Procedure for Controlling Transmitted Technical Data - ITAR compliance

[Riverbend]

I have been blessed with the opportunity to find a procedure that is basically one that describes a controlling notation for the tranmission of technical data. This is to be moving toward ITAR compliance. If anyone has crossed this bridge before and would be willing to share, please enlighten me. This subject is outside my 30 yr QA/NDE field of expertise.
Next on this ITAR agenda is to come up with a supply chain questionnaire, so if that puppy happens to be one of your gathering of procedures & policies, it too would be greatly appreciated. We are ISO9001:2000, PED 97/23/EC. AD2000-HPO, ASME "U", National Board "R" and AS9000 certified, and hopefully soon add ITAR & EAR to that list of shingles.

 

[CarolX]

Re: Procedure for controlling transmitted technical data

Can anyone help here?

FYI - ITAR ( International Traffic in Arms Regulations )

 

[Kales Veggie]

Re: Procedure for controlling transmitted technical data

I ran into this US government requirement this week.

The Directorate of Defense Trade Controls of the US Department of State has a website (pmddtc.status.gov) with registration requirements and links to government documents such as CFR $ 120.10.

Has anyone had any experience with ITAR? What is involved in registration? Any ideas to audit compliance with ITAR?

 

[edpaq]

Re: Procedure for controlling transmitted technical data

Hi I am new to this forum and found your thread. If it's not already too late. We will be having our first ITAR audit next week. First time I ever heard of ITAR was about a month ago when I was handed the company ITAR manual and told I was the company ITAR compliance officer. If you don't already know you will have to create a Manual with all the organizational charts, forms, procedures, employee training, and documentation similar to requirements on ISO specs.

You are required to register with The DDTC every two years. Even if you do not export you are required to find out if any of your customers may re-export your product. It even is considered an export if tell somone over the phone who is not a us citizen anything that may be considered information on a "Defense article". If you do not have a license for each individual transaction you and your company may be subject to civil, criminal fines and jail time as well as debarrment.

Start with the Guidelines for DDTC Registered Exporters/manufactures Compliance Program on the DDTC website you mentioned.

Beware of what you think may not be a defense article. The horror stories I am hearing about for so called unlicensed defense articles are unbelivable

Let me know how your doing. Sounds like we are both in the same boat.

 

[jdjobe]

Re: Procedure for controlling transmitted technical data

I just stumbled across this thread...

My boss just walked by and said a potential customer was asking if we were ITAR compliant, and he wanted me to look into it, since neither of us had ever heard of it before.

I've gathered some info from government sites, but the sheer number of documents and links from general information to more general information is making my eyes glaze over. :truce:

Are there any comprehensive sites out there with info about the $/timetable involved in getting registered?

I'm guessing if we're not registered, we're probably not even going to see the quote...am I right?

Thanks!

Jim

 

[edpaq]

Re: Procedure for controlling transmitted technical data

Ok, Be prepared to clear your other duties off of your desk for a while.Try these links http://pmddtc.state.gov/consolidated_itar.htm and http://www.bis.doc.gov/licensing/exportingbasics.htm for a start. I know what you are going through since I was in your situation a few months ago.

Depending on where you fall in will depend on $$ spent. If you are planning on exporting military hardware then the $$$ will be much higher. Don't even think about doing this yourself without the aid of a good consultant who has a background in the ITAR regulations.

The fines are steep and you can find you and your company being debared if you have been found to be in violation.

This is very complex. For example, giving a foreign person, debarred person, or foreign entity, a simple email or having a conversation on something that the government considers having military use would be considered an illegal export.

There is too much to explain here without more details of your products. Find a good counsultant and come back with more specific questions. I'll be glad to help you where I can.

What is it that you are selling?

 

[jdjobe]

Thanks for the reply. I was dancing all around those websites, but your information has helped me to focus things.

My company manufactures printed circuit boards (about 50 people). As I've been told, one of our existing customers does a low percentage of defense contracts, and they wanted us to quote some PCBs for them if we are ITAR compliant.

Of course, they have not yet told us the nature of the bid (1 tiny board or 10,000 big complex ones) so I'm sure that will have the biggest impact on whether we proceed with this or not.

 

[edpaq]

Glad I could help.

As long as your PCB's are in the public domain. That is to say that anyone can buy them and that they are not of military use then you would be OK. However, if these boards can be used to manufacture, say a stun gun or even a cattle prod then it would classify as ITAR controlled.

You are responsible for an "End User Statement" from your customer’s customer to insure that they will not be exported to a "Denied party". Keep in mind that this is also the case with all your customers.

Tread carefully. This has all become a little McCarthyish since 911. Do some more research about your products and make sure none of it falls under "ITAR".

Good luck.

 

[silentrunning]

I probably already know that this is forbidden, but I would like to get confirmation- What if we send material to a foreign country for work on a part that is eventually used in a military application? This would require that we send a print to this foreign country for a quote and processing.

 

[qmslady - 2009]

I have been blessed with the opportunity to find a procedure that is basically one that describes a controlling notation for the tranmission of technical data. This is to be moving toward ITAR compliance. If anyone has crossed this bridge before and would be willing to share, please enlighten me. This subject is outside my 30 yr QA/NDE field of expertise.
Next on this ITAR agenda is to come up with a supply chain questionnaire, so if that puppy happens to be one of your gathering of procedures & policies, it too would be greatly appreciated. We are ISO9001:2000, PED 97/23/EC. AD2000-HPO, ASME "U", National Board "R" and AS9000 certified, and hopefully soon add ITAR & EAR to that list of shingles.

I am attaching what I have...don't know what ITAR stands for, but this is AS9100-2008...will probably show up at the end of the threads because I must post a "reply" in order to attach files...hope it helps you could at least get a feel for it and use it as a template...Ones is for Data set files and two for Supplier Evaluation.
Luck!!
QMSLADY