ITAR Requirements and Visitor Screening

[mlaurie]

Does anyone have any practical experience with screening visitors that are foreign nationals?
How do I meet ITAR requirements if I don?t inquire and document the nationality of visitor to our facility?
Thanks for any input
Mike

 

[John Broomfield]

Re: ITAR Requirements and Visitors

mlaurie,

Indeed. Verifying nationality without insisting that your visitors bring their passports in pretty well impossible.

You could escort all visitors until such verifications are completed for the frequent visitors.

John

 

[mlaurie]

Thanks John. I thought of a visitor sign in sheet with a US Citizen check box. That may show due diligence and promote some awareness.

 

[John Broomfield]

mlaurie,

Many ITAR compliance seeking organizations do this.

But you can guess the question I would ask as the auditor!

John

 

[JLyt207]

Don't forget, it isn't just nationality you should be concerned with verifying. You also need to check against government denied party and debarred lists.
Two months ago we started using a system from Lobbyguard. It is working OK so far. It checks against the government lists, keeps records, and prints out badges that are red if not a US person.
I also would use caution with visitor logs. I hear auditors love them. It is a great place to find non-conformances.
(Note: I am not associated with Lobbyguard)

 

[FMS-Steve]

Hi Mike

We just went through our AS9100 audit, I was told your visitors must show Birth Certificate or a Valid Passport. You must get these prior their visit so you can verify the background checks.

 

[John Broomfield]

Even if accompanied by an employee?

 

[FMS-Steve]

Yes even on a tour, driver's license can be duplicated so easy these days. We had a welcome book said are you a US Citizen Yes / No our auditor said not enough. You must present a passport number or a birth certificate.

 

[soc1214]

Steve,

What qualifications does your AS9100 auditor have with the ITAR?


Our auditor tried the same line with me, and when I pulled out the ITAR, he could not find anywhere the requirement that a Birth Certificate or Passport was a requirement to be verified.

 

[Big Jim]

Hi Mike

We just went through our AS9100 audit, I was told your visitors must show Birth Certificate or a Valid Passport. You must get these prior their visit so you can verify the background checks.

Your auditor is off at least a little. Citizenship is not required. A US person includes anyone with a green card.