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
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www.rockwellcollins.com
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