PCB Newsletter - acid copper plating, ENIG, ENEPIG - Uyemura ...

The Thunder You Hear...Our government has shown a frighteninginability to deal effectively with oureconomy. Yet, in the midst of this malfunction(and occasionally malfeasance),there's something equally insane afoot: aflood of new laws aimed directly at USmanufacturing industries. Ours included.It would be cynical to see this as nothingmore than poorly-conceived job creationfor government employees and consultantsat the expense of US business. Fornow, I want to address the specifics of theregulations on their merit (or lack thereof.)Conflict Minerals – In July 2010, languageon conflict minerals was sneaked into theDodd-Frank bill which regulates the financialindustries. This add-on will costpublicly-held companies throughout theU.S. hundreds of thousands each, as theyattempt to prove that none of the gold, tin,tungsten or tantalum they use is comingfrom a particular distressed area of theCongo.Those of us who sell gold have long beenrequired by DEA to assure that the metal isnot used for laundering drug money. Whatmakes that requirement work, is that it isactually do-able. All plating manufacturers,Uyemura included, have establishedpolicies and procedures to assist in thiseffort. This conflict law is different.Since Uyemura is a world leader in immersiongold chemistry, gold is our primaryconcern, and as written, the Dodd-Frankadd-on is virtually impossible to obey. Thereason is that none of the ore we usecomes directly to the U.S. to be refined,since we are not in the primary smeltingby Don Walshbusiness. (Note: there is one US miningcompany that only handles its own ore).Most gold in the US is sourced from recyclerswho provide highly refined gold fromscrap (jewelry, electronics, teeth, etc.).Manufacturers have beenpressed into service asthe uncompensatedenforcement arm ofgovernment agencies.For years, “conflict gold” was primarilymarketed by Arab brokers to companies inSouth East Asia. How much of that nowfinds itself in recycled scraps in the USmarket? No one knows, and more importantly,no one can know. There is no “goldDNA” and no ability to determine thegeographic origin of this material. Nomatter, though: the law demands thatpublicly-held companies hire teams ofexperts to audit this unknowable at greatexpense. It would be no less effective if weall hired fortune-tellers.Possible good news: a July 28, 2011position letter from Spencer Bachus (Chairof the House Committee on FinancialServices), Gary Miller (Chair of the subcommitteeon International MonetaryPolicy and Trade), Robert Dold (Vice Chairof the same subcommittee), and SteveStivers ( member of the House Committeeon Financial Services). points out that thisbill would be time-consuming and expensiveand requests reasonable modifications,including those applicable torecycled materials.Continued on back cover.