Posted January 18, 2021
Can Your Parts Vendor Meet ITAR Data Security Requirements?
Government regulations help enforce the secure transmission of sensitive data related to national security. A machine shop must be registered in the International Traffic in Arms Regulations (ITAR) to do business in the defense industry. ITAR data security requirements apply to machine shops working on DoD projects and require them to be ITAR registered and compliant. ITAR compliance has numerous benefits to businesses beyond security, but it’s first useful to understand the requirements.
What Are the ITAR Data Security Requirements for Machine Shops?
ITAR is the federal government’s controlling regulations to protect defense-related technologies from being moved, sold, or transferred to foreign countries that may use them against the United States. The regulations apply to components that aren’t generally associated with DoD products. For instance, a simple metal part may qualify as an ITAR-controlled component if used in a military application. Parts initially used for a DoD purpose will always fall under ITAR regulations and control.
Technical data for ITAR-controlled products are also closely regulated, even if they aren’t considered especially sensitive. This includes part designs, CAD files, technical drawings, manufacturing specifications, and even research results relating to the product’s development. All of it needs guarding if it is associated with a defense-related product.
Manufacturers serving defense industry customers assume the responsibility of understanding and adhering to ITAR requirements and related data protection measures. These manufacturers must protect their customers from inadvertently violating ITAR requirements. For example, an engineer may know they need to work with an ITAR-compliant machine shop but not realize how they transfer their data to the vendor for prototype or production work affects their ITAR compliance.
ITAR requirements manufacturers must enact to ensure their customers’ ITAR compliance include:
- Registering with the U.S. Department of State. Any vendor approved to produce defense-related products must be registered with the government as ITAR compliant.
- Identifying all parties in the transaction. Suppose a manufacturer farms out services to third-parties or outsources materials from another vendor. In that case, that information must be included in the project documentation to ensure complete compliance by all parties.
- Using only compliant transfer mechanisms for technical data. Information sent via email or dropboxes that are not ITAR compliant will violate ITAR requirements.
- Ensuring documents have no errors or missing ITAR-compliant information. When sending design data to a manufacturer, engineers should ensure the data is reviewed thoroughly to ensure accuracy before production begins.
To avoid the penalties of violating ITAR requirements, it is incumbent on manufacturers to become ITAR registered before engaging in any defense-related work. It’s also critical for engineers to choose only ITAR-registered parts vendors when deciding which machine shop to prototype or produce defense industry components.
How Does a Machine Shop Become ITAR Registered?
ITAR registration requires the machine shop to file the appropriate forms and pay licensing fees to the Directorate of Defense Trade Controls (DDTC). Once the documents are reviewed and approved, the DDTC will send the machine shop its unique ITAR registration number. Now is when the real work to achieve ITAR compliance begins.
A machine shop must know the regulation requirements and demonstrate that they possess the knowledge and training to be ITAR compliant. Conducting regular internal process audits and ITAR requirement training will pay off toward that goal.
ITAR compliance is more than just holding a registration. Machine shops and their employees must be well-versed in the regulations for protecting both physical and digital sensitive materials and data. These include the handling, movement, and storage of any controlled physical items, materials, or CNC machined parts. There are also logistical and procedural measures for the machine shop implement:
- Information systems: The machine shop must adhere to cybersecurity best practices and utilize next-generation security, including physical security solutions for areas of the facility working on sensitive projects.
- Traceability: The manufacturer must continually monitor and document all access to the network, sensitive data, and the building.
- Testing: Security systems should be regularly tested to ensure their performance.
- Security policy: Documentation of all measures related to the machine shop’s information security policy must be made available to employees.
Ensuring that all employees understand and follow the ITAR requirements is critical for machine shops doing work for the defense department. It’s necessary to protect intellectual data, but there are also expensive fines and jail time involved in ITAR violations. Penalties could permanently discredit a business, and machine shops required to follow ITAR requirements must take every precaution to protect themselves, their clients, and national security.
The Advantages of Working with an ITAR-Compliant Machine Shop
There are several advantages to enlisting the services of an ITAR-registered machine shop—even if your work doesn’t require ITAR compliance. For one, ITAR-compliant machine shops employ a secure transfer method for your design data, greatly reducing the risk associated with your intellectual property.
Secondly, ITAR-registered machine shops are often ISO 9001-certified because the two sets of requirements are similar. Documenting all processes, emphasizing internal training, and monitoring quality control are vital elements in both ITAR registration and ISO 9001 certification. Working with a machine shop that complies with both ensures the work will satisfy your quality requirements.
At Plethora, we take the protection of your critical data seriously. As an ITAR-registered machine shop, our systems and processes utilize industry best practices, and our procedures adhere to the ITAR regulations. Protection of sensitive data occurs throughout our entire organization, from the moment you upload your design through production and shipment. Our ISO 9001 certification combined with our ITAR registration means your parts are manufactured at the highest levels of quality. To get started, you can upload your design files to Quote My Part or call us at 415-726-2256.
The Plethora Team
The Plethora team is your go-to CNC manufacturer for hardware done right the first time. We have the tools and experience needed to create high quality custom parts quickly and with precision, whether you need a prototype or production run.