Defense contract manufacturing of complex metal assemblies and systems face some of the most stringent regulations and compliance requirements simply because of the nature associated with the components.
The International Traffic in Arms Regulations, commonly known as ITAR, features compliance metrics rooted in legal and operational requirements that any defense contract manufacturing company must adhere to in order to create the metal assemblies and systems needed for U.S. defense programs. ITAR’s control of information associated with the U.S. Munitions List (USML) is vital in properly labeling all aspects of a defense contract manufacturing program.
Industrial Support Inc. details how we navigate through ITAR compliance as a contract manufacturer when creating the parts necessary for defense programs with key points on how to avoid the severe civil and criminal penalties that can be imposed by not following all compliance requirements.
What ITAR Covers in Metal Assemblies and Systems
ITAR compliance measures are associated with three main points in defense contract manufacturing and it all ties back to the USML.
Defense contract manufacturing programs are required to follow ITAR compliance metrics when performing operations on defense articles listed in the USML. These articles contain thorough lists and examples of specific products or systems where ITAR compliance must be followed. Some examples include weapon system housings, armored vehicle components, guided-missile structural parts, specific sensors, and avionics enclosures.
If technical information such as drawings, designs, CAD files, specific process specifications, inspection plans, BOMs, and test results are exposed to a defense contract manufacturer that ties directly into articles in the USML, ITAR compliance must be followed.
And the final coverage of ITAR compliance in defense contract manufacturing falls under any defense services including but not limited to: repair, maintenance, training, or technical assistance regarding items on the USML.
How ITAR Impacts Defense Contract Manufacturing and Manufacturers
Industrial Support Inc. and other defense contract manufacturing companies are impacted by ITAR compliance measures for as long as defense contract manufacturing services are offered. This entails a few different registrations and internal organizational tactics to provide streamlined support, quality, compliance, and record-keeping.
DDTC Registration
As a defense contractor, registration with the State Department’s Directorate of Defense Trade Controls (DDTC) is mandatory. This organization is the group responsible for enforcing ITAR compliance measures along with the Arms Export Control Act. Every manufacturer that’s registered with the DDTC has an internal officer to serve as the main compliance contact.
Internal Compliance Program Set-Up
Once registration with the DDTC has occurred, they require an internal compliance program (ICP) containing written policies and procedures specified to a manufacturer’s operations. Within the ICP also includes employee training that covers USML information including list awareness, technical data controls, and more.
As the DDTC can perform audits of any defense contract manufacturing company, recordkeeping procedures for at least five years are required of registered manufacturers.
Technical Data Controls
When defense contract manufacturing entails metal fabrication and metal shops, this means access to drawings and process documentation is more prevalent and common compared to other forms of manufacturing.
Manufacturers are required to limit access control to this information to authorized individuals only. Labeling of data is required so there are no mistakes made on sensitive or even classified information. And both digital and physical security measures must be in place.
Supply Chain Management
Any organization that comes into contact with an ITAR-compliant project is subject to ITAR compliance measures, and that includes the supply chain. Defense contract manufacturers are required to verify subcontractors and vendors are ITAR registered and can prove compliance with all measures.
Common Manufacturer Failures in ITAR Compliance
With so many measures in place for defense contract manufacturing in ITAR compliance, mistakes still happen and those mistakes can prove to be costly in the form of civil and criminal penalties – the extremes include a $1 million fine, debarment, and even 20 years of imprisonment.
To avoid these costly and harmful penalties, be mindful of these common oversights.
- Assumption of part exemptions because of how they look.
- Never assume, always validate
- Sharing information with offshore suppliers.
- Validate organizations are properly registered with the DDTC and are ITAR compliant.
- Poor data classification
- It is always better to over label information that adheres to ITAR programs.
- Reliance on prime contractor assurances.
- Constantly verify your own compliance status.
Practical Checklist
When selecting a defense contract manufacturing company keep this practical checklist in mind to ensure ITAR compliance is being followed properly.
- Classify products and data so it’s known what pieces fall under the USML.
- Ensure your manufacturer is registered with the DDTC.
- Ensure your manufacturer as a built out or recently refreshed ICP.
- Ask for implementation of technical controls.
- Ask for an audited supply chain record.
Contact Industrial Support Inc. for Defense Contract Manufacturing Operations and Experts in ITAR Compliance
Industrial Support Inc. serves as the contract manufacturing company that OEMs and other large manufacturers and suppliers rely on to create the products they need. We’ve proudly operated out of our Buffalo, New York, facility since 1995 and have served numerous industries with our wide range of metal manufacturing capabilities.
One area we are certainly proud to serve in is as a defense contract manufacturing company. Creating the complex metal assemblies and systems that are used by our nation’s finest is an honor and a privilege, and a massive responsibility to get it right every single time. That’s why we strictly follow and adhere to ITAR compliance measures and are constantly reviewing the USML to ensure our customers – and ourselves – aren’t exposed to extremely severe penalties associated with improper manufacturing.
If your team is searching for a defense contract manufacturing company with an exemplary record in following ITAR compliance, look no further. Contact ISI today and let’s begin the initial review of your program’s needs.