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September 2012

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Mon, 17 Sep 2012 08:47:40 -0500
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words of wisdom?  how about "good luck!"

No one is really ready for the conflict minerals problem, probably never will be.  But just adding a note to the drawing isn't even close to the requirements.  1751 & 1752 have nothing to help, they are vendor qualification profiles, not regulatory compliance.   Compliance can vary from board to board.  

What is basically supposed to happen is your fabrication vendor asks their laminate supplier to ask their foil supplier to ask their foundry to ask their supplier to ask the ore supplier to ask the mine if they are run by warlords.    And everybody duly records and certifies their answers.  Now go through all that with your assembly vendor, solder supplier, component manufacturers......  

My guess?  This regulation only exists because Dodd & Frank wanted to look like they were REALLY, REALLY concerned about suffering in Africa, so rather than actually do something about it, they stuffed this unworkable, unenforceable, and totally ineffective piece of legislation into a spending bill at the 11th hour.  So if it doesn't get repealed any time soon, it's doubtful it will ever find much compliance or any enforcement.

What we've done here is throw it over the wall to our legal department.  They will know FAR better than engineering what we can or should do about it.  They've placed it pretty far down their priority list.

Pete

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