I've recently had a discussion with my companies Export/ITAR department on 
an issue involving the off-site storage of record boxes.  We are looking 
to off-site boxes at one of our international facilities in Germany and 
due to the contents being mixed have no way of knowing whether there is 
Export mandated/ITAR related data in them.  Our ITAR department originally 
said that no boxes containing that type of data could be off-sited without 
being on the export authorization because it was considered a re-export- 
even within country. 

We've held many discussions on remediation and after a consultation with 
the Dept of State have decided that if the boxes are sealed with tamper 
proof tape, audits/controls put in place and some language changes in the 
contract we can move them.  This will be a logistical nightmare as well as 
an expensive proposition and I'm looking to the list for examples that 
either support or diminish the need for these actions.  Has anyone else 
encountered this situation before and if so how did you mitigate it.

They've even gone so far as to say that we may need to seal all boxes sent 
off-site- even within US borders given the fact we can't control foreign 
nationals from having building access where our boxes are stored, as 
vendor employee's.

Any advice/insight given will be appreciated. 

Steven H Petersen CRM / Records Manager 
MS 109-124
Phone: 319-295-5244 / VPN: 295-5244 
[log in to unmask]
www.rockwellcollins.com 


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