By Rich Schulman, Vice President of Quality and ITAR Technology Control Officer and Gerry St. Jean, Manager Audits and Training.
Columbia Tech has, for the fourth year in a row, successfully obtained ITAR re-registration from the Department of State. I’ve been part of the process since the beginning and can offer some insight into the journey, hopefully helping anyone considering taking on export controlled work, to avoid some of the most common obstacles to success.
JULY 2012- PART 1
A) TIPS FOR BEGINNERS
First and foremost
- Top management commitment is crucial; otherwise, you’ll find that the first time you run across a “tough” decision you’ll be tempted to take the easy way out instead of the right way out. We have had total management commitment from the onset which has helped in making our program successful.
- Scalable Security processes are key; as business needs change your security plans / systems must be able to adapt at the same pace.
Hiring a consultant, to help with the Export Control plan and the Technology Control plan, is invaluable. Read as much information on the internet as possible and be sure to read and re-read all correspondence you receive from the US Government. Learn everything you can, from every avenue, about the way the government expects you to conduct business and adhere to it stringently.
- Accuracy is paramount; the US Government is very specific about correspondence. In fact, they are very particular about the entire application process. Dot your I’s and cross your T’s ! The application process, including the form and method of payment, changed in late 2011. Our government now requires companies to wire money or use an automated bank check to pay fees; checks are NO longer accepted.
The first year we applied for re-registration we were ready to submit our application package when we received a letter reminding us that our application was due in 30 days and that a copy of that reminder letter needed to be part of the documentation. When the government states the “documentation should contain the following words”, make sure everything matches 100%. Had we not thoroughly read that reminder letter, we would not have included that document in the package and our application would likely to have been delayed.
B) LEARNING AND TRAINING
We’ve attended numerous seminars on Export Control and have become very diligent at controlling ITAR (Military) and EAR (Commercial with military applicability) shipments. Export Administration Regulations are not as clear cut as ITAR regulations and, as such, require extra attention when learning the “ins” and “outs” of exportation. We’ve learned a great deal in the last several years about each of these programs especially supplier flow-down requirements.
We’ve spent considerable time training our associates on the basics of ITAR and EAR controls and the necessity of protecting our customer’s technical data from unintentional exportation. Associate training has resulted in employees being more watchful and asking more questions. This is a good thing.
C) CONTINUAL IMPROVEMENT
As Columbia Tech began its journey, we designed our system to meet our needs at that time, but as our ITAR business increased we adapted our system to grow along with our ever changing business needs.
As part of our continual improvement process, we focus on improving every business process at Columbia Tech; this applies to ITAR processes as well. As we continue to grow, we scale each process learning more about the specific requirements dictated by our customers, the government, and our own systems. As changes are implemented, we make certain that our associates are educated to the changes too; improvement and education go hand-in-hand with successful transitions. Our ITAR program improves as we comply with our customer’s demands AND with ever changing Government regulations.
More to come about ITAR, EAR and Regulations in Part II