-401LR

0 0 0 0 0 4

3. Stop-flo No2 1 1 0 1 3 2

4. Stopyt-62G 1 1 1 1 4 1

(Individual Scoring: 1 = acceptable; 0 = unacceptable; Maximum Total Score = 4)

Based on the current understanding of the analysis of alternatives, Stopyt-62G is the strongest option offering the lowest technical risk overall. Stopyt-62G is a potential alternative for Stopyt-62A with few changes envisaged to the process techniques used for its application. The second strongest option is Stop-flo No2 which is less well understood in terms of the technical and economic risks. Stop-flo No2 requires additional testing steps since its composition is significantly different to Stopyt-62A.

Rolls-Royce has developed a project plan for the analysis of alternatives, including tasks that are in progress or planned (See Appendix A). However, it is not intended to progress further testing of Stop-flo No2 unless current tests on Stopyt-62G prove unsuccessful.

Once this work is complete and an alternative has been identified to substitute Stopyt 62A (specifically DEHP), a detailed substitution plan will be developed.

Rolls-Royce attended a Pre-submission Information Session (PSIS) meeting with the European Chemicals Agency (ECHA) on the 14

th November 2012. Following clarification of the processes and guidance on

Application for Authorisation at the PSIS, Rolls-Royce identified that there will be no need to provide a Substitution Plan as a separate report for submission, on the basis that adequate control could be


demonstrated and no qualified substitute exists at the time of submission. It was identified by Rolls-Royce that all actions (including R&D activities) required to develop alternatives will need to be listed, with a timetable for their implementation taking into account investment and the operating costs required. As such the relevant information that is currently available has been provided.

The Substitution Plan to be developed in the future once a qualified alternative has been identified will provide an overview of the alternative assessment; factors that will affect the substitution; actions, timetable and milestones and a monitoring of substitution plan implementation.



6. Appendix A: Project Plan for Alternative Analysis Programme



Rolls-Royce Plc 31 Alternatives Analysis Report for DEHP Use

7. Glossary Annex XIV List of chemicals requiring Authorisation to be used in the EU

ACGIH TLV 8-hrTWA American Conference of Governmental Industrial Hygienists Threshold Limit Values

BGA Butylglycolacetate

CLP Chemicals Labelling and Packaging

CAS Number Chemicals Abstracts Service Registry Numbers

CLP/GHS Classification Classification, labelling and packaging of substances and mixtures

DEHP bis(2-ethylhexyl)phthalate

Dag MS-401LR Yttria based stop-off

EINECS European Inventory of Existing Commercial chemical Substances

EC Number European Commission Number

EH40/2005 Workplace Exposure Limits

EASA European Aviation Safety Agency

ECHA European Chemicals Agency

ETOPS Extended Twin Operations

GG4400 B2 Water based stop-off agent

FOD Foreign object damage

H360 Hazard Statement – May damage fertility or the unborn child

HSE Health and Safety Executive

HCF High cycle fatigue

IUCLID International Uniform Chemical Information Database

IUPAC Name International Union of Pure and Applied Chemistry

LCF Low Cycle Fatigue

MSDS Material Safety Data Sheets

MCRL Manufacturing Capability Readiness Levels

MAC TGG 8 in ppm Maximum Allowable Concentration

NDT Non Destructive Testing

OSHA PEL 8-hr TWA Occupational Safety and Health Administration, permissible exposure limit

OES Occupational Exposure Standard

PSIS Pre-Submission Information Session

REACH Registration, evaluation, authorisation (and restriction) of chemicals

Stopyt-62A Bonding stop-off agent containing DEHP

Stopyt-62G Bonding stop-off agent containing Glycerol

Stop-flo No2 Braze “Stop-off”.

SVHC Substances of Very High Concern

TWA Time weighted average

UK EH40 WEL 8-hr TWA Workplace exposure limits

WCFB Wide-chord fan blade

Rolls-Royce Plc 33 Alternatives Analysis Report for DEHP Use



8. References

ECB 2008. European Union Risk Assessment Report for Bis(2-Ethylhexyl) Phthalate (DEHP). European Chemicals Bureau. 2008.

ECHA 2009. Background document for bis(2-ethylhexyl) phthalate (DEHP). Document developed in the context of ECHA’s first Recommendation for the inclusion of substances in Annex XIV. Report for ECHA. June 2009.

ECHA 2010. Review of New Available Information for bis (2-ethylhexyl) phthalate (DEHP). ECHA. July 2010.

ECHA Guidance on the preparation of an application for authorisation, January 2011, version 1

ECGA 2011. Guidance on the preparation of socio-economic analysis as part of an application for authorisation. Version 1. ECHA. Janaury 2011.

REACH Centrum 2011. The REACH DEHP Consortium Chemical Safety Report for the Registration of bis-2-ethylhexyl phthalate. 2011.

Rolls-Royce 1995. Patent for “Hollow component manufacture”. UK Patent Application GB2289429. Published by the UK Patent Office, London, 22

nd November 1995.

Rolls-Royce 1997. Production process development for the use of Acheson Colloids water based stop-off, GG4400 B2. March 1997.

Rolls-Royce 2011. Rolls-Royce Holdings plc Annual report 2011. Available at http://www.rolls-royce.com/investors/2011yearinreview/. Accessed 28

th September 2012.

Rolls-Royce 2012a. Rolls-Royce in the UK. Available at http://www.rolls-royce.com/careers/where_in_the_world/uk/. Accessed 28

th September 2012.

Rolls-Royce 2012b. Patent for “A diffusion bonded and superplastically formed turbomachine blade”. UK Patent Application GB2486695. Published by the Intellectual Property Office, London, 27

th June 2012.

Rolls-Royce 2013a. Reach Project Plan. February 2013.

Rolls-Royce 2013b. Technical Report on Dag MS-401LR. 2013.



ANALYSIS OF ALTERNATIVES FOR DEHP USE NON-CONFIDENTIAL REPORT

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