Aerospace industries have been significantly affected by the enormous growth in environmental and community noise regulations passed primarily in the United States and Europe since the 1970s. Legislation such as the Clean Water Act, the Clean Air Act and the Resource Conservation and Recovery Act in the United States and companion Directives in the European Union have resulted in voluminous local regulations to meet environmental quality objectives. These regulations typically enforce the use of best available technology, whether new materials or processes or end of stack control equipment. Additionally, universal issues such as ozone depletion and global warming are forcing changes to traditional operations by banning chemicals such as chlorofluorocarbons entirely unless exceptional conditions exist.

Early legislation had little impact on aerospace operations until the 1980s. The continued growth of the industry and the concentration of operations around airports and industrialized areas made regulation attractive. The industry underwent a revolution in terms of programmes required to track and manage toxic emissions to the environment with the intent to ensure safety. Wastewater treatment from metal finishing and aircraft maintenance became standard at all large facilities. Hazardous waste segregation, classification, manifesting and, later, treatment prior to disposal were instituted where rudimentary programmes had previously existed. Clean-up programmes at disposal sites became major economic issues for many companies as costs rose to many millions at each site. In the later 1980s and early 1990s, air emissions, which constitute as much as 80% or more of the total emissions from aircraft manufacturing and operation, became the focus of regulation. The International Civil Aviation Organization (ICAO) adopted engine emission standards as early as 1981 (ICAO 1981).

Chemical emissions regulations affect essentially all chemical processing, engine and auxiliary power unit, fuelling and ground service vehicle operations. In Los Angeles, for example, ground-level ozone and carbon monoxide reductions to achieve Clean Air Act standards could require a reduction of 50% of flight operations at Los Angeles International Airport by the year 2005 (Donoghue 1994). Emissions there will be tracked daily to ensure limits on total emissions of volatile organic compounds and carbon monoxide are below the overall total permitted. In Sweden, a tax has been levied on aircraft carbon dioxide emissions due to their global warming potential. Similar regulations in some regions have resulted in a near total elimination of vapour degreasing using chlorinated solvents such as trichloroethane due to the historically high levels of emissions from open-topped degreasers and the ozone depleting potential and toxicity of 1,1,1 trichloroethane.

Perhaps the most broad-based regulation yet imposed is the Aerospace National Emission Standard for Hazardous Air Pollutants (NESHAP) of 1995, promulgated by the United States Environmental Protection Agency under the Clean Air Act Amendments of 1990. This regulation requires all aerospace operations to comply with the average of the best 12% of the current United States control practices to reduce the emission of pollutants from the processes of greatest emissions. The standard requires compliance by September 1998. The processes and materials most affected are manual wipe and flush cleaning, primers and topcoats, paint removal and chemical milling maskants. The regulation allows process change or control and charges local authorities with enforcement of material, equipment, work practice and record-keeping requirements. The significance of these rules is the imposition of the best practices with little regard to cost on every aerospace manufacturer. They force a comprehensive change to low vapour pressure solvent cleaning materials and to coatings low in solvent content, as well as application equipment technology as shown in table 1. Some exceptions were made where product safety or personnel safety (due to fire hazard and so on) would be compromised.

Table 1. Summary of the United States NESHAP in manufacturing and reworking facilities.

¹ Considerable record keeping, inspection and other requirements apply, not listed here.

² Volatile organic compounds. These have been shown to be photochemical reactive and precursors to ground-level ozone formation.

³ Hazardous air pollutants. These are 189 compounds listed by the US Environmental Protection Agency as toxic.

⁴ Listed equipment includes electrostatic or high-volume, low-pressure (HVLP) spray guns.

⁵ Specialty coatings and other low-emission processes excluded.

⁶ Touch-up allowed using 26 gallons per aircraft per year of HAP-containing remover (commercial), or 50 gallons per year (military).

Source: US EPA Regulation: 40 CFR Part 63.

Summaries of typical chemical hazards and emission-control practices due to the impact of environmental regulations on manufacturing and maintenance operations in the United States are provided in table 2 and table 3 respectively. European regulations have for the most part not kept pace in the area of toxic air emissions, but have placed greater emphasis on the elimination of toxins, such as cadmium, from the products and the accelerated phase-out of ozone depleter compounds. The Netherlands require operators to justify the use of cadmium as essential for flight safety, for example.

Table 2. Typical chemical hazards of manufacturing processes.

Table 3. Typical emission-control practices.

¹ Most aerospace facilities are required to own an industrial wastewater pretreatment facility.   Some may have full treatment.

² Control efficiency usually must be greater than 95% removal/destruction of incoming concentrations.  Commonly 98% or greater is achieved by activated carbon or thermal oxidation units.

³ Strict regulations on landfilling specify treatment and landfill construction and monitoring.

⁴ Toxicity is measured by bioassay and/or leaching tests designed to predict results in solid waste landfills.

⁵ Usually filtered paint booths. Work done out of sequence or touch up, etc. is usually exempt due to practical considerations.

Noise regulations have followed a similar course. The United States Federal Aviation Administration and the International Civil Aviation Organization have set aggressive targets for the improvement of jet engine noise reduction (e.g., the United States Airport Noise and Capacity Act of 1990). Airlines are faced with the option of replacing older aircraft such as the Boeing 727 or McDonnell Douglas DC-9 (Stage 2 aircraft as defined by the ICAO) with new generation airplanes, re-engining or retrofitting these aircraft with “hush” kits. Elimination of noisy Stage 2 aircraft is mandated by 31 December 1999 in the United States, when Stage 3 rules take effect.

Another hazard posed by aerospace operation is the threat of falling debris. Items such as waste, aircraft parts and satellites descend with varying degrees of frequency. The most common in terms of frequency is the so-called blue ice which results when leaking toilet system drains allow waste to freeze outside the aircraft and then separate and fall. Aviation authorities are considering rules to require additional inspection and correction of leaking drains. Other hazards such as satellite debris may occasionally be hazardous (e.g., radioactive instruments or power sources), but present extremely low risk to the public.

Most companies have formed organizations to address emission reduction. Goals for environmental performance are established and policies are in place. Management of the permits, safe material handling and transportation, disposal and treatment require engineers, technicians and administrators.

Environmental engineers, chemical engineers and others are employed as researchers and administrators. In addition, programmes exist to help remove the source of chemical and noise emissions within the design or the process.

Back