Materials Processing Equipment

Technical Advisory Committee

August 7, 2003

# Opening Remarks and introductions

The Chairman called the meeting to order and requested all present to
introduce themselves.

## DEPARTMENT OF COMMERCE

Mr. Matthew S. Borman, Deputy Assistant Secretary for Export
Administration, Department of Commerce (DOC), spoke to the MPETAC about
a new initiative being conducted between DOC and the Department of
Defense (DOD). This followed his noting of appreciation for all of the
time and work that members of the Group provide to assist DOC in their
export control efforts.

Mr. Borman stated that DOC and DOD have agreed to initiate an effort to
conduct a comprehensive review of all Categories and items within the
control list. He commented that they were currently in the process of
structuring that review process and noted that all TACs will have a role
in that effort. He encouraged the MPETAC to provide recommendations to
the review process and noted that Mr. Steven Goldman, Director, Office
of Nonproliferation Controls and Treaty Compliance at DOC, would be the
point of contact for the review and would be contacting the TAC
concerning this effort.

Mr. Bill Root asked if there were any intentions about coordination of
requirements between Categories. He specifically noted that munitions
production export control addressed equipment and offered to send
information on it to the MPETAC.

It was agreed that he should send the information to the MPETAC
Chairman.

Mr. Borman again thanked the Group for their assistance before departing
the meeting.

> **Action Item:** Mr. Bill Root to send information concerning
> munitions production export controls to TAC Chairman.

# Minutes of the March 6, 2003 Meeting

The minutes of the meeting held March 6, 2003 were approved.

# Presentation of Papers or Comments by the Public

Mr. Newman Marsilius III, President of Moore Tool Company provided a
presentation and recommended proposal concerning changes to the
decontrol note of 2B201.b (Note: b) regarding jig grinders. The proposal
addresses a change that would include the words "with axis limited to X,
Y, Z, C, and A where up to only four out of these five axes are
coordinated simultaneously for "contouring control" by the controller."

Following a very informative presentation, the TAC agreed to the general
contents of the proposal, and requested it be submitted to DOC for
review and further action. The recommended proposal is appended as
Attachment A and becomes a part of these minutes. Following a
recommendation from participants at the meeting, it was also agreed that
the presentation provided by Mr. Marsilius be placed on the MPETAC
website.

> **Action:** TAC Chairman to proceed with submitting the jig grinder
> proposal to DOC for review and further action and request placing the
> Moore Tool Company presentation on the MPETAC website.

# REVIEW OF COMMITTEE'S 5-AXIS PROPOSAL

The Chairman reviewed updates to the initial TAC proposal for carve out
of large 5-axis machine tools. He noted that changes were made to the
parameters to restrict movement of the "A" and "B" axis to ± 45°. After
a brief discussion it was agreed that the parameter should read "A and B
rotary axis limited to or less than ± 45 degrees rotation."

During discussions it was noted that there are still concerns about the
ability to manufacture large aircraft components. The TAC commented that
it understood these concerns, but with the newly recommended parameters
it was highly suggested that a review be made to the ability of this
type of a limited capability machine to produce defense critical
components.

Following discussion it was agreed that the proposal be submitted to DOC
for further action. The recommended proposal is appended as Attachment B
and becomes a part of these minutes.

> **Action:** TAC Chairman to proceed with submitting the revised large
> 5-axis machine tool TAC carve-out proposal to DOC for review and
> further action.

# OTHER DISCUSSIONS

## Licensing Procedures

## 

## As with past MPETAC meetings, there was a discussion addressing licensing procedures and the continued issue with the ability of U.S. companies to compete with foreign competitors. The issue discussed in this meeting was, as in the past meeting, how foreign companies are using the disparity in the expedience in issuing licenses to sway customers in not pursuing U.S. products.

Ideas discussed included the creation of a small operating committee
that could address specific types of license requests (i.e. large 5-axis
machine tools and jig grinders) that could fast track them through the
review and approval process. Also discussed was the creation of an
interagency list of questions that a company could use in submitting
requests. The idea being that this would help codify information needed
to help expedite the review of licenses by eliminating or significantly
reducing the continued necessity for further information.

Another idea brought forward was using a favorable consideration note
for processing licenses.

Mr. Goldman commented that often it is not known that a license is
taking a significant amount of time to be processed. This is because the
tracking system used to monitor licensing records "executive order days"
or time, not clock time. That is, it tracks the time a license is active
in review stages. The executive clock stops, for example, when there is
a request for further information. There can be, therefore, a large
difference between the executive clock and the elapsed time in
processing a license.

Mr. Goldman requested that Mr. George Loh perform a study on the ratio
of executive time to clock time for licensing, and determine if licenses
are continually being sent back for additional information. This study
could then be used to support the need for a detailed list of
information required in processing a license and to aid in bringing more
transparency to the licensing process.

> **Action:** Mr. George Loh to perform a study on executive time versus
> actual time and identify if licenses are continually being sent back
> for additional information.

The TAC Chairman commented that it needs to be noted that the issue
before the TAC is the actual amount of time it takes to process a
license in the U.S. versus the time it takes foreign countries to
perform the same task. This ratio of timing is U.S. manufacturers' real
competitive disadvantage.

## Grinders Item 2B201.b

There was a brief discussion on a question concerning 2B201.b.2. This
was a request for further information in understanding if a grinder
containing two contouring rotary axis, with one of those axis restricted
through software to only positioning capability, would need a license.
It was suggested that the Department of Energy would still require a
license, but this question will be transmitted to them for
clarification.

> **Action:** TAC Chairman to request clarification of 2B201.b.2.

### OTHER BUSINESS

It was noted that there was a possible error in the control list item
2B201.a. In recent publications the words "equal to or" may have been
inadvertently added to the item. Mr. Loh stated he was checking into the
issue.

# NEXT MEETING

No date was set for the next meeting.

# ADJOURNMENT

No closed session was held. The committee adjourned at 1:15 p.m.

Attachment A

**Jig Grinder Proposal**

**[August 7, 2003 TAC Meeting]{.underline}**

***Summary:***

Given the nature of jig grinding and the advent of new CNC control
options, we are requesting that BIS review the jig grinder
classification on the Commerce Control List (CCL) -- specifically, we
are requesting a change in the language of the note to paragraph 2B201.b
of the Export Administration Regulations (EAR) as follows:

> **Note:** 2B201.b does not control the following grinding machines:

a.  Cylindrical external ... *(no change)*

b.  Jig grinders with axes limited to X, Y, Z, C, and A where up to only
    four out of these five axes are coordinated simultaneously for
    "contouring control" by the controller; and where C axis is used to
    maintain the grinding wheel normal to the work surface, and the A
    axis is configured to grind barrel cams.

c.  Tool or cutter ... *(no change)*

d.  Crankshaft or camshaft ... *(no change)*

Currently jig grinders have been decontrolled with the X, Y, C, and A
axes operating as four simultaneous axes. In this review, we are asking
that the vertical axis or Z be added to the list of possible axes and
that the customer be given the choice as to which four, but only four,
of these five axes will be simultaneously controlled. A controlled
vertical Z axis is used to increase productivity and/or better control
depths of holes or pockets by eliminating operator intervention.

***Background Information:***

Jig grinders represent technology dating back to the late 1940s when
Richard Moore developed the jig grinder at the Moore Special Tool
Company in Connecticut. NC or CNC controls have been available on jig
grinders since the early 1970s. While the accuracies are very good on
jig grinders (typically 2 µm), the jig grinder's accuracies have not
been improved over the last thirty years and there have been no
essential mechanical changes or improvements to these machines over this
period of time -- only the NC or CNC controllers have been improved.

Over the last ten years, the "vertical housing adjustment" axis (which
was initially a manual axis on early NC or CNC controlled machines) has
been changed to a W-axis in order to reduce setup times, improve
functionality, and also eliminate manufacturing cost. In the Moore Tool
case, this change was initially implemented by creating a new model
(CPW) about ten years ago and replacing the costly "double -- vee" way
design on the column housing subassembly and designing a W-axis using
commercially available linear guideways.

Today all Moore Tool (successor to Moore Special Tool) and other
competitors' jig grinders utilize essentially the same mechanical
structure, but offer different levels of functionality through the CNC
controls. Given the number of machines produced by any one manufacturer
in a given year, manufacturing cost pressures have driven the jig
grinder manufacturers to a single mechanical platform and controlling
the level of functionality through the control and software.

***Jig Grinder Mechanical Architecture:***

All jig grinder manufacturers have the identical mechanical
architecture, although the axes lengths might be slightly different
among the various competitors. All jig grinders have up to six axes of
motion -- X, Y, W, Z, C, and U, plus occasionally an A axis; however,
not all these axes are necessarily under CNC control and some are
parallel axes.

At a minimum, jig grinders use X, Y, C, and U (where U is parallel to X)
axes, which provide a basic level of functionality for grinding holes
and two-dimensional contours. Besides the X and Y axes, which are
similar to all machine tools, jig grinder axis nomenclature is as
follows:

1.  The C axis is a rotary axis used to maintain tool normalcy or
    spindle orientation to the work surface -- typically used for
    grinding holes and two-dimensional contours used in metal stamping
    tools or plastic molds

2.  The vertical axis can be either the W and/or the Z axis. When both
    are present, they are parallel axes. The primary purpose for a
    controlled vertical axis is to facilitate depth control, i.e. the
    bottom grinding of blind (non-through) holes or counter bores (holes
    with two or more diameters). If there is a W axis, it can also be
    used to automatically adjust the position of the jig grinder
    housing/spindle to the proper height over the workpiece for setup,
    which improves the productivity of the machine.

3.  The U axis is parallel to the X axis, and is only used to step
    (position) the grinding head for part sizing control -- the U axis
    is never used simultaneously with other axes

4.  The A axis is an optional rotary axis, typically used to grind
    barrel cams

***CNC Control Architecture:***

All current jig grinder manufacturers only offer their machines with
Fanuc CNC controllers. To the best of our knowledge no other control is
currently used on jig grinder machines; and in Moore Tool's case, we
have exclusively used Fanuc controls for over the last ten years. Please
note that these controls and their related Fanuc axis drives and motors,
are distributed in the US and Europe through the GE Fanuc organization,
a joint venture between these companies.

Fanuc has recently introduced the Fanuc 18*i*-MB control, which Moore is
beginning to implement as our "standard control" on all jig grinder
products, especially for the export market.

The Fanuc 18*i*-MB control will support up to eight (8) axes of motion,
but it has been licensed for all export destinations because it will
only support up to a maximum of any four (4) of these axes
simultaneously. Using the Fanuc 18*i*-MB control, the jig grinder would
only allow up to four simultaneous axes of motion, even though the
machine might have 5, 6 or 7 total axes under CNC control.

If a customer were to order a jig grinder with a more powerful CNC
controller, allowing more than four simultaneous axes of motion, then
this machine would require an export license. For example, a jig grinder
equipped with a GE Fanuc 16*i* control permitting six simultaneous axes
would require licensing approval. Given that Fanuc updates their product
line from time to time, we request that the regulations allow for any
controller models that are of equivalent capability with the Fanuc
18*i*-MB model.

***Capabilities of Jig Grinders:***

Jig grinders are used to precision grind surfaces, typically for metal
stamping and forming tools, plastic injection molds as well as grinding
of various jigs and fixtures. The most common application for jig
grinders today is grinding precision holes.

Over the last twenty-five years, other manufacturing processes, most
significant electro-discharge machining or EDMs, have replaced jig
grinders in many applications. EDMs are capable of achieving jig grinder
levels of precision and require less operator skill, and have become
commonplace. We would expect that twenty-five or more EDMs are sold for
every jig grinder sold today, and there are probably over twenty major
suppliers of EDM equipment worldwide. It is also interesting to note
that EDMs do not require export licensing!

In discussions with various Department of Energy national laboratory
personnel, we have been advised by these industry experts that jig
grinders are not, nor can they be, used to manufacturer components
within nuclear weapons, or to facilitate the manufacturing of such
weapons. Several of these experts have offered to support this statement
in our efforts to minimize export licensing requirement on jig grinders.

Fred Jones of the Y-12 facility, in a letter in June 2001 to Steven
Clagett, supported this position. A copy of Mr. Jones's letter is
available in Adobe Acrobat PDF format and is attached to this request.

**Exhibit A**

**[Foreign Availability]{.underline}**

There are five manufacturers of jig grinders in the world today:

a)  Moore Tool Company -- privately held US company

b)  Hauser -- Switzerland -- part of the Hardinge Grinding Group (US
    owned)

c)  Mitsui Seiki -- Japan -- Toyota is corporate parent

d)  Waida -- Japan -- privately held

e)  Ningjiang Machine Tool Group -- Sichuan, China

Moore and Hauser probably control 75 percent or more of the world market
for jig grinders, which is estimated to be about seventy-five (75)
machines in a normal year. We estimate that less than 25 machines were
sold worldwide last year, with perhaps ten sold in China. The developing
industrial nations -- China, India, Eastern Europe and the former Soviet
block countries -- represent perhaps a 30 percent (and growing) share of
jig grinder market.

Moore Tool has over 150 jig grinders in China today, both manual as well
as CNC controlled machines. These machines have been sold over a
twenty-five year period.

**Exhibit B**

**[Recent Lost Jig Grinder Orders in China]{.underline}**

The following chart summaries Chinese orders that Moore Tool lost to its
Swiss competitor, Hauser, over the last few years -- at least orders
that we know were lost. Please note the number of controlled axes in
each case, and the number of machine equipped with W axes. Also note,
that since 2000, Hauser has been owned by Hardinge -- a US, publicly
traded company.

  --- ---------------------- ------------- ------------- ---------------- --------
      **Name of customer**   **Model of    **Number of   **Number of      **Bid
                             Hauser        Control       simultaneously   date**
                             machine**     axis**        control axis**   

  1   Xi'an Aircraft         S55-W with A  X,Y,W,C,U,A   Any four axis    April
      Industries (Group) LTD axis                        among X,Y,W,C,A  2000
      (CATIC)                                                             

  2   Zhuzhou Carbide Works  S35-Z         X, Y, Z, C, U X, Y, Z, C       August
                                                                          2000

  3   China national south   S55-W         X, Y, W, C, U X, Y, W, C       June
      aero engine Co.                                                     2001
      (CATIC)                                                             

  4   Zhongnan driving       S35-W         X, Y, W, C, U X, Y, W, C       April
      machine factory                                                     2002
      (CATIC)                                                             

  5   Baocheng               S35-W         X, Y, W, C, U X, Y, W, C       June
      Aviation-Electronic                                                 2002
      LTD (CATIC)                                                         

  6   Liaoyuan Aviation      S45-W         X, Y, W, C, U X, Y, W, C       Nov.
      machinery company                                                   2002
      (CATIC)                                                             

  7   Pingyuan electronic    S45-W with A  X,Y,W,C,U,A   Any four axis    Feb.
      optic instrument       axis                        among X,Y,W,C,A  2003
      factory (NORICO)                                                    
  --- ---------------------- ------------- ------------- ---------------- --------

Also note that the last machine Hauser sold to Pingyuan in February 2003
appears to have been equipped with a Fanuc 18*i*-MB control -- any four
axes simultaneous among X, Y, W, C and A.

The source of this information was K.C. Yeung, Moore Tool's Chinese
employee for the last twenty-five years. Mr. Yeung compiled this
information at our request.

Attachment B

WORKING DRAFT

DEPARTMENT OF COMMERCE

DISCUSSION PROPOSAL ON

**5-AXIS MILLING MACHINES**

# Issue

Five-axis milling machines have been considered as one of the most
critical commodities in the Wassenaar Arrangement (WA) List of Dual-Use
Commodities. This has also been true in the control list of the Nuclear
Supplier Group (NSG). In the WA control list, all 5-axis milling
machines are controlled. In the NSG list, because of the unique concerns
of the NSG, only 5-axis milling machines with certain characteristics
are controlled. It is now apparent that countries outside of the WA are
developing the capability to produce 5-axis milling machines and the
United States believes that certain levels of 5-axis milling machines
will soon be available from Taiwan or China. Therefore, the U.S. is
proposing to modify the present control parameters to maintain control
on the most critical machines and, at the same time**,** release many
machines used in the manufacture of aircraft structures. Due to modern
aircraft uses of composites, the military advantage of reduced structure
weight resulting from 5-axis machines has greatly decreased.

Present text

2.B.1.b. Machine tools for milling, having any of the following
characteristics:

1\. Having all of the following:

> a\. Positioning accuracy with \"all compensations available\" equal to
> or less (better) than 4.5 µm according to ISO 230/2 (1997) or national
> equivalents along any linear axis; [and]{.underline}
>
> b\. Three linear axes plus one rotary axis which can be coordinated
> simultaneously for \"contouring control\";
>
> 2\. Five or more axes which can be coordinated simultaneously for
> \"contouring control\"; [or]{.underline}
>
> 3\. A positioning accuracy for jig boring machines, with \"all
> compensations available\", equal to or less (better) than 3.0 µm
> according to ISO 230/2 (1997) or national equivalents along any linear
> axis;

4\. Fly cutting machines, having all of the following characteristics:

a.  Spindle \"run-out\" and \"camming\" less (better) than 0.0004 mm
    TIR;

> [and]{.underline}
>
> b\. Angular deviation of slide movement (yaw, pitch and roll) less
> (better) than 2 seconds of arc, TIR, over 300 mm of travel.

-1-

## Proposed text

2.B.1.b. Machine tools for milling, having any of the following
characteristics:

1\. Having all of the following:

> a\. Positioning accuracy with \"all compensations available\" equal to
> or less (better) than 4.5 µm according to ISO 230/2 (1997) or national
> equivalents along any linear axis; [and]{.underline}
>
> b\. Three linear axes plus one rotary axis which can be coordinated
> simultaneously for \"contouring control\";
>
> 2\. Five or more axes which can be coordinated simultaneously for
> \"contouring control\"; [or]{.underline}
>
> 3\. A positioning accuracy for jig boring machines, with \"all
> compensations available\", equal to or less (better) than 3.0 µm
> according to ISO 230/2 (1997) or national equivalents along any linear
> axis;
>
> 4\. Fly cutting machines, having all of the following characteristics:

a.  Spindle \"run-out\" and \"camming\" less (better) than 0.0004 mm

> TIR; [and]{.underline}

b.  Angular deviation of slide movement (yaw, pitch and roll) less
    (better) than 2 seconds of arc, TIR, over 300 mm of travel.

NOTE: Item 2.B.1.b.2 does not control milling machines having all of the
following characteristics:\
\
1. X-axis travel greater than 2.0 m;\
2. Overall positioning accuracy on the x-axis, with "all compensations
available", greater (worse) than 23 microns according to ISO 230/2
(1997);\
3. A and B rotary axis limited to or less than ± 45 degrees rotation;
and\
4. No C rotary axis.

# Justification

This proposal releases selected general purpose, large, 5-axis milling
machines, particularly those used in the manufacture of aircraft
structures, but maintains under control the machines usable for the
manufacture of quiet propellers and those usable for the manufacture of
smaller items, for example gyros, jet engine components, etc., where the
accuracy is critical.

-2-