IG-00-048

AUDIT

REPORT CONTRACTOR EXPORTS OF

CONTROLLED TECHNOLOGIES

September 19, 2000

National Aeronautics and

Space Administration

OFFICE OF INSPECTOR GENERAL
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Acronyms

EAA Export Administration Act

EAR Export Administration Regulations

ECP Export Control Program

GAO General Accounting Office

ISS International Space Station

ITAR International Traffic in Arms Regulations

NPD NASA Policy Directive

NPG NASA Procedures and Guidelines

OIG Office of Inspector General
W September 19, 2000

TO: A/Administrator

FROM: W/Inspector General

SUBJECT: INFORMATION: Contractor Exports of Controlled Technologies

Assignment Number A9903301

Report Number IG-00-048

The NASA Office of Inspector General has completed an audit of Contractor Exports1 of

Controlled Technologies. We found that two of the three major NASA contractors2 that we

reviewed, TRW Space and Electronics Group (TRW) and Lockheed-Martin Michoud Space

Systems (Lockheed-Martin), have adequate export control programs in place to ensure that

exports of controlled technologies are effected in compliance with applicable laws and

regulations. TRW and Lockheed-Martin have (1) developed effective export control policies,

(2) established export control training programs, and (3) maintained required export records

that were readily available for review. The third contractor, Boeing Space and Communications

Group (Boeing) may not have complied with applicable export laws and regulations when

exporting controlled items on behalf of the International Space Station (ISS) Program.

Specifically, Boeing was unable to readily produce records related to exports of controlled

technologies. Further, on two of the six3 NASA-obtained export licenses related to the ISS,

Boeing potentially effected exports of controlled technologies beyond the scope of the licenses.

NASA, therefore, lacks assurance that Boeing's export activities on behalf of the Agency for the

ISS Program are being performed in full compliance with applicable export laws and

regulations.

Background

NASA's international activities often involve the transfer of commodities, software, or

technologies to foreign partners not only by NASA, but also by its contractors.4 The

 

1

 Exports are transfers of any commodities, software, or technologies to foreign entities and include items

such as flight hardware and software, propulsion systems, and spacecraft systems and associated

equipment.

2

 See Appendix E for details on the specific contracts selected for review.

3

 For the ISS Program, Boeing has effected exports against a total of five NASA-obtained export licenses

and one special comprehensive license (see details on this type of license in footnote 14).

4

 See Appendix C for situations in which controlled technologies are exported in support of NASA

programs.
2

transfers are generally subject to export control laws and regulations, regardless of whether they

occur in the United States, overseas, or in space. Export controls are imposed on such

transfers and activities in order to protect the national security and to further U.S. foreign policy

objectives.

In 1995, NASA established an Export Control Program (ECP). The “NASA Export Control

Program” pamphlet, dated November 1995 (revised October 1998), establishes policies and

procedures on an Agency-wide basis to ensure that NASA’s exports and transfers to foreign

parties and international activities are consistent with the requirements of the Department of

State's, International Traffic in Arms Regulations (ITAR) and the Department of Commerce's,

Export Administration Regulations (EAR). NASA contractors are responsible for following the

same U.S. export laws and regulations.

Recommendations

We recommended that management require Boeing to establish an appropriate export control

program and a detailed company-wide export policy that comply with all EAR requirements

prior to authorizing Boeing to utilize NASA-obtained export licenses on behalf of the ISS

program. We also recommended that management direct the ISS Program Office, in

coordination with the Center Export Administrator, to periodically review Boeing's and its

subcontractors' export control programs to ensure that exports effected against NASAobtained licenses in support of the ISS Program are being accomplished in accordance with

applicable U.S. export laws and regulations.

Management's Response

Management concurred with the recommendations and provided comments on our finding (see

Appendix H). Management questioned whether some of the examples detailed in the report

were in fact export violations. We reaffirm our position that the examples of export shipments

detailed in the report could represent possible export violations because of the disparities in

explanations provided by management and the inconsistencies in the available supporting

documentation. Our detailed response to management's comments is in

Appendix I of the report.

[original signed by]

Roberta L. Gross

Enclosure

 Final Report on Audit of Contractor Exports of Controlled Technologies
FINAL REPORT

AUDIT OF CONTRACTOR EXPORTS OF

CONTROLLED TECHNOLOGIES 
W September 19, 2000

TO: I/Associate Administrator for External Relations

AA/Director, Lyndon B. Johnson Space Center

FROM: W/Assistant Inspector General for Auditing

SUBJECT: Final Report on Audit of Contractor Exports of Controlled Technologies

Assignment Number A9903301

Report Number IG-00-048

The subject final report is provided for your information and use. Our evaluation of your

response is incorporated into the body of the report and into Appendix I. The corrective actions

planned for the recommendations are responsive. The recommendations will remain open for

reporting purposes until corrective actions are completed. Please notify us when action has been

completed on the recommendations, including the extent of testing performed to ensure corrective

actions are effective.

If you have questions concerning the report, please contact Mr. Kevin J. Carson, Program

Director, Safety and Technology Audits, at (301) 286-0498, or Mr. Timothy L. Bailey, Auditorin-Charge, at (301) 286-3355. We appreciate the courtesies extended to the audit staff. The

final report distribution is in Appendix J.

[original signed by]

Russell A. Rau

Enclosure
2

cc:

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

H/Associate Administrator for Procurement

JM/Acting Director, Management Assessment Division

M/Associate Administrator for Space Flight

Y/Associate Administrator for Earth Science

100/Director, Goddard Space Flight Center

DA01/Director, Marshall Space Flight Center
NASA Office of Inspector General

IG-00-048 September 19, 2000

 A9903301

Contractor Exports of Controlled Technologies

Introduction

The NASA Office of Inspector General (OIG) has completed an audit of Contractor Exports of

Controlled Technologies, which we conducted as part of the overall audit of Contractor Control

of Sensitive Technologies (controlled technologies). This report is the second and final report

on the audit.5 The audit objective discussed in this report was to determine whether major

contractors have established adequate controls over NASA's controlled technologies to

preclude unauthorized or unlicensed exports.

The majority of exports are governed and controlled by either the Office of Defense Trade

Controls at the Department of State or the Bureau of Export Administration at the Department

of Commerce. The Bureau's EAR state that when an export license is issued to a particular

person or entity, that person or entity becomes the licensee. The licensee is accountable for the

use of the license, whether as a principal (exporting for own account) or as an agent. The

licensee assumes responsibility for effecting the export and appropriately using the license and

for due performance of all of the license's terms and conditions.

Appendix A contains further details on the audit objectives, scope, and methodology.

Results in Brief

Two of the three major NASA contractors that we reviewed, TRW and Lockheed-Martin,

have adequate export control programs in place to ensure that exports of controlled

technologies are effected in compliance with applicable laws and regulations. TRW and

Lockheed-Martin have (1) developed effective export control policies, (2) established export

control training programs, and (3) maintained required export records that were readily

available for review. The third contractor, Boeing, needs to improve its export control program

in order to prevent the potential unauthorized or unlicensed transfers of controlled technologies

related to NASA's ISS Program. NASA, therefore, lacks assurance that Boeing's export

activities on behalf of the Agency for the ISS Program are being performed in full compliance

with applicable export laws and regulations.

 

5

 The results of the first audit are discussed in Audit Report IG-00-018, "NASA Oversight of Contractor

Exports of Controlled Technologies," March 23, 2000 (see Appendix B for details).
2

Background

NASA's international activities often involve the transfer of commodities, software, or

technologies to foreign partners not only by NASA, but also by its contractors.6 The transfers

are generally subject to export control laws and regulations, regardless of whether they occur in

the United States, overseas, or in space. Export controls are imposed on such transfers and

activities in order to protect the national security and to further U.S. foreign policy objectives.

The Department of State's Office of Defense Trade Controls is responsible for controlling items

identified on the U.S. Munitions List7 pursuant to the International Traffic in Arms Regulations

(ITAR).8 The Commerce Department's Bureau of Export Administration controls items that are

identified on the Commerce Control List9 pursuant to the EAR.10

Appendix D contains further details on the U.S. Munitions List and Commerce Control List.

NASA's Office of External Relations has overall Agency responsibility for ensuring the

compliance of all NASA program activities and exports with U.S. export control laws and

regulations. NASA Center Directors are responsible for appointing a Center Export

Administrator to ensure full compliance of all Center program activities with applicable export

laws and regulations.

The NASA ECP establishes policies and procedures on an Agency-wide basis to ensure that

NASA’s exports and transfers to foreign parties and international activities are consistent with

the requirements of the ITAR and EAR. NASA contractors are responsible for following the

same U.S. export laws and regulations. An essential part of the ECP is the establishment of

mechanisms within the Agency (including the Centers) that provide checks and safeguards at

key steps in program development and implementation, helping to better manage international

program initiatives. Such oversight helps to ensure that NASA export personnel ask the right

questions to preclude NASA officials and contractors from effecting transfers that may be

contrary to U.S. export controls or that may be inconsistent with requirements of the ITAR and

EAR.

 

6

 See Appendix C for situations in which controlled technologies are exported in support of NASA

programs.

7

 U.S. Munitions List, April 1999, identifies items designated by the President to be defense articles and

services.

8

 The ITAR provide guidance for controlling the export and import of defense articles and services.

9

 The Commerce Control List, October 1999, identifies “dual-use” items that have military/strategic and civil

applications.

10 The EAR implement the export and re-export requirements of the Export Administration Act (EAA) of

1979, as amended (Note: Although the EAA expired in September 1990; the provisions of the EAR are

continued under the authorities of the International Emergency Economic Powers Act, which states “the

administration of section 38 (e) of the Arms Export Control Act (22 U.S.C. 2778 (e) shall remain in full force

and effect until amended or revoked under proper authority.”)
3

Contractor Exports of Controlled Technologies

Finding. Boeing may not have complied with applicable export laws and regulations when

exporting controlled items on behalf of the ISS Program. Specifically, Boeing was unable to

readily produce records related to exports of controlled technologies. Further, on two of the

six11 NASA-obtained export licenses related to the ISS, Boeing potentially effected exports of

controlled technologies beyond the scope of the licenses. This condition exists because Boeing

did not have effective company policies in place with regard to exports. In addition, NASA

does not provide oversight of Boeing's export control program, even though NASA is the

licensee for several ISS-related export licenses. As a result, exports of controlled technologies

by Boeing in support of the ISS Program have been effected in potential noncompliance with

U.S. export laws and regulations.

ISS Contract Requirements

NASA's ISS contract (NAS15-10000) with Boeing, Clause H.5, "Export of Technical Data,

Computer Software, or Hardware in the Conduct of Space Station Related Activities," states:

When such a need arises, NASA may exercise the applicable

exemptions, general licenses, existing NASA export licenses or other

approvals available to a Federal agency under the U.S. export control

laws, and may effect the export of such technical data, computer

software, or hardware provided for NASA by direction to the

contractor. When directed in writing by the Contracting Officer, or

designated representative, the Contractor, acting as an agent of NASA

for the purposes of export control, shall export on behalf of NASA

specifically identified technical data, computer software, or hardware to

a named foreign entity or person, in the manner and under the

conditions provided for in the direction. Further, the Contractor agrees

to include this clause in all Space Station related subcontracts, the

performance of which may require the development, delivery, or use of

technical data, computer software, or hardware.

Although this clause requires Boeing to comply with applicable export laws and regulations,

NASA is responsible for the proper use of any export license that the Agency has obtained and

is the identified licensee.

Export Administration Regulations

The EAR governs most export activities in support of the ISS Program. The EAR, Part 736.2,

"General Prohibitions and Determination of Applicability," states that "you may not, without a

license or license exception, export any item subject to the EAR to another country or reexport

any item of U.S. origin if the item is controlled for a reason indicated in the applicable Export

 

11 For the ISS Program, Boeing has effected exports against a total of five NASA-obtained export licenses

and one special comprehensive license (see details on this type of license in footnote 14).
4

Control Classification Number." Part 758.3, "Shippers Export Declaration," states that a

Shippers Export Declaration must be submitted by the exporter or the duly authorized

forwarding agent of the exporter, to the Commerce Department's, Foreign Trade Division,

Bureau of the Census. The Shippers Export Declaration is a statement to the U.S. Government

asserting that information on the specific item being exported as shown on the declaration is

true.

Part 762, "Recordkeeping," requires the retention of records related to individual export

licenses and the exports effected against those licenses. The records must be retained for 5

years and must be originals, unless the licensee complies with certain requirements related to

reproductions. Part 762 also states:

Persons located in the United States may be asked to produce records

that are required to be kept by any provision of the EAR, or any license,

order, or authorization issued thereunder and to make them available for

inspection and copying by any authorized agent, official, or employee

of the Bureau of Export Administration, the U.S. Customs Service, or

any other agency of the U.S. Government, without any charge or

expense to such agent, official, or employee.

Availability of Boeing's Export Records

Boeing was unable to readily provide for our review the records and supporting documentation

related to exports effected on NASA licenses in support of the ISS program. Specifically,

Boeing was unable to produce complete records and supporting documentation related to

exports effected against two of the six NASA-obtained export licenses for the ISS program.

Boeing's Huntington Beach, California, facility, in particular, could not readily provide the

records. As part of the audit, we informed NASA and Boeing officials of our intention to

review supporting records and documentation for export activities related to the ISS contract.12

In July 1999, the audit team asked Boeing to provide a complete list of export licenses related

to the ISS contract and the location of the export records associated with the licenses. Boeing

did not provide the OIG with the requested information until September 1999.

Upon receiving the requested license and record location information from Boeing Export

Control officials in Houston, Texas, the audit team notified Boeing of planned visits to its

Huntington Beach, California, and Huntsville, Alabama, facilities with the express purpose of

reviewing export records and supporting documentation. The visits occurred in September

1999. The Huntsville facility gave the audit team access to all requested export-related records

and supporting documentation. However, Boeing Huntington Beach informed the audit team

that the records were not available, may be archived, and could take from 2 to 3 weeks to

retrieve.

 

12 We also reviewed similar information for the TRW and Lockheed-Martin contracts reviewed as part of the

audit.
5

After the Huntington Beach visit, we expressed concern to Boeing officials that we were not

provided access to Huntington Beach’s records. Boeing responded that the Huntington Beach

facility had subsequently located the records and that a shipment to the OIG would be

forthcoming. After receiving two partial, incomplete shipments of records, the OIG issued a

subpoena to Boeing for the records on October 8, 1999.

Boeing Huntington Beach should have appropriately maintained the records and made them

available for our review in accordance with the requirements of Part 762 of the EAR. In

contrast to Boeing (Huntington Beach), TRW and Lockheed-Martin gave the audit team free

access to export records and related supporting documentation. Both contractors had available

for OIG review, all records and supporting documentation related to NASA exports as

required by the EAR.

The NASA Contracting Officer for the Boeing ISS Contract took action to notify Boeing that

records related to exports effected on NASA's behalf must be produced in accordance with the

EAR. The Contracting Officer issued a November 15, 1999, letter to Boeing stating:

With regard to records of exports you effect on NASA's behalf, we

require that you ensure that you can produce these records as required

by U.S. export regulations. It has come to our attention that your

Huntington Beach site was unable to produce records of NASA exports

recently in the course of an audit.

NASA should take follow-up action on this request to ensure that Boeing has an adequate

system in place to ensure it meets the recordkeeping responsibilities of EAR Part 762 for

exports effected by Boeing against NASA-obtained export licenses.

Boeing Exports of Controlled Items

Boeing may have effected exports of controlled items in support of the ISS Program that were

beyond the scope of two NASA-obtained licenses and were in potential noncompliance with

the EAR.13 As the prime contractor for the ISS, Boeing is directed/authorized, by contract

clause, to export controlled technologies. Since award of the ISS contract to Boeing in 1993,

NASA has obtained from the Bureau of Export Administration a total of five export licenses

and one special comprehensive14 license. Boeing has exported ISS Program controlled

technologies using both types of licenses. Although Boeing has effected the exports, NASA is

the licensee15 for both the individual and special comprehensive licenses, and as such, is

 

13 The Department of Commerce's Bureau of Export Administration is the final determinant as to whether a

noncompliance with the EAR has occurred.

14 NASA and approved, related entities use the special comprehensive license, which eliminates the need

for obtaining individual export licenses for every item expected to be exported. The special comprehensive

license identifies foreign cosignees, governments, and organizations authorized to receive NASA controlled

exports and re-exports.

15 Boeing has also obtained licenses for ISS-related exports for which Boeing is the licensee.
6

responsible for the proper use of the license, and for due performance of all the license’s terms

and conditions.

Upon receiving the subpoenaed export records and supporting documentation from Boeing, we

initially identified potential noncompliances with the EAR related to a total of 25 shipments of

export controlled items effected against two of the six NASA-obtained licenses. The potential

noncompliances included shipped items that were not included on the referenced license, items

shipped in excess of amounts identified on the license, and items shipped without appropriate

supporting documentation. After discussing these potential noncompliances with NASA

management, Boeing provided additional information to satisfy our concerns with all but nine

shipments. The nine shipments that are in potential noncompliance with the EAR are discussed

below:

NASA Export License D219490. NASA-obtained export license D219490 from the

Department of Commerce's Bureau of Export Administration on April 4, 1995. The license

authorized NASA to ship five line items of ISS-related hardware with a total value of about

$2.9 million to the Russian Space Agency and its related contractors. Our review of exports

effected against this license identified a total of eight shipments made in potential noncompliance

with the EAR. Problems identified with these eight shipments include (1) items shipped in

excess of amounts identified on the license (2) items shipped that were not on the license, (3)

items shipped prior to receiving a license amendment, and (4) incomplete shipping records.

Some of the specific items follow:

• Multiplexer/Demultiplexer (MDM) - The Shippers Export Declaration, dated April

17, 1995, indicates that Honeywell, a Boeing subcontractor, shipped two MDM's with a

total value of $760,000 to a Russian Space Agency contractor. Export license D219490

authorized the shipment of two MDM's but at a total value of $400,000. When we asked

Boeing to explain the discrepancy in the value of the items shipped, Boeing initially stated

that the additional $360,000 consisted of "cables and connectors and loose items." When

Johnson Space Center (Johnson) Export Officials questioned the excessive dollar amount

associated with the cables, connectors, and loose items, Boeing responded that the

shipment actually consisted of one MDM at $200,000, and two Space Station MDM

Application Test Environment (MATE)-3 items at $1.2 million or a total of $1.4 million.

License D219490 authorized the shipment of three MATE-3 items at a total value of $1.8

million. This revised explanation from Boeing places the value of the controlled items listed

on license D219490 at $1.4 million, almost double the amount listed on the Shippers Export

Declaration. Based on the inconsistencies of Boeing’s explanations and the $640,000

difference between the Shippers Export Declaration and the items listed on license

D219490, we cannot conclude that the controlled items were actually shipped against the

license. In addition, Honeywell shipped these items prior to being approved as a consignor

to license D219490. The shipments were made on April 17, 1995, but amendment 7 to the

license, which authorized Honeywell as a consignor, was not authorized by the Bureau of

Export Administration until June 12, 1996, or more than 1 year later.
7

• Wire Harness Assembly - Boeing made a shipment of six wire harness assemblies valued

at $22,800 to a Russian Space Agency contractor on June 3, 1996. The license contained

no authorization for this item. Boeing stated that the item did not require an export license in

accordance with the EAR. When Johnson Export Officials stated that previous shipments

of wire harnesses had been licensed, Boeing replied that the wire harness assembly is made

of wire that does not require a license and connectors that do require a license. The

packing list and cargo specification sheet for the shipment identifies the wire harness

assembly as a controlled item requiring an export license. Boeing was also unable to locate

the Shippers Export Declaration for this item.

NASA Export License D238777. NASA obtained export license D238777 from the

Department of Commerce's Bureau of Export Administration on June 3, 1997. The license

authorized NASA to ship nine line items of ISS-related hardware with a total value of about

$15 million to the Russian Space Agency and its related contractors. Our review of exports

effected against this license identified one shipped item that was not authorized on the license.

The details follows:

• Thermal Protection Blankets - Boeing was unable to locate the Shippers Export

Declaration for this shipment. Our review of available documentation such as the

Requisition and Invoice/Shipping Documents related to this license showed that Boeing

shipped thermal protection blankets with a value of $9,650 to a contractor for the Russian

Space Agency. The blankets were not authorized on export license D238777 (the license

was referenced by Boeing on the shipping document). Boeing stated that freight forwarders

prepared the Shippers Export Declaration and that Boeing did not retain a copy. When we

asked Boeing why these items were not authorized by the license, Boeing responded that

the items did not require a license. However, documentation related to the items clearly

showed that the items should be controlled in accordance with the EAR and required an

export license.

Exports of the items discussed above represent potential noncompliances with the EAR.

Appendix F contains details on additional exports of controlled items by Boeing or its

subcontractors that are in potential noncompliance with the EAR. NASA should take

appropriate actions to ensure that Boeing's exports on behalf of the ISS Program are effected in

compliance with applicable laws and regulations.

Boeing's Commercial Exports

We identified similar areas of potential noncompliance with regard to commercial exports

effected by Boeing with licenses it obtained for the ISS Program. Boeing maintains an ISS

commercial program through which the ISS Program Office allows Boeing to market similar and

sometimes identical technologies developed under the NASA ISS contract to foreign partners

involved in the ISS program. Boeing follows the same export policies regardless of whether the
8

export is on a Boeing- or NASA-obtained license. Our review of exports related to Boeing’s

commercial program identified records and supporting documentation that were either not

readily available or incomplete. In addition, Boeing made exports that were beyond the scope

of the export license. Appendix G of the report provides details on the potential

noncompliances we identified. Although contractors are responsible for ensuring that their

export activities are in compliance with U.S. export laws and regulations, NASA management

should be concerned that technology developed under a NASA contract is being exported to

foreign entities under a contractor's commercial program in potential noncompliance with

applicable laws and regulations.

Boeing's Export Policies

Boeing’s export control policies did not effectively outline the necessary requirements for

ensuring that exports of controlled technologies are effected in accordance with applicable laws

and regulations. Boeing's export policies, as described in Boeing Policy, “Export and Import of

Hardware, Software, Technical Data and Services,” are not specific. For example, the policies

identify the responsibilities of various Boeing officials as related to export control; however, the

policies do not identify detailed export procedures, the required forms, and export control

documentation needed for the export process. In addition, the policies do not address exports

effected by subcontractors or oversight of subcontractor exports. Boeing officials stated that it

is the subcontractors’ responsibility to ensure that export controls are in compliance with the

EAR.

Boeing officials acknowledged that the company's export policies lack detailed, descriptive

procedures that could aid employees who encounter export control issues. These same officials

stated that Boeing will develop a detailed corporate export compliance manual that will contain

export policies for Boeing employees to use in ensuring compliance with U.S. export laws and

regulations. NASA should ensure that Boeing has adequate export policies in place prior to

authorizing Boeing to utilize NASA-obtained licenses on behalf of the ISS program.

Lack of NASA Oversight of Boeing's Export Activities

NASA has not performed sufficient oversight of Boeing's export activities even though the

Agency is the licensee for six licenses (including the special comprehensive license) that Boeing

uses in support of the ISS Program. As the licensee, NASA is responsible for the proper use

of the license and for due performance of all of the license’s terms and conditions.

As described in the NASA Export Control Program Pamphlet, oversight helps ensure that the

right questions are asked to preclude NASA officials and contractors from effecting exports that

may be contrary to U.S. export controls or inconsistent with the requirements of the EAR. The

pamphlet requires NASA Headquarters and the Centers to appoint an export control auditor

who, on an annual basis, reviews the Center's export control program to ensure its adequacy.

Although the pamphlet states that oversight is necessary to preclude contractors from effecting
9

exports that may be in noncompliance with applicable laws and regulations, the pamphlet has no

specific provision for the review of contractor export control programs by the export control

auditor. NASA has not reviewed Boeing or its subcontractors export control programs. As a

result, NASA is relying on Boeing and its subcontractors to ensure that exports effected against

NASA-obtained licenses are in compliance with applicable export laws and regulations.

Actions Taken by NASA Management

After we notified NASA management that several exports effected by Boeing against two

NASA-obtained export licenses were in potential noncompliance with the EAR, the Agency

took some corrective actions. For example, in March 2000, the Johnson Export Services

Team initiated a system to track licensed hardware, software, and data against actual shipping

information. This system provides a database for tracking all items on a particular license

including authorized quantities and dollar amounts. Upon receipt of shipping documents such as

the Shippers Export Declaration, the Export Services Team enters into the database actual

information on dollar amounts and quantities shipped. The database alerts Johnson export

officials who use it when the quantities or dollar amounts on the shipping documents exceed the

scope of the export license.

Initiatives such as the Johnson database system should help ensure that exports effected against

NASA-obtained licenses are in compliance with applicable export laws and regulations. In

addition, NASA management has actions planned as a result of a previous OIG audit16 to

improve Agency oversight with respect to contractor exports of controlled technologies.

NASA should take further steps to ensure that Boeing and its subcontractors have effective

controls in place to make certain that exports effected on NASA-obtained licenses in support of

the ISS Program are accomplished in accordance with applicable U.S. export laws and

regulations.

Recommendations, Management’s Response, and Evaluation of

Response

1. The Associate Administrator for External Relations should require Boeing to

establish an appropriate export control program and a detailed company-wide export

policy that comply with all EAR requirements prior to authorizing Boeing to utilize

NASA-obtained export licenses on behalf of the ISS program.

Management's Response. Concur. Boeing established a company-wide export control

manual that has been reviewed by Johnson officials. These officials found the manual to be

satisfactory in regard to Boeing being authorized to effect exports under NASA licenses.

 

16 The results of the audit are in Audit Report IG-00-018, "NASA Oversight of Contractor Exports of

Controlled Technologies," March 23, 2000 (see Appendix B for details).
10

Management questioned whether some of the examples detailed in the report were, in fact,

export violations and provided additional information to support its position.

The complete text of management’s response is in Appendix H.
11

Evaluation of Management’s Response. Management’s planned actions are responsive to

the recommendation. The recommendation is resolved, but will remain undispositioned and

open for reporting purposes until corrective actions are completed. We reaffirm our position

that the examples of export shipments detailed in the report could represent possible export

violations because of the disparities in explanations provided by management and the

inconsistencies in the available supporting documentation.

We address management’s additional comments on the finding in Appendix I.

2. The Associate Administrator for External Relations, in conjunction with the

Director, Lyndon B. Johnson Space Center, should direct the ISS Program Office in

coordination with the Center Export Administrator to periodically review Boeing's and

its subcontractors' export control programs to ensure that exports effected against

NASA-obtained licenses in support of the ISS Program are being accomplished in

accordance with applicable U.S. export laws and regulations.

Management's Response. Concur. NASA Headquarters will provide direction to the ISS

Program Office, in coordination with the Johnson Center Export Administrator, to periodically

review Boeing and its applicable subcontractors' export programs for those exports authorized

by NASA under NASA-obtained licenses (see Appendix H).

Evaluation of Management’s Response. Management’s planned actions are responsive to

the recommendation. The recommendation is resolved, but will remain undispositioned and

open for reporting purposes until corrective actions are completed.
12

Appendix A. Objectives, Scope, and Methodology

Objectives

Our objective, as discussed in this report, was to determine whether major contractors have

established adequate controls over controlled technologies to preclude unauthorized or

unlicensed exports. This is the second report issued as part of the overall audit of Contractor

Control of Sensitive Technologies. Details on the findings and recommendations in the previous

report are in Appendix B.

Scope and Methodology

We reviewed export policies for selected contractors to determine contractor compliance with

the ITAR and EAR. We also obtained an overall understanding of selected contractors' export

control programs and how the contractors export controlled technology on behalf of NASA.

During the audit, we:

• Identified and reviewed NASA and selected contractors’ export policies, in addition to the

ITAR and EAR.

• Reviewed export licenses, applications, and supporting documentation, dated from 1992

through 1999, at both NASA and contractor locations.

• Interviewed personnel in NASA’s Office of External Relations and program, contracting,

and export officials at Goddard Space Flight Center (Goddard), Johnson, and Marshall

Space Flight Center (Marshall).

• Interviewed program, contracting, and export officials at Lockheed-Martin, Boeing, and

TRW.

• Interviewed personnel with the Defense Contract Management Agency at LockheedMartin, Boeing, and TRW.

Management Controls Reviewed

We reviewed the following management controls relative to NASA and contractor exports of

controlled technologies:

• NASA Policy Pamphlet, “NASA Export Control Program,” November 1995

(revised October 1998).

• TRW Space and Electronics Group’s Export/Import Compliance Manual.
13

Appendix A

• TRW Space and Electronics Group’s Export and Import Compliance Pamphlet.

• Boeing Company-Wide Procedures, PRO-2805, “Export of Hardware, Software,

Technical Data, and Services,” June 29, 1999.

• Lockheed Martin Acquisition Procedure LMAP 2.230, “Procurements with

Foreign Suppliers.”

• Lockheed Martin Michoud Space Systems Standard Procedure 6-13, “Export

Requirements."

• U.S. Export Administration Regulations, January 1998

• International Traffic in Arms Regulations, April 1999

Audit Field Work

We conducted field work on this portion of the audit from November 1999 through

June 2000 at NASA Headquarters, Goddard, Johnson, and Marshall. We visited contractor

locations in Huntsville, Alabama; New Orleans, Louisiana; Houston, Texas; and Huntington

Beach and Redondo Beach, California. We performed the audit in accordance with generally

accepted government auditing standards.
14

Appendix B. Summary of Prior Audit Coverage

NASA Office of Inspector General

“NASA Oversight of Contractor Exports of Controlled Technologies,” IG-00-018,

March 23, 2000. The report states that NASA export, program, and contracting personnel at

Goddard, Johnson, and Marshall could not readily identify the types and amounts of NASAfunded controlled technologies that contractors export in support of NASA programs. This

condition exists because NASA’s current export policies do not clearly define the Agency’s

oversight responsibilities regarding its contractors who export controlled technologies.

Consequently, NASA does not have assurance that contractors are exporting controlled

technologies in accordance with applicable U.S. export laws and regulations. The report

contains two recommendations to assist the Agency in ensuring that controlled technologies are

exported in accordance with applicable laws and regulations. Management concurred with both

recommendations.

“NASA Control of Export Controlled Technologies,” IG-99-020, March 31, 1999. The

report states that NASA has not identified all export-controlled technologies related to its major

programs and does not maintain a catalog of classifications for transfers of export-controlled

technologies. Also, Agency oversight of and training for personnel in the Export Control

Program need improvement. Specifically, annual audits of each NASA Center’s export control

systems were not adequately performed, and NASA personnel lack training in controlling and

documenting export-controlled technologies. The report contains six recommendations to assist

NASA in addressing export-controlled technologies. Management concurred with all

recommendations.

General Accounting Office (GAO)

“Export Controls – International Space Station Technology Transfers,” GAO/NSIAD00-14, November 1999. The House of Representatives Committee on Science requested that

GAO review NASA’s implementation of Federal export regulations. The Department of

Commerce has issued nine validated licenses to NASA to export specific items and one special

comprehensive license. The special comprehensive license allows NASA to export certain

preapproved items without seeking Commerce’s approval each time NASA needs to export

them for the ISS program. The special comprehensive license has been used only once, even

though its purpose was to preclude the need for individual licenses.

The GAO also reported that NASA erroneously authorized the export of radiation-hardened

electronic parts to a Russian firm in 1997 without obtaining a license from the Department of

State. Further, NASA’s internal and external reviews of Agency export control activities have

identified weaknesses. The GAO made one recommendation to improve the quality of

NASA’s internal audits of Agency export control activities.
15

Appendix C. Situations in Which Controlled Technologies are

Exported

1. NASA exports controlled technologies on its own behalf. NASA exports controlled

technologies on its behalf, usually for in-house programs and projects. In this situation, NASA

is the exporter of record. NASA is responsible for administration and oversight of the export

licenses that it obtains from either the Department of State or Department of Commerce.

2. NASA grants license exemptions (for licenses from State Department only). In

some cases, NASA can grant contractors authorization to export controlled technologies

without obtaining licenses from the State Department. As a Government agency, NASA is

entitled to certain license exemptions not available to industry. NASA, in turn, utilizes its

exemptions to make it easier for contractors to export controlled technologies for NASA

programs.

3. NASA obtains export license, and contractors effect the exports. For certain

programs, such as the ISS, NASA can obtain a single or special comprehensive export license

from the Commerce Department. This process enables contractors, pursuant to contract

direction/authority, to export controlled technologies to NASA’s international partners. NASA

is the exporter of record and is responsible for administration and oversight of the license.

4. Contractor obtains export license from the Departments of State or Commerce for

NASA-funded programs. Contractors directly obtain the export licenses for controlled

technologies to be transferred to foreign entities. In this situation, the contractor is the license

holder and exporter of record. The contractor is also responsible for administration of the

export license.

5. Contractor obtains export license from the Departments of State or Commerce for

NASA-funded technologies exported commercially. For certain programs such as the ISS,

the contractor commercially markets hardware and software containing NASA-funded

controlled technologies. In this situation, the contractor is the license holder and exporter of

record and is responsible for administration of the export license.
16

Appendix D. Laws, Regulations, and Guidance

Relating to Controlled Technologies

Arms Export Control Act, 22 U.S.C. § 2778. The Arms Export Control Act authorizes the

President to control the export of defense articles and services. This authority has been

delegated to the State Department, which implements the Act through the ITAR. Defense

articles and services subject to the Act are identified in broad categories on the U.S. Munitions

List. Violations of the Act are punishable by debarment; fines of up to $500,000; and

imprisonment up to 10 years.

Export Administration Act of 1979, as amended, 50 U.S.C., Appendix 2401-2420. The

Export Administration Act (EAA) is a legal authority underlying the Export Administration

Regulations (EAR). (The EAA expired in September 1990; however, the provisions of the

EAR are continued under the authorities of the International Emergency Economic Powers Act,

which states “the administration of section 38 (e) of the Arms Export Control Act (22 U.S.C.

2778 (e) shall remain in full force and effect until amended or revoked under proper authority.”)

U.S. EAR, 15 Code of Federal Regulation (CFR), Part 730. The Commerce

Department’s Bureau of Export Administration issues the EAR under laws relating to the control

of exports and re-exports. The EAR were designed to implement the Export Administration

Act of 1979. The term "dual-use" distinguishes the types of items covered by the EAR from

those covered by regulations of certain other U.S. Government departments and agencies with

export licensing responsibilities. The term dual-use also distinguishes EAR-controlled items that

can be used in military and other strategic uses and in civil applications from those that are

weapons and are for military-related use or designs subject to the controls of the State

Department. The export items are classified in at least 1 of the 10 categories of the Commerce

Control List:

• Category 0 - Nuclear Materials, Facilities and Equipment, and Miscellaneous

• Category 1 - Materials, Chemicals, Microorganisms, and Toxins

• Category 2 - Materials Processing

• Category 3 - Electronics

• Category 4 - Computers

• Category 5 - Telecommunications and Information Security

• Category 6 - Lasers and Sensors

• Category 7 - Navigation and Avionics

• Category 8 – Marine

• Category 9 – Propulsion Systems, Space Vehicles, and Related Equipment
17

Appendix D

International Traffic in Arms Regulations (ITAR), 22 CFR, Parts 120-130. The Bureau

of Political-Military Affairs, Office of Defense Trade Controls, Department of State, issues the

ITAR to control the export and import of defense articles and defense services. The President

shall designate the articles and services deemed to be defense articles and services. These

defense articles and services constitute the U.S. Munitions List, a subpart of the ITAR. The

intended use of the article or service after its export is not relevant in determining whether the

article or service is subject to the controls of the ITAR. The defense articles or services fall into

1 of the 21 categories of

the U.S. Munitions List:

• Category 1 - Firearms

• Category 2 - Artillery Projectors

• Category 3 - Ammunition

• Category 4 - Launch Vehicles, etc.

• Category 5 - Explosives, Propellants, Incendiary Agents, and Their Constituents

• Category 6 - Vessels of War and Special Naval Equipment

• Category 7 - Tanks and Military Vehicles

• Category 8 - Aircraft and Associated Equipment

• Category 9 - Military Training Equipment

• Category 10 - Protective Personnel Equipment

• Category 11 - Military Electronics

• Category 12 - Fire Control, Range Finder, Optical and Guidance and Control

Equipment

• Category 13 - Auxiliary Military Equipment

• Category 14 - Toxicological Agents and Equipment and Radiological Equipment

• Category 15 - Spacecraft Systems and Associated Equipment

• Category 16 - Nuclear Weapons Design and Related Equipment

• Category 17 - Classified Articles, Technical Data, and Defense Services Not

Otherwise Enumerated

• Category 18 - Reserved

• Category 19 - Reserved

• Category 20 - Submersible Vessels, Oceanographic, and Associated Equipment

Category

• Category 21 - Miscellaneous Articles
18

Appendix E. Contracts Selected for Review

We reviewed the following three contracts as part of the audit.

Contractor/Contract

Number Description/Value

Location of

Performance

Cognizant

NASA Center

Boeing Missiles and

Space Division,

NAS5-10000

International Space Station

Alpha Program

$7.1 billion

Houston, TX

Huntington Beach, CA

Huntsville, AL

Canoga Park, CA

Johnson

TRW, NAS5-32954 Earth Observing System

Common Spacecraft

$396 Million

Redondo Beach, CA Goddard

Lockheed-Martin

Michoud Space

Systems, NAS8-

36200

Space Shuttle External Tanks

$3.7 billion

New Orleans, LA Marshall
19

Appendix F. Controlled ISS Parts and Equipment Exported in Potential

Noncompliance with EAR on NASA-obtained Licenses

Export License/Bill

of Lading Shipment

Number

Description of Export Destination

of Export Area of Noncompliance

License-D219490

D-1,902,298 Model Multiplexer

Demultiplexer (MDM) –

4

Russia Item not listed on Export

License

D-1,902,516 Field Test Connector Russia Recordkeeping –

Complete shipping

records were not available

D-1,902,718 SPDSU-PROD*

Hardware

Russia Item not listed on export

license

D-1,902,756 SPDSU-PROD

Hardware

Russia Item not listed on export

license

D-1,902,732 Wire Harness Assembly Russia Item not listed on export

license

Recordkeeping –

Complete shipping

records were not available

D-1,902,735 6B Box Mounting

Hardware Kit

(2 each) and Connector

Kit

Russia Recordkeeping –

Complete shipping

records were not available

D-1,902,757 SPDSU-PROD

Hardware

Russia Item not listed on export

license

D-3,004,162 SS Model Multiplexer

Demultiplexer (MDM)-4

FGB Spare

Russia Item not listed on export

license

License-D238777

D-3,004,725 Thermal Blankets Russia Item not listed on export

license

Recordkeeping –

Complete shipping

records were not available

* Serial Parallel Digital Simulation Unit Production
20

Appendix G. Boeing ISS Commercial Program Exports

License and

Description of

Export

Destination of

Export

Shipments Against

Export License

Shipments in

Potential

Noncompliance with

EAR

D240166

Connectors and

Accessories

Japan 146 98 shipments -

Complete shipping

documents not

available.

D220611

Connectors and

Accessories

Japan 180 68 shipments -

Complete shipping

documents not

available.

Dollar value of

shipments exceeds

dollar value scope of

export license by $4.95

million

D234914

PTCS Temperature

Sensors

Japan 1 1 shipment - Complete

shipping documents not

available.

D234917

PTCS Temperature

Sensors

Japan 1 1 shipment – Complete

shipping documents not

available.
21

Appendix H. Management’s Response
22

Appendix H
23

Appendix H

See Appendix I,

OIG Comment 1

See Appendix I,

OIG Comment 2
24

Appendix H

See Appendix I,

OIG Comment 3
25

Appendix H

See Appendix I,

OIG Comment 4

See Appendix I,

OIG Comment 5

See Appendix I,

OIG Comment 6
26

Appendix H
27

Appendix H
28

Appendix I. OIG Comments on Management’s Response

NASA management provided the following comments in response to our draft report. Our

responses to the comments are also provided.

Management’s Comment. NASA personnel at the Johnson Space Center reviewed the

Boeing policies in place in the summer of 1999. At that time, Boeing was in the process of

bringing the export compliance programs of several other acquired companies into the Boeing

corporate structure, and there were a number of export policies in effect. Management believes

that the report should state that Boeing did not, at the time of the audit, have company-wide,

standardized procedures in place to establish consistency and traceability for exports. Boeing

currently has a company-wide export manual in place.

1. OIG Comments. We interviewed export control and International Space Station (ISS)

Officials at Johnson on July 7, 1999. During the interview, those officials informed us that they

had not formally reviewed Boeing's export policies and procedures. Boeing officials further

confirmed that, prior to July 7, 1999, Johnson export control and ISS officials had not reviewed

Boeing's export policies and procedures.

Management’s Comment. The estimated dollar amount on the license for three

Multiplexer/Demultiplexer (MDM) Application Test Environments (MATE's) ($1.8 million) was

based on a Boeing conservative estimate of $600,000 per MATE. The value on Honeywell's

Requisition and Invoice/Shipping Document (DD-1149) that is associated with this license is

$710,000 for two MATE's, or $355,000 each. This does not constitute a potential export

violation.

The Shippers Export Declaration indicates that a MATE and associated equipment was

shipped. The two Honeywell-prepared DD-1149s for this shipment indicate that the actual

items shipped were: one Mass Equivalent Model (MEM) MDM, and two MATE's. The total

dollar value of the two DD-1149s is $760,000, as stated on the Shippers Export Declaration.

The value is made up of the two MATE's at $355,000 each and one MEM MDM at $50,000.

Through further fact finding after the auditor's initial questioning of this shipment, Boeing

demonstrated (based on the DD-1149s) that the shipment consisted of one MEM MDM and

two MATE's. While the value of the corresponding items in the approved License (D219490)

total $1.4 million, the value of the same licensed items in the shipment is $760,000. The value

on the license of $600,000 per MATE was Boeing’s estimate as provided to NASA and was

the value NASA used in applying for the license. The license value is generally used as a "not to

exceed" value for the shipment. This dollar amount difference is in favor of the exports effected

by Boeing’s subcontractor Honeywell. The value of the items exported did not exceed the

value authorized by the license. The DD-1149s show what items were shipped and are

consistent with the items listed under License D219490.
29

Appendix I

2. OIG Comments. It is our opinion that the MDM may not have been shipped in

accordance Export License D219490 due to the inconsistencies of Boeing's explanations of

shipments. Since our initial questioning of Honeywell's (Boeing's subcontractor) shipment of the

MDM's, we have received three different explanations of the shipments from Johnson/Boeing

export officials. The initial explanation we received from Boeing was that Honeywell shipped

two MDM's at a total value of $760,000 to a Russian Space Agency contractor when export

license D219490 authorized the shipment of two at a total value of $400,000. Boeing officials

explained the dollar value discrepancy by stating that the additional $360,000 consisted of

cables, a connector, and loose items. Johnson export officials also questioned this initial

explanation by Boeing. Boeing subsequently provided a revised explanation that Honeywell

shipped MDM and MATE items, which according to the export license were valued at $1.4

million. We again questioned this explanation because the Shippers Export Declaration

indicated that the value of the shipment was only $760,000, or almost half the value of the items

listed on license D219490. In its most recent explanation, Boeing again asserts that Honeywell

shipped two Mate's with a value of $710,000 ($355,000 each) and one MDM with a value of

$50,000 for a total shipment valued at $760,000, which is within the dollar and quantity scope

of the export license. However, those items were identified in license D219490 as having a

value of $1.4 million, or a $640,000 difference between the license and the Shippers Export

Declaration. We believe that Boeing's inconsistent explanations cast doubt as to whether this

shipment was made in accordance with U.S. export laws and regulations. Further, as stated in

the finding discussion, Honeywell shipped these items prior to being approved by the Bureau of

Export Administration as a consignor to license D219490.

Management’s Comment. A wire harness assembly is composed of connectors, wire, and

cable. The wire harness assembly sent to Russia was specialized because of the attached

amphenol connectors. These connectors were licensed under D219490. The wire harness

assembly parts list was previously provided to the auditors to show that the connectors were

part of the assembly.

3. OIG Comments. We reviewed available documentation on this shipment such as the DD1149 and Packing List Cargo Specification Sheet. Both documents clearly show that the wire

harness assembly items were shipped as controlled items under license D219490, even though

the export license does not list the items. Further, Boeing was unable to produce the Shippers

Export Declaration, which would definitively identify whether the wire harness assembly items

were shipped against license D219490. Our position is further strengthened by documentation

related to Boeing's commercial exports effected for the ISS Program which showed that wire

harness assemblies were shipped against export licenses. In addition, when we first questioned

this shipment, Johnson export officials
30

Appendix I

responded that previous shipments of wire harness assemblies by Boeing had been licensed.

Because of the conflicting explanations and the lack of a Shippers Export Declaration, we

maintain our position that the wire harness assembly items were shipped without an export

license.

Management’s Comment. A May 9, 2000, letter from Chemfab Corporation, the

manufacturer of the Beta Cloth fabrics (thermal protection blankets), to Boeing, indicates that

when used as intended, these products do not require an export license. The fabrics are used

extensively in aerospace applications. The Requisition and Invoice/Shipping Document

erroneously lists License D238777 as the license authority for the export of the blankets. It is

management’s understanding that these items were not subject to a license requirement and

should have been shipped "No License Required."

4. OIG Comments. We reviewed the available documentation on this shipment such as the

DD-1149 and Packing List Cargo Specification Sheet. Both documents clearly show that the

thermal blankets were shipped as controlled items under license D238777, even though the

license does not list the items. Boeing was unable to produce the Shippers Export Declaration,

which would identify whether the thermal blankets were shipped against license D238777.

Management's response includes a letter, obtained after our initial questioning of the shipment,

from the manufacturer of the blanket's fabric. The letter states that to the "best of our

knowledge," the products do not require a license. Our conclusion that the thermal blankets

were shipped without the benefit of an export license is based on the incomplete shipping

documentation, which indicated that the thermal blankets were controlled items and were

shipped under license D238777.

Management’s Comment. NASA has previously provided data to the OIG to demonstrate

that these items were approved by the Department of Commerce in license D219490,

Amendment 3, as part of "MATE Hardware Upgrades." Management does not agree that

these shipments are in potential noncompliance with the EAR.

5. OIG Comments. Honeywell's Export Shipping/Invoice and DD-1149 list the descriptions

of the export items as "VME Assembly" and SPDSU Upgrade Kit," not as “MATE Hardware

Upgrades” as listed on Amendment 3 of license D219490. For our audit, we identified eight

export shipments that were specifically listed as “MATE Hardware Upgrades” on Honeywell's

shipping documents and could be clearly traced to license D219490. However, we cannot

conclude that the “VME Assembly and SPDSU Upgrade Kit” were effected against license

D219490 Amendment 3, due to the fact that the item descriptions do not match.
31

Appendix I

Management’s Comment. The SSMDM-4 FGB Spare referenced by the report as "not

listed on export license" was in fact a replacement unit for an MDM found on license D219490,

line item 3. This license authorizes shipment of "2 Space Station FEU [Functional Equivalent

Unit] SS MDM 4 (FEUM4 FGB-1, 2)." The confusion stems from shipping documents for the

SSMDM-4 FGB Spare which indicated both export license D219490 "RPL" (for the EAR

License Exception for replacement units), and Export Control Classification Number "EAR99."

The reference to EAR99 was in error. The correct license authority was cited. A McDonnell

Douglas Aerospace (Boeing), Information Transmittal Sheet dated in July 1997, shows that the

Spare unit was approved for shipment to Russia after completion of rework and inspection

efforts. Management does not agree that this shipment was potentially noncompliant with the

EAR.

6. OIG Comments. It remains our position that the SSMDM-41 FGB Spare may have been

shipped without benefit of an export license. Specifically, our review of the Shippers Export

Declaration showed that Honeywell shipped the SSMDM-41 FGB-Spare on July 24, 1997, or

after the April 1997 expiration date of license D219490. In addition, the description of the

SSMDM-41 FGB-Spare on the Shippers Export Declaration does not match the description

listed on license D219490. Further, the explanation Boeing now provides indicates that

Honeywell shipped an SSMDM-41 FGB Spare valued at $500,508, which exceeded the

dollar value of $350,000 listed on export license D2194990.
32

Appendix J. Report Distribution

National Aeronautics and Space Administration (NASA) Headquarters

A/Administrator

AE/Chief Engineer

AI/Associate Deputy Administrator

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

H/Associate Administrator for Procurement

I/Associate Administrator for External Relations

ID/Director, Assessments and Technology Division

IM/Director, Resources Management Office

J/Associate Administrator for Management Systems

JM/Acting Director, Management Assessment Division

L/Associate Administrator for Legislative Affairs

M/Associate Administrator for Space Flight

P/Associate Administrator for Public Affairs

Q/Associate Administrator for Safety and Mission Assurance

R/Associate Administrator for Aerospace Technology

S/Associate Administrator for Space Science

U/Associate Administrator for Life and Microgravity Sciences and Applications

Y/Associate Administrator for Earth Science

Z/Associate Administrator for Policy and Plans

NASA Centers

Director, Ames Research Center

 Center Export Administrator, Ames Research Center

 Center Export Counsel, Ames Research Center

 Procurement Office, Ames Research Center

Director, Dryden Flight Research Center

 Center Export Administrator, Dryden Flight Research Center

 Center Export Counsel, Dryden Flight Research Center

 Procurement Office, Dryden Flight Research Center

Director, John H. Glenn Research Center at Lewis Field

 Center Export Administrator, John H. Glenn Research Center at Lewis Field

 Center Export Counsel, John H. Glenn Research Center at Lewis Field

 Procurement Office, John H. Glenn Research Center at Lewis Field
33

Appendix J

NASA Centers (Cont.)

Director, Goddard Space Flight Center

 Center Export Administrator, Goddard Space Flight Center

 Center Export Counsel, Goddard Space Flight Center

 Procurement Office, Goddard Space Flight Center

Director, Jet Propulsion Laboratory

 Center Export Administrator, Jet Propulsion Laboratory

 Procurement Office, Jet Propulsion Laboratory

Director, Lyndon B. Johnson Space Center

 Center Export Administrator, Lyndon B. Johnson Space Center

 Center Export Counsel, Lyndon B. Johnson Space Center

 Procurement Office, Lyndon B. Johnson Space Center

Director, John F. Kennedy Space Center

 Center Export Administrator, John F. Kennedy Space Center

 Center Export Counsel, John F. Kennedy Space Center

 Procurement Office, John F. Kennedy Space Center

Director, Langley Research Center

 Center Export Administrator, Langley Research Center

 Center Export Counsel, Langley Research Center Director

 Procurement Office, Langley Research Center Director

Director, George C. Marshall Space Flight Center

 Center Export Administrator, George C. Marshall Space Flight Center

 Center Export Counsel, George C. Marshall Space Flight Center

 Procurement Office, George C. Marshall Space Flight Center

Director, John C. Stennis Space Center

 Center Export Administrator, John C. Stennis Space Center

 Center Export Counsel, John C. Stennis Space Center

 Procurement Office, John C. Stennis Space Center

Non-NASA Federal Organizations and Individuals

Assistant to the President for Science and Technology Policy

Deputy Associate Director, Energy and Science Division, Office of Management and

 Budget

Branch Chief, Science and Space Programs Branch, Energy and Science Division, Office

 of Management and Budget

Associate Director, National Security and International Affairs Division, Defense

 Acquisitions Issues, General Accounting Office

Professional Assistant, Senate Subcommittee on Science, Technology, and Space
34

Appendix J

Chairman and Ranking Minority Member – Congressional Committees and

Subcommittees

Senate Committee on Appropriations

Senate Subcommittee on VA, HUD, and Independent Agencies

Senate Committee on Commerce, Science, and Transportation

Senate Subcommittee on Science, Technology, and Space

Senate Committee on Governmental Affairs

House Committee on Appropriations

House Subcommittee on VA, HUD, and Independent Agencies

House Committee on Government Reform

House Subcommittee on Government Management, Information, and Technology

House Subcommittee on National Security, Veterans Affairs, and International Relations

House Committee on Science

House Subcommittee on Space and Aeronautics, Committee on Science

Congressional Member

Honorable Pete Sessions, U.S. House of Representatives
NASA Assistant Inspector General for Auditing

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