Timothy Mitchell, of Belden Communications Division, told us the story,
at http://www.mail-archive.com/edi-l%40listserv.ucop.edu/msg00657.html,
of how one of his customers wants their orders routed through a minority
or woman-owned business (MWOB). Even though his company will actually
be handling the orders, Timothy wants all EDI documents returned to the
customer to appear as if they were coming from the MWOB. Timothy wants
to know if it makes any difference whether his company's DUNS number is
used in the ISA Interchange Header receiver ID, since he's intercepting
the orders on "behalf" of the MWOB.
For those readers unfamiliar with American customs and laws, Congress
intended that government contractors "set-aside" a certain minimum
percentage of sub-contracts for the benefit of companies whose ownership
reflects particular disadvantaged groups. Supposedly, this partially
makes up for the historical business advantages enjoyed by white
Protestant guys with good hair and silver temples and who look swell in
golf pants.
Regardless of the wisdom of such laws, Congress' intent is clear, and
it's our obligation to obey them in good faith. So long as the "MWOB"
is not a dummy shell corporation really controlled by Euro-guys, I
wouldn't think you had anything to worry about when it comes to the ISA.
The interchange and functional groups are merely envelopes used for
routing (regardless that most translators' application logic may be
governed by the ISA sender and receiver), and it's the EDI transactions
contained within that are the legal business documents. Presumably, in
your case, the transaction sets themselves somehow identify the MWOB as
the fulfiller of the order (say, in the N1).
You will often find answers indirectly at FORESIGHT Corporation's
Resources Web-Page, where we have links to dozens of sites containing
viewable Implementation Guidelines or Specifications (ICs or MIGs); see
http://www.foresightcorp.com/ and select "Resources," then "Guidelines,
Maps, and Documents." Besides actual EDI guidelines, there will often
be Trading Partner Agreements and ancillary documentation which you may
find useful in addressing your query.
For example, the FORESIGHT "Guidelines, Maps, and Documents" page points
to GISB, the Gas Industry Standards Board; by navigating from their
guidelines page back to GISB's home page, you can come across the GISB
Requests for Standards page at http://www.gisb.org/req.htm. There's an
entry to "Add a new standard or standards language to the current GISB
Electronic Delivery Mechanism standards. The proposed standards address
the use of ISA (Envelope) Sender Identification codes when sending EDI
files." Detail on the request is at http://www.gisb.org/pdf/r97071.pdf,
where it describes the benefit of the proposed change:
...the sending and receiving parties are clearly identified
using their own common entity codes (per GISB standards) and
are not required to utilize other party's (i.e., the service
requester's) common entity codes in the ISA envelope
surrounding the transmissions.
Certainly the entity who is actually requesting or providing
the service (one who has rights under a contract) must be
identified in the body of the communication [the actual X12
transaction]. Our request goes only to the enveloping and
origination issues.
This language, submitted by a lawyer, would seem to make the case that a
"third-party" service provider could have their own IDs in the ISA
without contaminating the legal content of the X12 transaction sets
contained within. Whether Belden CD can call itself a "third-party"
service provider is another issue, since they're the clear beneficiary
of the order from the customer.
William J. Kammerer
FORESIGHT Corp.
4950 Blazer Memorial Pkwy.
Dublin, OH USA 43017-3305
(614) 791-1600
Visit FORESIGHT Corp. at http://www.foresightcorp.com/
"Commerce for a New World"
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