Subject: Comments for Conflict Minerals Rule File No. S7-40-10
From: Susan Pugsley

March 7, 2017

As an Administrative Assistant in the Legal Department of a battery manufacturer [NAICS 335911, 335912], I have been burdened with the task of complying with the regulations of the Conflict Minerals reporting  portion of the Dodd-Frank Act.  I have estimated that it will take me more than 2000 hours to survey our suppliers, review CMRTs for discrepancies and compile data to report to our customers, only to find that I am still unable to accurately trace the minerals back to the smelter level due to the complex and multi-layered network of suppliers.
In order to help us meet the regulations, I have been reaching out to contracting services to assist us in this process.  The quotes that I have received so far are in excess of $25,000/year. 
In addition to the excessive amount of time required and costs associated, the process of Conflict Mineral Reporting  is not effective for the purpose it was intended.    In a recent report from the International Business Times, findings published in August from SEC reports from Tulane University and Assent Compliance found that approximately 90% of the 1262 companies that filed the required conflict mineral disclosures last year said they couldn’t determine whether their products were conflict-free.   Two-Thirds of the companies did not define the country of origin.  Only 24% reached full compliance and 43% failed to disclose how they performed due diligence.   
While I am committed to the purpose of protecting the innocents of the war torn region of the DRC, I feel that my efforts provide little to no benefit for the cause.  Since the process is so burdensome and ineffective, it does not make sense for American businesses to continue the same process with little results.  
If it is deemed that the Dodd-Frank act is essential in limiting crimes surrounding mining in the DRC region, perhaps a less burdensome method of tracking the origin of the conflict minerals could be considered.  From my perspective (as a third or fourth tier supplier) it seems virtually impossible to be able to track the origin of the minerals and the smelters.  It would make much more sense to only require 1st tier suppliers who actually have contacts and relationships with the mines and smelters to report on their usage of 3TG’s. 

Thank you for giving the opportunity to submit comments regarding Conflict Mineral Reporting.  


Susan Pugsley
Administrative Assistant – Contracts/Legal
EaglePicher Technologies, LLC
C & Porter Streets
PO Box 47
Joplin, MO 64802-0047