Export Control EC

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Export Control (EC) the Nadcap process (rev
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• Report to NMC Plng OPS
• Tuesday, Feb 26, 2008
• Rome Nadcap meeting
• DonB

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EC a lot of activity a lot of attention

• PRI continues to make a concerted effort to
  address all the ramifications of ITAR/EAR/Export
  Control as it relates to the Nadcap process.
  Thanks to Boeing, Goodrich, GE, and
  Lockheed-Martin for extra efforts in this area.
• The number of new Incident Reports written on
  ITAR related issues continues to rise. (30 since
  Pittsburgh mtg Oct 2007)
• PRI Staff Nadcap auditors continuing to be very
  diligent RE all aspects EC.
• (For the purposes of this presentation when we
  mention Export Control, we mean ITAR/EAR License
  Required Technical Data.)

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Where does the industry need improvement?

• As reported initially in the Paris Nadcap meeting
  April 2007 The following are areas which need
  improvement
• Supplier understanding incorporation of Export
  Control polices and practices
• Clear identification of EC requirements
  License Required technical data (restricted)
  status from primes to suppliers to sub tiers
• Continue fool proofing the Nadcap system for EC
• Continuing issue suppliers placing ITAR/EAR
  License Required technical data in eAuditNet.

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Licensing

• Under the current Nadcap EC process, if a
  supplier has License Required technical data
  and PRI does not have an Unrestricted auditor
  available for the audit, the EC License
  Required material is omitted from the audit
• A pilot program has been established to secure
  Technical Assistance Agreements (thru the US
  State Dept) which will enable the individuals
  listed on the TAA (Nadcap auditors PRI Staff
  Engrs) to review EC License Required technical
  data which is listed on the TAA

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Key issue getting license data from suppliers

• The supplier must supply the following data about
  all EC material to PRI for the submittal to
  State Dept
• EC License Required technical data
  material from all primes for all Nadcap
  processes

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Information for TAA

• US Customer Name - company who got the original
  export authorization (e.g. license, license
  exemption or agreement number) to send the
  parts/technical information to you or to your
  customer (in name of foreign country)
• Your Customer Name company who supplied you
  with the parts/technical information (if not the
  US customer).
• Part Number or other unique identification
• Part Description
• Program/Platform Name - list aircraft and/or
  aircraft engine program and where in the aircraft
  and/or aircraft engine the part is located.
• USML Category U.S. Munitions List Category
  (e.g. VIII for aircraft)
• License/License Exemption / Agreement Number /GC
  Retransfer Authorization - We need the number of
  the State Dept license number or license
  exemption (e.g. 126.5 Canadian exemption, if
  applicable) or agreement  (TAA or MLA) number
  which originally approved the export of the ITAR
  parts/technical data to foreign country.

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Incorporation of TAA

• If the supplier (especially sub tier) does not
  have this information (flow down problem) - they
  will have to get it - from their customer (1st
  tier supplier) or from the prime directly (if
  they have direct P.O.)
• Once the TAA process has been initiated, all
  future all Nadcap audits at foreign sources will
  be required to have a TAA license issued by State
  (or equivalent from Commerce if EAR restricted)
  for there to be any auditing of EC material.
  This will be true of both Restricted and
  Unrestricted auditors.
• An incorporation date will be established once we
  have completed the pilot phase of the TAA
  program. This change will be coordinated with/
  communicated to all parties in the Nadcap system
  before being implemented.

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Licensing Progress

• We have 4 suppliers/prime facilities we are
  working with to generate the data necessary for
  the first TAAs
• Thanks to
• Goodrich Landing Gear Ontario Canada
• Goodrich Landing Gear Grosno Poland
• CP Tech Ontario Canada
• Northstar Ontario Canada

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Auditor activity RE Export Control

• We continue to address questions raised by Nadcap
  auditors related to Export Control
• E-mails, conference calls, etc on going as issues
  arise
• New auditor Advisory Dec 14, 2007
• Covered
• EC topics to be covered in opening meeting
• of Nadcap audit
• Technical data - what gets included in eAuditNet
  what does not
• New NIP 7 - 07

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Checklist Project

• Task groups were charged with completing the task
  of identifying any questions with technical
  content which could not be answered on EC
  restricted hardware - by the end of the Rome
  meeting (Feb 2008)
• We are finalizing the exact method to identify
  these questions on the checklists
• Communication to auditors, suppliers, and primes
  will be forthcoming as this is completed

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Data Removal process implemented

• When PRI Staff (normally Staff Engineer)
  recognizes ITAR/EAR data which should not have
  been posted/input into eAuditNet they
• Remove it immediately discard the data
• Raise an Incident Report (via DonB) describing
  what was removed from where in the audit

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Data Removal process implemented

• DonB will investigate the cause establish
  corrective action for the incident
• Once closed copy of the Incident Report will be
  sent to the prime whose material was affected
• Should the prime wish to see the information- or
  get it re input into eAuditNet they will get
  the data from the supplier coordinate with the
  PRI Staff Engr.
• PRI has no system or authorization to keep
  License Required technical data

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Comments Issues Suggestions?

• Contact Don Buehler donb_at_sae.org
• 513-662-5190 or 513-305-7493