[amsat-bb] Re: Hopefully - Some ITAR Clarifications.
samudra.haque at gmail.com
Mon Oct 26 14:37:45 PDT 2009
On Mon, Oct 26, 2009 at 5:24 PM, Bill Ress <bill at hsmicrowave.com> wrote:
> But ALL US citizens and foreign permanent residents must be very careful
> about the more sinister part of ITAR called DEEMED EXPORTS. That's where you
> discuss certain ITAR controlled satellite hardware or technology issues with
> a foreign national, with which you do not not have a State Department
> technical exchange agreement, whether this foreign national is in this
> country or you contact them by phone, internet or other forms of
> communication. So while you can work on an AMSAT-NA satellite project that
> has aspects controlled by ITAR, because you are a legal permanent resident,
> you can't email your parents, if they are foreign nationals, to discuss
> those ITAR restricted subjects, whether they are in the US or a foreign
> country. If you do, it is "deemed to be exported" without ITAR approval and
> serious penalties can result.
Yes, I usually take care to divide my correspondence amongst the
particular groups I am working with, and this is also the basis in
which I recently proposed moving to (a) moderated forum (such as
phpBB) or (b) sub-dividing the amsat-bb list into amsat-engineering
(ITAR restricted) and amsat-user (open to all) lists. If moderation is
not possible, practical or simply open to all is the order of the day,
at least we can move the ITAR stuff (development centric stuff) to a
closed list format and ensure what is said and done is always in
compliance (i.e., track of who say what and documents are marked
restricted for circulation) etc.
The AMSAT-BB is the real funny way of becoming ITAR compliant (while
we are under ITAR, lets not forget we have responsibilities) so, until
the day that ITAR is not applicable to us, AMSAT-BB should be
restricted to open questions, user questions etc. no blanket mail
concerning tech details from the US side. However, for the specific
engineering stuff I suggest that whoever administers the list should
consider a security protocol and a secure file area for this
compliance issue, hopefully not on the same machine as amsat-bb to
avoid any chance of overlap.
Sorry if I ruffle a few feathers here, this an important issue for me too !
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