NMC Export Control Sub-Team - Performance Review Institute

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EXPORT CONTROL GUIDELINES SUB-TEAM
OCTOBER 2013
CONFIRMED
CONFIRMED MINUTES
OCTOBER 23, 2013
PITTSBURGH, PENNSYLVANIA, USA
These minutes are not final until confirmed by the Task Group in writing or by vote at a
subsequent meeting. Information herein does not constitute a communication or recommendation
from the Task Group and shall not be considered as such by any agency.
Wednesday, October 23, 2013
1.0
OPENING COMMENTS
1.1
Call to Order / Quorum Check
The Export Control Guidelines Sub-Team was called to order at 1:05 p.m., 23-Oct-2013.
It was noted that the meeting was restricted to NMC Voting Members only. The following
attendees were invited guests of the Chairperson, Kevin Ward:



Mike Baumann, The Boeing Company
Andrew Caliendo, Sikorsky Aircraft
Martha Hogan-Battisti, The Boeing Company
A quorum was established with the following representatives in attendance:
Subscriber Members/Participants Present (* Indicates Voting Member)
NAME
*
*
*
*
*
*
*
*
*
*
*
*
*
*
Pascal
Richard
Christian
Robert
Scott
Jeff
Frank
Ana
Fabrizio
Mark
Brad
Davide
David
Kevin
COMPANY NAME
Blondet
Blyth
Buck
Custer
Iby
Lott
Mariot
Ottani dos Santos
Quadrini
Rechsteiner
Richwine
Salerno
Soong
Ward
Airbus
Rolls-Royce
SAFRAN
AAA Plating & Inspection
Hamilton Sundstrand (UTAS)
The Boeing Company
Triumph Group
Embraer S.A
AgustaWestland
GE Aviation
Raytheon Company
Alenia Aermacchi S.p.A.
Pratt & Whitney
Goodrich (UTAS)
Baumann
Caliendo
Hogan-Battisti
The Boeing Company
Sikorsky Aircraft
The Boeing Company
Other Attendees
Mike
Andrew
Martha
PRI Staff Present
Scott
Jesse
Jim
Stacey
Christine
Klavon
Lehmier
Lewis
McKinley
Sanz
Committee Chairperson
EXPORT CONTROL GUIDELINES SUB-TEAM
OCTOBER 2013
CONFIRMED
2.0
John
Steffey
GOVERNMENT REGULATIONS
Kevin Ward gave a brief introduction on the topics that would need to be considered during the
meeting. He informed the group that awareness of all government regulations was needed, not
only for ITAR and EAR, but for other countries as well. Please see the attached presentation for a
list of topics to consider regarding government regulations.
Export Control
slide.pptx
3.0
EXPORT CONTROL -2013 COMPLIANCE DISCUSSION
Christine Sanz presented the Performance Review Institute’s (PRI) Export Control -2013
Compliance Discussion. Kevin Ward pointed out that it is important to realize that ITAR/EAR
screenings start with the scheduling department at PRI. Suppliers are asked if they are ITAR/EAR
compliant before their audit is scheduled. It is their responsibility to provide the correct information
to PRI.
“Creation of a technology control plan for purposes of outlining how data exchanged outside of
eAuditNet is to be handled” is an item proposed for review by this committee. This bullet point can
be found on slide nine of the UTC Slides PowerPoint presenation attached below. Christine Sanz
noted that Directorate of Defense Trade Control (DDTC) is the organization that controls ITAR.
PRI has not renewed its registration with DDTC at this time. PRI does not perform defense
services and therefore, the registration is not required. Scott Iby requested that PRI look into the
laws and requirements of DDTC because requirements are constantly changing. Christine Sanz
informed the group that a letter was sent to the DDTC regarding this issue two weeks prior to the
meeting. NMC Subscribers and PRI will need to work together on this issue. For more details
please see the attached presentation.
UTC Slides - .ppt
4.0
BRAINSTORMING
PRI and the NMC will need to find an approach whereby all parties can work together to ensure
compliance with all export control regulations. Kevin Ward noted that a comprehensive plan
would need to be put in place. It is imperative that every step of the program is documented. The
following topics will need to be explored at future meetings.
1. NIP 7-07 – Team Review of document. Particular emphasis on paragraph 3.1 – consider
changing “Export Controlled” to “license required Export Controlled”.
2. Need to provide guidance to Task Groups on whether NLR routers or other NLR technical
data can be uploaded as objective evidence of corrective actions to eAuditNet NCRs without
tagging. Also, even NLR technical data is not permitted to be exported to certain countries, so
should all technical data be excluded from eAuditNet?
3. How does IAQG deal with ITAR? EN 9104-001 Par. 6.11
4. eAuditNet protocol for interim storage of items that were removed from eAuditNet by the staff
engineer for future evaluation.
5. Assemble a prime advisory panel to assist Task Group in determining Export Control
requirements.
EXPORT CONTROL GUIDELINES SUB-TEAM
OCTOBER 2013
CONFIRMED
Export Control NMC Team will be comprised of the following members:







David Soong- Lead
Richard Blyth
Christian Buck
Martha Hogan-Battisti
Scott Iby
Frank Mariott
Mark Rechsteiner
ACTION ITEM: Frank Mariot to add the Export Control NCM Team to the NMC Organizational
Structure chart.
5.0
ADJOURNMENT
Motion made to adjourn and seconded. Motion Passed.
ADJOURNMENT – 23-Oct-2013– Meeting was adjourned at 2:51 p.m.
Minutes Prepared by: Stacey McKinley; smckinley@sae.org
***** For PRI Staff use only: ******
Are procedural/form changes required based on changes/actions approved during this meeting? (select
one)
YES* ☐ NO ☒
*If yes, the following information is required:
Documents requiring revision:
Who is responsible:
Due date:
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