As if we didn't have enough paperwork to support our day-to-day supply chain concerns, here comes another truck load of documents that may be worth their weight in gold.
I have been thinking about a possible company standard operating procedure for processing and reporting on conflict minerals (CM). In brief, according to the new government mandate, any public company whose products contain gold, tin, tungsten, or tantalum, will have to identify the smelter of origin of these minerals and file an annual report or face potential punitive damages.
So, rather than wait to the last minute (formal reporting begins in 2014) I looked at some of the existing resources to determine if it was reasonable to farm out such a task or handle the effort internally. I can't just ask the internal sales person who works at my electronics parts' distributor if anything I buy from them contains these minerals, but I can determine from material data sheets (MDS) a component's chemical composition down to parts per million.
So, if I can get an MDS for every part on my bill of materials (BOM) and visually or PDF search scan each document for the CM potentials, I can quickly create a pile of candidate parts that will require further due diligence.
My part master or item master data base should allow for including attachments to every part number. Typically, those attachments include such documents as drawings, specifications, product life cycle, PLM information such as product change notices or end-of-life alerts. Now, I need to start gathering the MDS documents for every approved part in my BOM. For that, I will need to contact every part's manufacturer and request the document.
Step one in this procedure is to identify the BOM of immediate interest. Step two is to use the manufacturer's contact information to email in a formal request for the MDS documents. You should have already created a table or form on which you track the OEM's responses by cross-referencing the part's MDS document to the part number. You will discover something rather quickly. Maybe 30 percent of your manufacturers have responded after two to three weeks.
The third step was to record the responses and the forth will be to follow-up with the remaining 70 percent of the slackers. So, let's say after a month or two, you have an MDS document for every part on the BOM. You have sorted through the MDS documents and determined that all of your semiconductors have tin on their leads and gold used for wire bonding.
Your bare-printed circuit card has gold fingers, and the solder used for attaching the electrodes onto your crystals contains tin as well. By the way, all of your tantalum capacitors, have tantalum. Now you are ready to move on.
Step five. You create a mail merge form letter to every one of the manufacturers referencing their part numbers, and in this letter you request an origin smelter report for the raw and processed CM minerals they have purchased from their suppliers. You ask them to specify the authorized smelter name and number. If they cannot do so, you are up a virtual creek without a mining pan.
This absentee return response either means they do not have the internal infrastructure in place to perform such supplier/smelter audit or they are in an information vacuum because they are buying from a supplier and that supplier's supplier is not able to or very slow in sourcing the required information.
You can refuse to do business with them in the future, remove the respective manufacturer's part number from your approved vendor list, and scramble for an alternate source that can produce a smelter reference. Or, you can hire an outside resource that will fill in all of the gaps in your BOM, letting you concentrate on that line-down situation in the factory because some bonehead didn't order enough sole-sourced parts for a build in progress.