Conflict Mineral Smelter Question

[FloridaST]

I'm new to the CMRT and I have three customers asking for us to submit a completed template. We are a contract manufacturer and we purchase the majority of our components through distributors like Mouser and Digi-Key. My main hang-up is with the smelter information. One customer has at least 50 active assemblies with varied BOM sizes amongst them. Is it expected to check every component on every BOM to see who the manufacturer is and then look up what smelters they use? Texas Instruments alone has 240 smelters listed on their template. How do we know which manufacturer uses which smelter?

There will clearly be some repeated manufacturers but this seems like a daunting task for just one person to accomplish. Any tips on how to be effective at this?

 

[Ninja]

I'm no expert in this area, but we simply polled our vendors for their Conflict Minerals statements and consolidated onto ours.

 

[normzone]

It's been a couple of years, but as I recall this is not a game one wins at.

The biggest and most powerful companies (Intel) that work at this at best develop the appearance of trying, and that's after devoting significant resources to it.

Some of the big aerospace players would try to pin us down to specifics, via portals using spreadsheets that locked up if you answered anything incompletely, incorrectly, or in a different format than their programmer anticipated.

Any answer you provide will be wrong, so do as [Ninja] suggests.

 

[FloridaST]

Thank you both for the comments. I assumed this was going to be a nebulous process and the more research I do, the hazier it gets. I found smelter info from most of our distributors - Digi-Key will only point you to the actual suppliers and takes no personal responsibility. Smart if you can get away with it. Thanks!

 

[Ninja]

Digi-Key will only point you to the actual suppliers and takes no personal responsibility. Smart if you can get away with it.

As a pure distributor, they may scoot through a loophole...but unlikely to hold up if their ever audited (though that gets into legal, where I am not qualified).
Conflict minerals is totally a paper game of CYA. Make a big piece of paper (pdf) that covers yours...that's the best I've ever seen happen.
It's a computer file, no one cares if its 265 pages long...if anything, the longer the better...more paper to CYA with.

 

[FloridaST]

As a pure distributor, they may scoot through a loophole...but unlikely to hold up if their ever audited (though that gets into legal, where I am not qualified).
Conflict minerals is totally a paper game of CYA. Make a big piece of paper (pdf) that covers yours...that's the best I've ever seen happen.
It's a computer file, no one cares if its 265 pages long...if anything, the longer the better...more paper to CYA with.

Well heck, you could just copy/paste the entire smelter list and say there you go, it's probably one of these.

 

[Ninja]

Well heck, you could just copy/paste the entire smelter list and say there you go, it's probably one of these.

I'm guessing you are kidding from the smiley at the end...

But all the same, that's EXACTLY what I would do.
Is your company on a mission to be precise with this report to increase profit? Or are you trying to check a necessary checkbox?
I submit you just need to get that box checked...Copy/paste gets it checked at minimized cost of labor...

 

[FloridaST]

I'm guessing you are kidding from the smiley at the end...

But all the same, that's EXACTLY what I would do.
Is your company on a mission to be precise with this report to increase profit? Or are you trying to check a necessary checkbox?
I submit you just need to get that box checked...Copy/paste gets it checked at minimized cost of labor...

I was being a little factious but it's mostly a box checking exercise for our customer but I do want to at least try and be thorough. I'm understaffed and overworked so expediency will likely be the motivating factor.

 

[Randy]

There is no way to absolutely prove 100% what dirt minerals came out of where, do the best you can, have some traceability and go for it....Everyone is on the honor system which we all know works without question.