This is a follow-up post from “Dodd Frank Conflict Minerals Law: Headache for Metal Supply Chains,” published last week.
For expert commentary on metals impacted by Section 1502 of the Dodd-Frank financial reform law — the so-called conflict minerals law — we contacted Michael Pfeifer, president of Industrial Metallurgists, LLC, which provides learning and courseware around material engineering and material training.
Mike has 20 years of experience as an engineer in product development and manufacturing.
We asked Mike to help us better understand the role of MSDS (material safety data sheets) in identifying materials that might fall under the conflict minerals rules. Mike reminded us that MSDS sheets do not serve as the “controlling document.”
In other words, MSDS sheets identify maximum limit impurities. For specific material analysis, “one should rely upon ASTM specifications or standards from other countries such as DIN, JIS, EN, etc.,” he said.
“When one sees the words ‘minimum limit’ the interpretation suggests ‘alloying element’ and therefore that material could fall under Section 1502 requirements,” Mike continued.
Mike went on to say, “the word ‘range’ also implies ‘alloying element,’” which would also fall under the rules. The term “maximum limit,” on the other hand, refers to an impurity and therefore does not get purposefully added to the melt.
These distinctions matter when determining at the part/SKU level whether something falls under the rules.
MetalMiner will continue to publish information and analysis on semi-finished metal forms impacted by Dodd-Frank. We will also explore some industry frameworks, tools and templates as they relate to compliance efforts.