An Overview of the AD-DSL

The AD-DSL (Aerospace and Defense Declarable Substances List) is a collection of regulated chemicals. It serves as a voluntary resource for companies in the automotive and defense industries to get an overview of their compliance status. In fact, it is not an environmental law.

Who is Responsible for the Aerospace and Defense Declarable Substances List?

The IAEG, the International Aerospace Environmental Group, developed the Aerospace and Defense Declarable Substances List. They are a non-profit organization connecting companies from across the aerospace industry to discuss their common issues in the environmental sector.

Why are Certain Substances Added to the AD-DSL?

The IAEG chooses chemicals that are environmental concerns in the aerospace and defense industries. The main factor is that they are first recognized as threats by other organizations or are candidates for future acts. In addition, the AD-DSL provides regulatory criteria for each chemical to indicate whether they are restricted, declarable or of interest under those previous regulations.

Why was the AD-DSL Developed?

The AD-DSL’s purpose is to unite substances from different regulations in the same document, such as some of the chemicals from the following acts.

EU POP (Persistent Organic Pollutants)
EU REACH (European Union’s regulation on the Registration, Evaluation, Authorisation, and Restriction of Chemicals)
EU RoHS (Restriction of Hazardous Substances)
US TSCA (United States Toxic Substances Control Act)

Keep reading below to find out more about these regulations!

The AD-DSL strives to be a consistent way of communicating with suppliers about compliance. Hence, grouping the chemicals together is meant to simplify the inquiry process. Manufacturers identify any substances from the AD-DSL that are present in their parts and could therefore be dangerous to the environment.

A few Regulations that Overlap the Aerospace and Defense Declarable Substances List

Many regions have laws banning POPs. For example, Europe has Regulation 2019/1021. Organic compounds containing halogens, such as chlorine or bromine, bioaccumulate in humans and animals. Thus, they cause many health problems.
EU REACH focuses on problematic chemicals for the environment and human health. It mandates the declaration of certain chemicals called Substances of Very High Concern (SVHCs) when they appear in parts above a concentration of 0.1%. Furthermore, REACH’s Annex XVII covers unique rules for specific uses of chemicals. For instance, parts with nickel cannot come into direct and prolonged contact with skin.
The aerospace industry is out of scope for RoHS, meaning there is no obligation to comply with the concentration thresholds described in that regulation. Despite this, the RoHS substances are still present in the AD-DSL.
TSCA regulates substances considered to be persistent, bioaccumulative and toxic (PBT). Some compounds have concentration thresholds. However, others are banned, except under exemption conditions. In particular, Phenol, Isopropylated Phosphate (3:1), also known as PIP (3:1), is exempt from the ban when used in new and replacement parts for vehicles within the aerospace and automotive industries. PIP is also allowed in hydraulic fuel for aviation and military purposes when no alternative exists for the U.S. Department of Defense’s safety and performance standards. Similarly to RoHS, PIP is still found on the AD-DSL regardless of these exemptions.

Enviropass can help you assess the AD-DSL in your products. Contact Enviropass for more information on our services.