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Export Control The purpose of this information is to give suppliers and primes one place to go to see the basic information relevant to Nadcap and Export Control. This is a central location for past communications to suppliers and primes as well as other useful information on the subject of Export Control.General Information IMPORTANT NOTICE: Performance Review Institute has received from the U.S. Department of State a determination that the audit portion of Nadcap audits do not require licensing. This verifies PRI’s contention all along that the Nadcap audit is NOT a defense service. The importance of this is that it verifies the decision taken by PRI to utilize Unrestricted auditors on all audits – whether there are EC-LR/Restricted items (see definition above) or not. Therefore, Unrestricted auditors are allowed access to any data at suppliers, both U.S. and non U.S. suppliers, without any restriction. Restricted auditors (& PRI Staff) still cannot have access to EC-LR/Restricted products & data. Of course, technical data on EC-LR/Restricted items still cannot be input into eAuditNet. If you have any question about this, contact Ericha McLaughlin ericham@sae.org. Definition of EC-LR/Restricted: All Defense Articles and Technical Data controlled by the ITAR; any dual-use or civil items or Technology controlled by the EAR under any ECCN except EAR99. When communications etc. refer to “EC-LR/Restricted” the two categories of controls listed in the definition apply to any/all of these materials, parts, or processes used by suppliers in connection with Nadcap audits.
It is critical for suppliers to have correctly identified any materials which meet this definition and to ensure that only properly licensed materials and information is included in the Nadcap audit. It is Suppliers' and customers' (Prime) responsibility to correctly indentify Export Control status of all products, technical data, and technology in their procession and to properly control it as per applicable regulations. If suppliers do not have this information, they need to contact their customers to secure it.
Supplier Information Suppliers have received a number of important communications on Export Control: 10 Point Plan: The following document is the 10 point plan regarding Export Control processes and procedures. Prime and Supplier email: The following document is the email sent out to all Primes and Suppliers regarding defenition of "defense service" Here are the URLs for the State (ITAR) & Commerce (EAR) http://www.pmddtc.state.gov/regulations_laws/itar_official.html http://www.bis.doc.gov/licensing/exportingbasics.htm
What to Look For
Past Presentations The last presentations made to NMC and SSC are included here: Please Note: Some data in past presentations has been changed or updated. "The Present": Export Control Roundtable power point presentation from the Dallas 2009 meeting. "Culture of Compliance": Export Control Rountable power point/brainstorming presentation from the Dallas 2009 meeting. Answers to questions raised at the Pittsburgh SSC meeting (Posted August 7, 2008) EC Roundtable presentation July 24, 2008 Pittsburgh SSC presentation July 22, 2008 NMC Planning & Ops presentation July 22, 2008 Rome NMC presentation Feb 26, 2008 For more Information on Export Control Go to our Frequently Asked Questions page and click on the Export Control Link. |
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