February 2, 2017
Vermillion is directly exempt from having to report on this information as a result of its private, small business status. Unfortunately, the majority of our customers, like Boeing, Rockwell Collins, and Northrop Grumman are required to report on this. As a result they flow this requirement down to Vermillion, and further require us to create a report that is only specific to the products we manufacture and sell to them. As primarily a build-to-print manufacturer, we have very little to no impact on the products that are designed into the aerospace and defense platforms we support, however are being required to attempt to trace back to the raw materials of those same items. Most of our suppliers are larger organizations than ourselves, and many of them are required to report the information directly to the SEC anyways, therefore it creates undue burden on our small business to duplicate these efforts. I am of the opinion that the organizations that directly do business with the smelters should be required to report the information directly to the government, versus placing the burden back on many small businesses by requiring any SEC filing organization to file a report. Additionally, the burden could be placed on anyone directly importing the material, etc. Just a thought.