For some of you, EAR/ITAR may be directed primarily at computer hardware
and software, but that is not nearly the majority of covered items, so
don't breathe that sigh of relief until you have read the
"controlled" lists. EAR alone has the following
categories:
0-Nuclear Materials, Facilities and Equipment and Miscellaneous
1-Materials, Chemicals, "Microorganisms," and Toxins
2-Materials Processing
3-Electronics
4-Computers
5-Telecommunications and Information Security
6-Lasers and Sensors
7-Navigation and Avionics
8-Marine
9-Propulsion Systems, Space Vehicles and Related Equipment
A caveat here for those who might focus on the term
"sales." EAR and ITAR also cover services - some
examples, dual use software development where the stated service,
contractually, is to assist with or provide software development for a
non-military use and the software can actually be used in a weapons
guidance or targeting system; developing certain micro components for a
foreign held electronics corporation; a genetically enginered organism or
plant (and the methods used for the engineering); a pathogenic
microorganism and/or its toxin(s). (If you have ever had your
doctor tell you you have a "Staph" infection, you may have been
harboring an export controlled organism in your wound...
interesting concept.) So, if your institution is working with a
foreign sponsor, sales or services, carefully consider export control
issues. Your medical or agricultural schools may be as affected by
export control as your physics, Mathematics, engineering and computer
science schools.
Rosemary
At 08:28 PM 10/18/2002 -0400, you wrote:
I would agree with what Rosemary
says here. However, subject/products of most of our grants and
contracts do not go beyond the US boarders directly or indirectly in
terms of tangible materials. Most of the ITARS and EARS are
directed at direct/indirect sales of hardware and software to overseas
entities (indirect here being through a 3rd party sale).
Greg
Rosemary H. Ruff
Office of the Vice President for Research
Associate Director
Review and Compliance
Phone (334) 844-5965
FAX (334) 844-4391