12/15/21, 5:28 PM Developing an ITAR-Compliant Program | Production Machining

3/21/2012
| 2 MINUTE READ

Developing an ITAR-Compliant Program

JOEL PECORARO, PRESIDENT, BUSINESS MANAGEMENT SERVICES

If you want to do business in the defense industry you need to be ITAR (International
Traffic in Arms Regulations) certified. It is expensive and some would say unnecessary, but
it is the law and messing around with that law can be costly. The penalties for not
registering with ITAR are severe. Violations of the rules can result in civil penalties of as
much as $500,000 per violation, and criminal penalties including a $1 million fine per
violation or 10 years imprisonment. Think it can’t happen to you? In May 2011, BAE
Systems paid a $79 million fine for 2,591 violations. While BAE is a high profile case,
hundreds of companies are fined thousands of dollars a year for minor violations.

What defines a defense article? Defense articles include: any item or technical data
designated in the United States Munitions List; an item that has significant military or
intelligence applicability; any modification for a military or defense purpose, no matter
how minor; technical data can include information which is required for the design
development, production, manufacture, assembly, operation, repair, testing, maintenance
or modification of defense articles.

Compliance requires a documented system, and there are numerous areas that need to be
addressed. Here is a listing of the general topics that need to be covered.

Corporate commitment: A compliant ITAR program should clearly identify the corporate
commitment to meeting and maintaining all ITAR guidelines. Specifically, a program should
identify the persons responsible for overseeing the ITAR program, a directive from the
senior company management describing the company commitment to ITAR compliance,
and duties and authorities for key persons who maintain ITAR requirements.

Document control program: The program must address the identification, receipt and
tracking of ITAR controlled items/technical data. The program should include controls over
access, electronic communication, storage, disposal and communication of
information/products to outside sources.

Human resource program: Training and hiring practices need to be clearly defined as they
relate to ITAR controlled items. Your program must clearly define controls over hiring (U.S.
citizens vs. foreign nationals), citizenship verification, training on specific ITAR guidelines
and employee responsibilities relating to ITAR controlled items.

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Internal audit program: Once an ITAR program is developed, an internal audit process
needs to be established to monitor the implementation and effectiveness of the program.
The program should include areas such as auditor training, documentation of audit results,
yearly schedules of audit activities and actions to be taken if violations are noted.

Vendor control program: You may have suppliers/subcontractors involved in the processing
of ITAR controlled items. Are you using suppliers/subcontractors who are capable of
following ITAR guidelines? You should maintain a responsibility to ensure these guidelines
are understood and followed. Your program should ensure suppliers/subcontractors
understand their responsibilities relating to ITAR controlled items, including their
responsibility to limit access to controlled information, how is controlled information
transmitted to the supplier/subcontractor and how will controlled information be
returned/disposed after the contract is complete.

Work environment control program: Limiting access to ITAR controlled items is a required
part of any documented program. Your program should include controls over
visitors/subcontractors who may have access to controlled items, secured access points to
your facility, controls over recording devices (for example, cell phones, cameras) and
secured storage areas for controlled items.

Record maintenance program: Documents define an activity; records are the evidence the
activity took place. Your record control program should include retention periods, secured
storage areas, controls and back-ups for electronic records and storage of records on
personal computers.
 

11/20/2018
| 4 MINUTE READ

Industry 4.0 Careers of the Future

Know a young person considering a career pathway? Encourage him or her to consider these careers.

MATTHEW KIRCHNER
Columnist, Profit 360, LLC

I am a lifelong resident of southeastern Wisconsin, a region chosen last year by the largest
contract manufacturer in the world to build a 20 million square-foot complex (yes, you read
that right, 20,000,000 square feet) that is being billed as the most technologically advanced
manufacturing facility on the planet. Predictions about the impact of this project abound,
but my favorite one is that the Midwest will become the nation’s “Epicenter of Industry 4.0
Technology” bringing with it a host of new career opportunities. One of the lead industrial
engineers working on this transformative project shared some examples with me earlier
this year. 

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12/15/21, 5:28 PM Developing an ITAR-Compliant Program | Production Machining

Thirty years ago, my classmates used to brag about their plans to be doctors, lawyers and
investment bankers. Those were the cool careers. Tomorrow’s “cool” careers may look more
like the following list. Each includes an MKF: My Kid Factor –that is, I would want my kid to
consider this job. The scale is 1-10.

App Developer. As mobile apps become ubiquitous in industrial processes (think

monitoring quality and productivity directly from your smart phone), people possessing
a familiarity with manufacturing combined with the requisite software and
programming skills will find a prosperous future in industry. (MKF 8)
Automation Engineer. These people design, develop and test advanced manufacturing
technology.  Curiously, this occupation is the “4th Happiest Job in America” according to
USA Today, in part I believe because they get to work with really amazing technology
and also because the boss has no idea how they do, what they do so they get left alone at
work. (MKF 9)
Electrical Engineer. Responsible for the electrical aspects of systems, from the device
level (a smart sensor on a machine) to the enterprise level and everything in between,
electrical engineers will be in high demand in an Industry 4.0 economy. (MKF 6)
Industrial Engineer. The purpose of this role is to optimize industrial processes,
reducing bottlenecks, eliminating waste, increasing yield and thereby maximizing
efficiency. As technology on the manufacturing floor has become more complex and
software driven, so too have the aptitudes necessary to be successful in this career.
(MKF 5)
Interface Developer. People who choose this career develop the software and
hardware that connect people to machines and software—think the “HMIs” (Human
Machine Interfaces) common in many industrial facilities. (MKF 8)
Mechanical Engineer. Imhotep is said to have built the Pyramid of Djoser in about
2,630 B.C. dawning the role of the mechanical engineer. No longer designing pyramids
for pharaohs, in an industrial setting their responsibilities might include the planning
and design of mechanical systems and processes, conveyorized and automated material
handling and product transfer systems. (MKF 6)
Production Engineer. The role of the production engineer is similar to that of the
Industrial Engineer though with increased emphasis on the execution of manufacturing
processes.  (MKF 5)
PLC Programmer. Called by some the computer of manufacturing, the programmable
logic controller receives information and turns into output.  For example, a material
handling system on an automated production or processing line is likely controlled by a
PLC, taking an input signal from a sensor that indicates a part is ready to me moved and
sending and output signal to a mechanical lift system to move the part.  PLC
Programmers design these programs, enter them into PLCs and troubleshoot industrial
operations when necessary. (MKF 6)
Quality Engineers. Responsible for overall product quality throughout the supply
chain, quality engineers may also have a role in executing the processes designed by the

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12/15/21, 5:28 PM Developing an ITAR-Compliant Program | Production Machining

test engineer. (MKF 5)

Systems Integrator. Robotics, conveyors, material handling systems, PLCs, industrial
control systems and computer networks and the related software are becoming
inextricably linked in manufacturing, requiring people with knowledge in all of these
capable of making them work in concert. (MKF 9)
Test Engineer. These individuals design and operate the processes and systems used to
ensure product conforms to its specification.  As quality control functions are
performed automatically and in-process, using technologies such as vision systems, 3D
scanning, advanced coordinate measuring machines and tomography, the role of the
test engineer is becoming an increasingly technical and engaging vocation. (MKF 8)

Note that the same engineer who shared these careers with me was asked whether these
would require four-year degrees or would those with associate degrees also be considered.
No offense intended to those with bachelor’s or master’s (myself included), the engineer’s
response was, “A lot of times, the two-year people are smarter than the four-year people.” 

Know a young person considering a career pathway? Encourage him or her to consider

these careers and be open to the possibility that a four-year degree and the debt that may
accompany one is just one of many means to an end. If your career choice has already been
made, prepare for a future of lifelong learning—the only way to ensure your aptitudes
remain relevant and your skills valued in what promises to be a wild ride.

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