GAO

United States General Accounting Office

Report to the Chairman and Ranking 

Minority Member, Committee on Science 

House of Representatives

November 1999 EXPORT CONTROLS

International Space 

Station Technology 

Transfers

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Contents

Letter 3

Appendixes Appendix I: Commodities Exported Using Individual Validated 

Licenses 18

Appendix II: Examples of ISS-Related Commodities Exported 

in 1998 Under No License Required Authority 19

Appendix III: Comments From the National Aeronautics and 

Space Administration 20

Appendix IV: Comments From the Department of Commerce 26

Abbreviations

CBM common berthing mechanism

EVA extravehicular activity

ISS International Space Station

MOU Memorandums of Understanding 

MDM multiplexer/demultiplexer

NASA National Aeronautics and Space Administration

OIG Office of the Inspector General

RAM Random Access Memory
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United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-283363 Letr

November 3, 1999

The Honorable F. James Sensenbrenner, Jr.

Chairman

The Honorable Ralph M. Hall

Ranking Minority Member

Committee on Science

House of Representatives

With 16 countries involved, the International Space Station Program is one 

of the largest scientific collaborations ever attempted.1

 Under international 

agreements related to the program, the National Aeronautics and Space 

Administration (NASA), as the U.S. representative, is obligated to deliver, 

disclose, or transfer technology, data, and commodities necessary to meet 

its responsibilities in implementing the program. Concerned about the 

extent of safeguards to protect technology and information exported in 

support of the space station, you and the late Representative George 

Brown asked us to evaluate NASA’s implementation of federal export 

control regulations. Specifically, we are providing information on 

(1) licenses granted to NASA to export space station-related technology 

and commodities and plans to export encryption technology and (2) the 

results of internal and external assessments of NASA’s export control 

program and NASA’s actions to implement audit recommendations. 

Encryption technology provides a capability to maintain the secrecy of 

information and is needed to provide secure transmission of command and 

control instructions between ground and space elements of the space 

station.

A significant percentage of NASA’s international activities may involve 

transfers of commodities, software, or technologies to foreign partners by 

NASA or authorized contractors. To protect national security and U.S. 

foreign policy interests, the export of technology and commodities to the 

15 partner countries involved with NASA in the International Space Station 

Program is controlled through a system of licenses. The Departments of 

Commerce and State are responsible for granting NASA such licenses. 

1

 The 16 countries are the United States, as lead partner; Canada; Japan; the European 

countries Belgium, Denmark, France, Italy, Germany, the Netherlands, Norway, Spain, 

Sweden, Switzerland, and the United Kingdom; Russia; and Brazil.
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Commerce issues licenses for the export of dual-use items—those items 

that have both commercial and military applications—on the Commerce 

Control List. Similarly, State issues licenses for exports of U. S. Munitions 

List items—articles, services, and related technical data designated as 

defense articles and services. NASA’s export activities must conform to the 

procedures and regulations established by Commerce and State.

Results in Brief Since April 1995, the Commerce Department has issued nine Individual 

Validated Licenses2 to export specific items and one special comprehensive 

license that allows NASA to export certain preapproved items without 

seeking Commerce’s approval each time NASA needs to export them for 

the International Space Station Program. Although the special 

comprehensive license was intended to preclude the need for individual 

licenses, NASA has only used it once because it has not been updated and, 

according to NASA officials, individual licenses are easier to obtain than 

updating the special comprehensive license. As new export requirements 

have materialized, NASA has elected to apply for individual licenses rather 

than amend the special comprehensive license. The State Department has 

not issued any licenses to NASA to export technology or commodities for 

the International Space Station. However, NASA erroneously authorized 

the export of radiation-hardened electronic parts to Russia in 1997 without 

first obtaining a license from State. NASA expects to export encryption 

technology for use in the program but has not determined whether a 

license is needed. NASA expects that such exports will be limited to its 

Japanese and European partners.

Internal and external reviews of NASA’s export control activities have 

identified weaknesses, including a need for greater management 

involvement in export-related decisions and additional training to educate 

employees involved with technology control about export laws, 

regulations, and procedures. NASA has taken steps to correct these 

weaknesses; however, some additional actions are needed. For example, 

annual internal audits have not provided sufficient information to assess 

the effectiveness of NASA’s export controls for the International Space 

Station Program. Resulting reports of audits that were issued in 1997 and 

2

 An Individual Validated License is a written authorization from the government to export. 

After a license application is approved, a license is issued by Commerce bearing the license 

number and validation date. The license will generally be valid for a 24-month period.
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1998 provide little detail and analyses beyond completing a required audit 

checklist.

This report recommends improvements aimed at improving the quality of 

NASA’s internal audits.

Background NASA had no formalized export control policy when the Space Station 

Program began in 1984, nor when the space station partnership was 

established in 1988. Although NASA issued a technical data and goods 

transfer control plan for the earlier Space Station Freedom Program in 

1991, that plan did not include procedures for making export-licensing 

determinations. When Russia joined the International Space Station (ISS) 

Program in 1993, the need for associated export controls was heightened. 

Thus, NASA established a Space Station Export Control Steering Group 

and an Interagency Export Control Working Group early in 1994 to assist in 

developing an approach to controlling exports of ISS-related commodities. 

Chaired by NASA, the groups comprised senior policy, legal, and technical 

representatives from the Executive Office of the President’s Office of 

Science and Technology Policy and the Departments of State, Commerce, 

and Defense.

Since 1994, NASA has been developing a more comprehensive technology 

control plan specifically for the ISS Program. The plan has remained in 

draft form but has been modified since its inception. NASA intends to 

finalize its most recent draft plan in mid-November 1999. In the meantime, 

NASA employees, contractors, and centers supporting the ISS Program 

have been instructed to use the draft control plan as guidance in 

implementing ISS-related export activities.

In 1995, NASA published an agencywide export control program document 

for all programs involved in international activities. NASA based its export 

control program on federal laws and regulations that require licenses for 

exports of controlled technologies, commodities, and services. Commerce 

and State are responsible for granting licenses to NASA and its
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designated contractors for the export of technologies to ISS partners.3

Under the authority of the Export Administration Act, Commerce 

established a licensing system for exports of dual-use items—those items 

that have both commercial and military applications—on the Commerce 

Control List. Similarly, under the authority of the Arms Export Control Act, 

State issues licenses for exports of defense articles and defense services 

that are on the U.S. Munitions List. The statutory authority to issue 

regulations regarding the export of dual-use items and defense articles and 

services is delegated to the Secretaries of Commerce and State. Commerce 

and State published the Export Administration Regulations and 

International Traffic in Arms Regulations, respectively, implementing the 

acts. NASA must ensure that its ISS export activities conform to these laws 

and regulations. NASA’s export control program document contains a stepby-step process for NASA employees and contractors to follow in 

determining whether technology and commodities can be exported to 

foreign countries, with or without a license.

NASA includes the following elements in its decision to export items in 

support of the ISS Program: (1) the necessity of the export and its 

consistency with NASA’s export control program, (2) any prohibitions on 

the export established by federal law or regulation, (3) whether State or 

Commerce is responsible for authorizing the export, and (4) whether the 

export requires a license. The export classification process includes these 

elements.

The line of authority for all NASA export-related activities originates at 

NASA headquarters and flows to the agency’s field center export 

administrators, program and project managers, and transportation officers. 

These officials share responsibility for ensuring compliance with U.S. 

export control regulations and NASA’s export control program. NASA’s 

program requires training to be conducted at least annually and covers 

issues and developments in export controls that impact the agency’s 

international activities.

3

 The Export Administration Act (50 U.S.C. app. 2401, as amended) has expired. However, 

Commerce carries out the Export Administration Regulations pursuant to an executive 

order issued under the President’s authority in the International Emergency Powers Act. 

The Arms Export Control Act (22 U.S.C. 2778, as amended) authorizes the President to 

control the export and import of defense articles and services. The authority to issue 

regulations with respect to export of defense articles and services was delegated to the 

Secretary of State by Executive Order 11958. 
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Status of Licenses and 

Plans to Export 

Encryption Technology

Since April 1995, the Commerce Department has issued nine individual 

licenses to export specific items and one special comprehensive license. 

With one exception, NASA has not used the special comprehensive license 

granted by Commerce to facilitate exporting the large volume of ISSrelated technology and commodities that it expected to transfer to the 

ISS partners. State has not issued NASA any licenses to export ISS-related 

technologies. However, NASA inappropriately exported radiation-hardened 

technology without having obtained a license from State. A centralized 

database of exported technologies is in development and will include 

information on items transferred without licenses. While encryption 

technology has not been exported, the requirement for it is being 

considered by NASA and its European and Japanese partners.

Licenses Issued to Export 

ISS Technologies

From April 1995 through May 1999, Commerce issued nine individual 

licenses to NASA for the export of ISS-related technologies. An individual 

license is granted in response to an application for a specific export. Six 

licenses were for items shipped to Russia, two for items shipped to Italy, 

and one license for items shipped to Germany. Appendix I includes a 

description of the commodities transferred using these licenses and the 

countries of destination.

For ISS-related exports, NASA may request an individual license or use the 

ISS special comprehensive license. In May 1996, Commerce issued NASA a 

special comprehensive license to facilitate the large volume of expected 

exports incidental to the ISS Program and to eliminate the need to apply for 

an individual license for each item it expected to export. The special 

comprehensive license is to be used to export only items listed in the 

bilaterally established exchange list and included in the license. None of 

the items are under State’s export control jurisdiction. The license covers 

certain ISS hardware, software, and technical data under the export control 

jurisdiction of Commerce. The license is only for the use of NASA 

personnel and approved related entities, such as authorized contractors 

and subcontractors listed in the license, and only when the entities have 

received specific contractual direction from NASA.

With the exception of one case in which the item exported was returned 

following a determination that procedures were properly followed, the
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special comprehensive license has not been used.4 NASA headquarters 

export officials said that technologies listed in the special comprehensive 

license, which was developed more than 3 years ago, need to be 

reevaluated and that obtaining an individual license to transfer ISS 

technologies is less complicated than amending the special comprehensive 

license. In commenting on a draft of this report, Commerce stated that, in 

1999, the NASA special license was fully entered into its electronic license 

database, making it easier for NASA to submit changes. Commerce further 

stated that, to export an item not identified in the original application, 

NASA would need to submit one form; to export multiple items not 

previously identified, NASA would submit an amendment form.

The special comprehensive license does not relieve NASA from its 

obligation to request a separate license if one is required. Because 

Commerce does not review each individual transaction authorized by the 

special comprehensive license, NASA and the entities authorized to use it 

must have mechanisms to ensure that each export made under it fulfills the 

terms and conditions of the license and applicable provisions of 

Commerce’s export regulations.

NASA Failed to Obtain State 

License in One Case

According to NASA officials, State has not issued NASA any licenses 

associated with the ISS Program to export items under the export control 

jurisdiction of State. However, NASA disclosed that in January 1997, 

radiation-hardened electronic parts were inappropriately exported to 

Russia without a license. This export occurred because a NASA 

contractor’s parts supplier had received an erroneous export classification 

from the manufacturer who was not aware that the parts were on State’s 

U.S. Munitions List, and NASA did not independently determine whether a 

license was needed. Additional details about this export and the resulting 

NASA investigation are discussed on pages 11 and 12 of this report.

4

 NASA verified its internal process of effecting an export under the authority of the ISS 

special comprehensive license in conjunction with the export of an electrical power system 

to its Japanese partner. The item was returned within 30 days.
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A Database of All ISS 

Export Controlled 

Technologies Is Being 

Developed 

NASA is not required to acquire a license for all export-controlled items 

that are ISS related. Under federal export control regulations, NASA has 

exported numerous ISS-related technologies with license exceptions. An 

exception allows NASA to export, under stated conditions, items subject to 

Commerce’s Export Administration Regulations that would otherwise 

require a license. As required by State’s and Commerce’s regulations, 

NASA’s export control program includes the requirement that records be 

maintained for at least 5 years on all exports and transfers. NASA’s draft 

ISS export control plan reiterates these requirements. Appendix II shows 

examples of ISS-related export controlled commodities NASA exported in 

1998 without licenses.

According to NASA officials, NASA’s centers have retained individual 

records of all ISS items that the agency has made export classification 

decisions on and exported since 1995. However, the records were not 

summarized and the ISS program office could not readily provide us with a 

complete list of ISS technologies exported to its partners without licenses. 

Although such a database is not required under export control regulations, 

having this information would be useful to supplement guidance and as a 

crosscheck in reaching future export classification decisions. Moreover, it 

would provide NASA, State, and Commerce with a tool to use in conducting 

reviews to assess NASA’s compliance with export laws and regulations.

According to NASA officials, the database of exported technologies 

currently in development will be a centralized database and will include 

information on items transferred without licenses and will be available 

agencywide. The ISS database development is a Johnson Space Center and 

ISS program office initiative.

Plans to Export Encryption 

Technology Are Being 

Discussed

To date, no encryption technology has been exported for use in the ISS 

Program. The requirements for and potential export of encryption 

technology needed to support the ISS are being discussed by NASA, its 

European and Japanese partners, and agencies that have export approval 

authority for the technology. To date, no license has been applied for. 

According to NASA officials, encryption will be needed to provide secure 

transmission of command and control instructions between ISS ground and 

space elements. The Japanese and European partners and NASA have 

agreed to use a common U.S. standard technology as the means of 

encrypting command and control communications. To use U.S. encryption 

technology, the Japanese and European partners must agree to provide it a 

level of protection equal to that provided by the United States, which would 
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require them to procure hardware from the list of sources approved by 

Commerce’s National Institute of Standards and Technology. NASA would 

provide them technical support for the hardware selection, related 

software development, and encryption key management, enabling them to 

interpret the coded instructions. The Japanese and European partners are 

considering a draft agreement that outlines U.S. protection requirements 

for the technology. If they concur with U.S. protection requirements and 

sign the agreement, NASA or the supporting contractor could initiate 

action to obtain a license to export encryption technology to the partners. 

NASA is collaborating with the National Security Agency and the National 

Institute of Standards and Technology about exporting the technology to 

these partners.

NASA officials stated that Russia would not be included as a destination in 

any potential licenses for encryption technology. While Russia and the 

United States will use a common infrastructure to transmit data between 

ISS space and ground elements, the Russian Space Agency and NASA will 

not use a common encryption technology or share such technology. Both 

the United States and Russia have their own encryption systems. According 

to NASA officials, Russia and the United States prefer using their own 

systems.

Reviews of NASA’s 

Export Control 

Program Have 

Identified Some 

Weaknesses

NASA’s export control program is subject to periodic internal reviews and 

to external reviews by Commerce and State. Moreover, investigations can 

be triggered by specific events requiring follow-up. The reviews and 

investigations conducted to date have identified some weaknesses in 

NASA’s export control program. NASA officials have taken steps to address 

many of these weaknesses. However, further actions are needed in some 

areas, such as improving the quality of NASA’s internal audits.
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State’s Review of 

License Application 

Triggered NASA’s 

Investigation of 

Radiation-Hardened 

Electronics Parts 

Exported Without 

License

In 1998, the State Department requested NASA’s review and comment on a 

license application involving a U.S. company affiliated with a Russian 

company for radiation-hardened electronic parts. The license application 

had also indicated that NASA had exported the parts to Russia in the past. 

In reviewing the application, NASA detected a potential issue of improper 

export with its prior transfer of the parts to Russia. NASA initiated an 

investigation and found that it had inappropriately exported radiationhardened electronics parts to Russia for use in the ISS Program. NASA had 

exported these parts without a license after the parts were erroneously 

classified as the lowest level of controlled technology. NASA did not follow 

its own policy, which is to determine the classification of material proposed 

for export or to ensure that its contractors have appropriately determined 

the material’s classification. Instead, a NASA contractor’s supplier 

determined that the export of the parts to Russia did not require a license 

and the contractor relied on that determination. NASA, in turn, relied on its 

contractor’s classification of these parts.

The parts were exported to Russia in January 1997. According to a NASA 

export control official, the supplier’s and manufacturer’s regional office 

officials were unaware that the radiation-hardened parts were on State’s 

U.S. Munitions List and therefore required an export license. NASA was 

unaware of the error for about 18 months until the U.S. company affiliated 

with a Russian company applied to State for an export license for the same 

parts, and State referred the license application for NASA’s review in June 

1998. According to a State official, the request for the license in this 

instance was to support activities associated with the Russian Mir space 

station. NASA export control officials told us that the application 

inaccurately stated that NASA had obtained a license for an earlier export 

of the same parts to Russia.

In a June 1998 letter to State about the incident, NASA formally 

acknowledged the error and stated that it had reminded the Russian Space 

Agency and the Russian company that the parts were solely for use in 

Russian-provided components of the ISS and were not to be used for any 

other purpose or transferred without NASA’s written approval. The Russian 

company responded that it had accounted for each of the exported parts 

and indicated how they were being used and where they were located. 

NASA accepted this response in good faith.

Although NASA may seek advice from the manufacturers to assist in the 

determination, NASA is ultimately responsible for determining the correct 
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classification and requesting a license, if required. As a result of this 

incident, NASA advised State in July 1999 that the ISS program office had 

instituted specific changes to its export procedures, requiring

• a manufacturer export office, rather than a sales office, to confirm 

export classifications of commercially available items and

• a NASA manager to be directly involved in determining export 

classifications before proceeding with exports.

According to NASA, key features of this process include a centralized 

database to capture all ISS exports and backup data, an Export Control 

Council to review exports and resolve issues, and documented export 

compliance training for employees. Also, training conducted by the ISS 

export administrator highlights the fact that radiation-hardened parts are 

export controlled. We concur with the need for these steps.

NASA’s Office of Inspector 

General Assessment

In March 1999, NASA’s Office of the Inspector General (OIG) completed a 

review of the agency’s export activities related to controlled technologies. 

The report noted that NASA had not identified all export-controlled 

technologies related to its major programs and did not maintain a catalog 

of classifications for transfers of export-controlled technologies. The 

report further stated that agency oversight of training for personnel in the 

export control program needed improvement and that, as a result, NASA 

might not have adequate control over export-controlled technologies to 

preclude unauthorized or unlicensed transfers. The OIG recommended that 

NASA

• establish a policy and procedures for cataloging controlled technology 

export classifications that would be available for all NASA installations; 

• define the qualifications of personnel that perform export program 

audits;

• designate only qualified personnel to perform annual audits of the 

export control program, in accordance with established policy; 

• establish a policy for resolving and following up on recommendations 

resulting from export control audits;

• enhance the current export control training program for NASA 

personnel, to include educating them about U.S. export laws and 

regulations and procedures for classifying and documenting exports; 

and 

• expand training on a recurring basis to NASA employees involved 

directly or indirectly with technology control.
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NASA concurred with the OIG report, and according to NASA officials, the 

agency is taking actions as follows:

• The agency plans to establish a central catalog of export control 

technologies. Each center has been requested to provide the 

headquarters Export Administrator copies of all classifications made for 

exports to facilitate the development of the catalog.

• NASA is hiring additional staff to conduct training in export controls 

and write policy guidance. NASA officials told us that it was developing 

computer-based training and that the agency plans to expand training 

modules to include more in-depth coverage of export laws and 

regulations, classification requirements, and procedures useful for 

conducting the annual audits of the export control program.

• In addition to computer-based training, the headquarters’ and centers’ 

export control administrators will continue to conduct training 

seminars on export controls.

• Auditing requirements and auditor qualifications are being included in a 

NASA program directive and a NASA procedures guide scheduled to be 

completed at the end of 1999. The directive and guide will also specify 

how center management will follow up on recommendations resulting 

from export control audits.

Commerce’s Assessment of 

NASA’s Export Controls

In June 1998, Commerce’s Office of Exporter Services reviewed NASA’s 

export control program, including the use of the special comprehensive 

license for the ISS Program. The purpose of this review was to ensure that 

NASA was complying with the Export Administration Regulations and the 

terms of the license. Commerce also reviewed pertinent records associated 

with NASA’s export control program, indicating in its report that NASA did 

not have a formal procedure in place to ensure that products were at the 

consignee sites and were being used for the intended purpose. Commerce 

concluded that, overall, NASA had adequate export controls and was 

complying with the act’s implementing regulations. However, to ensure full 

compliance with the implementing regulations, Commerce recommended 

that NASA

• revise its procedures for screening the Denied Persons List, a list of 

specific persons whose export privileges have been denied by 

Commerce;
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• update its export control audit module to reflect the latest Commerce 

terminology−using the Denied Persons List instead of the Table of 

Denial Orders;5

• develop a procedure for verifying that exports of certain items are at 

their intended destinations; and

• develop procedures for screening against Commerce’s most current 

entities list, which provides notice of license requirements for certain 

end users when there is an unacceptable risk that the commodity or 

technology may be diverted.

NASA has taken steps to implement these recommendations. While 

Commerce noted that NASA does not have a formal procedure in place to 

ensure that products are being used by the intended entity and for the 

intended purpose, it did not make recommendations regarding this point. 

NASA’s procedures developed in response to Commerce’s review focus on 

verifying that exports of certain items are at their intended destinations. 

Ascertaining that usage is as intended is not addressed.

Johnson Space Center 

Internal Audits

NASA’s export control program requires the agency’s centers to conduct 

annual audits of their export control practices and submit a report 

describing the review process, audit results, and any recommendations to 

NASA headquarters. However, such audits have not always been conducted 

in a comprehensive and rigorous manner. NASA’s OIG found during a 1999 

review of NASA’s export control program that though a significant portion 

of Johnson Space Center exports related to the ISS, the Center’s auditor did 

not review ISS exports. Moreover, we found that the Center’s 1997 and 1998 

annual audit reports were not sufficiently detailed to provide NASA 

headquarters with sufficient information to assess the effectiveness of the 

agency’s export control practices. Center auditors documented their 

reviews for fiscal years 1997 and 1998 by using a checklist−the NASA 

Export Control Program Audit Module−that included general questions 

requiring yes or no answers. Accompanying written reports, which were 

supposed to include a description of the review process, the audit results, 

and recommendations, were not prepared as required. Rather, the Center 

auditors forwarded only the completed checklists, with limited added 

detail, to the headquarters export administrator. For example, the 

checklists for 1997 and 1998 included a yes answer in response to a 

question regarding whether Commerce Export Administration Regulations’ 

5

 Former terminology for Denied Persons List.
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record-keeping requirements were being followed. However, they did not 

explain how the auditors reached this determination, nor did they include 

any comments or recommendations on this issue. NASA guidance requires 

auditors to verify, through sampling, that required screening and licensing 

procedures are regularly followed and that required documents are 

maintained in compliance with Commerce’s Export Administration 

Regulations. In commenting on a draft of this report, Commerce pointed 

out that the special comprehensive license also requires that NASA 

conduct a complete system review and not simply compare its procedures 

to an audit checklist.

Agencywide SelfAssessment of 

Transfer/Export Control 

Practices

In December 1998, NASA initiated an assessment of its export control 

program to determine whether its technology transfer and export control 

procedures were thorough, rigorous, and provided for fully safeguarding 

controlled goods and technologies, particularly in its international 

partnerships and programs. NASA required managers and employees at 

various organizational levels to complete a questionnaire designed to 

assess technology controls in their areas of responsibility. Consolidation of 

all assessments is under way, and NASA’s centers will be briefed on results. 

NASA officials told us that NASA has no plans to conduct a similar 

agencywide self-assessment in the future on a regularly scheduled basis.

NASA requested feedback on its three-part questionnaire from (1) NASA 

Enterprise directors, (2) center directors, and (3) center managers that 

direct projects involving international participation. We examined the 

assessments completed by the Human Exploration and Development of 

Space Enterprise, the Johnson Space Center, and the ISS program office 

since these entities are the most likely to be involved with ISS technology 

transfers. While the responses about the effectiveness of the 

implementation of NASA’s export control program were generally 

favorable, Johnson Space Center and ISS program office assessments cited 

a lack of adequate staff for export control matters. In particular, the 

assessments determined that additional personnel were needed for the 

time critical export classification process. The ISS program office 

assessment indicated that export control personnel were working with 

Johnson Space Center management to increase the number of personnel 

involved.

Conclusions NASA’s internal audits at the Johnson Space Center have not been 

comprehensive or detailed enough to judge the effectiveness of NASA’s 
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export control program or compliance with export control laws and 

regulations. The reports of audit lack evidence of audit work focused 

specifically on ISS exports and do not include detailed information on audit 

methods, findings, and recommendations as required by the agency’s 

export control program. Since NASA has no plans to conduct the 

agencywide self-assessment on a regular basis, making the Johnson Space 

Center’s audit more useful takes on added urgency.

Recommendation To enhance NASA’s ability to oversee and implement its export controls of 

ISS-related technologies, we recommend that the NASA Administrator 

ensure that center-based audits are completed with sufficient detail to 

enable the agency to identify weaknesses in NASA’s export control 

procedures.

Agency Comments and 

Our Evaluation

NASA reviewed a draft of this report and stated that the report captured the 

many facets of export control related to the ISS Program. NASA did not 

explicitly state whether it agreed or disagreed with our recommendation. 

NASA also provided technical comments to further clarify understanding of 

some issues and suggested revisions that we have incorporated where 

appropriate.

NASA’s written comments are presented in appendix III.

We also provided drafts of this report to the Departments of Commerce and 

State. We did not receive a written response from State. However, a State 

official indicated the agency concurred with the report. Commerce 

provided written comments, stating that the report is accurate (see app. 

IV). Both State and Commerce provided technical suggestions for 

clarification purposes that we incorporated where appropriate. 

Scope and 

Methodology

To determine the number and types of ISS-related licenses issued in 

conjunction with the ISS Program and the destination of technology and 

commodities exported to date, we compared export license records 

maintained by NASA headquarters with Commerce’s Export Control 

Automated Support System database. Our comparison included ISS-related 

licenses that Commerce issued between fiscal year 1994 and the first 

quarter of fiscal year 1998. We also reviewed program office listings of ISSrelated items it exported without licenses. To obtain information on the 
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status of encryption exports, we reviewed NASA records and held 

discussions with NASA officials about requirements for such exports and 

countries of destination.

To determine the results of past reviews of NASA’s export control program, 

we reviewed audit reports conducted by NASA’s OIG and Commerce and 

the results of a NASA investigation of radiation-hardened electronic parts. 

We also reviewed the methodology and results of recent internal audits of 

export control practices conducted by NASA’s Johnson Space Center. We 

assessed NASA’s responsiveness to audit recommendations by discussing 

follow-up actions with NASA officials and documenting changes in NASA’s 

policies and procedures.

We conducted our review from September 1998 through September 1999 in 

accordance with generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further 

distribution of this report until 14 days from its issue date. At that time, we 

will send copies to the Honorable Daniel S. Goldin, NASA Administrator; 

the Honorable Madeleine Albright, Secretary of State; the Honorable 

William M. Daley, Secretary of Commerce; the Honorable Jacob Lew, 

Director of the Office of Management and Budget; and other interested 

parties. We will also make copies available to others upon request.

If you or your staff have any questions concerning this report, please 

contact me on (202) 512-4841. Key contributors to this assignment were 

Jerry Herley, Samuel Cox, and Shirley Johnson.

Allen Li

Associate Director

Defense Acquisitions Issues
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Appendix I

Commodities Exported Using Individual Apendxies

Validated Licenses ApendxiI

a As shown, license 1 was amended six times.

Licenses Description Destination

1a

 Circuit emulator, International Space 

Station system bus upgrade, 

multiplexer/demultiplexer (MDM)

Russia

Amendment Circuit emulator, ISS system bus 

upgrade, MDM

Russia

Amendment Electronics equipment connectors Russia

Amendment Prototype and flight MDM, field-testing 

equipment, and cable kits

Russia

Amendment Prototype MDMs Russia

Amendment MDMs for payload blocks, command and 

control, navigation and guidance, and 

testing; connectors; test processors; and 

memory cards

Russia

Amendment Microswitches, MDM spare prototype, 

functional equivalent, and flight circuit 

boards

Russia

2 Connectors, MDM prototypes and circuit 

boards, spare circuit boards, flight 

enhanced MDMs, and flight stand

Russia

3 Random Access Memory (RAM) and 

optical couplers for developmental and 

flight stages

Russia

4 Synchronous RAM Russia 

5 Microcircuit optical coupler flight parts 

(radiation-hardened) for service module 

and functional energy block matching unit 

requirements

Russia

6 Hewlett Packard optical coupler circuits Russia

7 Hatch assembly kits, including hatches, 

tracks, trusses, and roller assemblies

Italy

8 Institute of Electrical and Electronics 

Engineers (Firewire) Ethernet 

Hub/Gateway

Germany

9 Active and passive common berthing 

mechanism (CBM) kits; CBM seal kits 

with bold assemblies

Italy
Page 19 GAO/NSIAD-00-14 Export Controls

Appendix II

Examples of ISS-Related Commodities 

Exported in 1998 Under No License Required 

Authority ApendxiI

Description Destination

Articulating portable foot restraint for ISS 

extravehicular activity (EVA)

Canada

Seat track material to be used for evaluating 

ISS designs and for interfacing with seat 

track anchors

Russia

Labels fabricated for National Space 

Development Agency of Japan flight in 

support of the ISS

Japan

Protective caps to provide cover for ISS 

EVA-installed communication cable 

connector

Canada

Cable, Russian degassing pumps to 

support the Russian spacesuit unbiblical for 

flight/testing applications

Russia

Fans/hardware Canada

Bar code reader, laser Russia

Camera equipment (35-70 millimeter f2.8D 

lens, Nikon) in support of Russian segment 

imagery

Russia

Terminal switching unit Russia

Smith press station for training of ISS crews Russia

22-inch hand rails (class III) for ISS EVA 

training

Russia

Russian simplified aid for EVA rescue 

mockup

Russia

Ammonium persulfate reservoir and acid 

reservoirs

Russia

Laptop computer Russia

Microfixtures Canada

On-board spacesuit control assembly Russia
Page 20 GAO/NSIAD-00-14 Export Controls

Appendix III

Comments From the National Aeronautics 

and Space Administration ApendxiI

Note: GAO comments

supplementing those in 

the report text appear at

the end of this appendix.
Appendix III

Comments From the National Aeronautics 

and Space Administration

Page 21 GAO/NSIAD-00-14 Export Controls

Now on p. 4.

Now on p. 4.
Appendix III

Comments From the National Aeronautics 

and Space Administration

Page 22 GAO/NSIAD-00-14 Export Controls

See comment 1.

Now on p. 5.

See comment 2.

See comment 3.

Now on p. 7.

Now on p. 4.

Now on p. 7.

Now on p. 7.

Now on p. 8.

Now on p. 9.
Appendix III

Comments From the National Aeronautics 

and Space Administration

Page 23 GAO/NSIAD-00-14 Export Controls

See comment 2.

Now on p. 9.

See comment 4.

Now on p. 11.

Now on p. 11.

Now on p. 11.

Now on p. 11.

Now on p. 11.
Appendix III

Comments From the National Aeronautics 

and Space Administration

Page 24 GAO/NSIAD-00-14 Export Controls
Appendix III

Comments From the National Aeronautics 

and Space Administration

Page 25 GAO/NSIAD-00-14 Export Controls

The following are GAO’s comments on the National Aeronautics and Space 

Administration’s (NASA) letter dated September 29, 1999.

GAO Comments 1. We do not agree that the statement “NASA had no formalized export 

control policy when the International Space Station (ISS) Program began” 

is misleading. However, we have revised the text of the report to provide 

additional explanation. We believe that our report’s background section 

accurately describes the status of the NASA export control policy when the 

ISS Program began as well as the current status of its export control plan 

for the ISS Program.

2. In our opinion, the terminology “without license” is a more accurate 

characterization of the information that will be included in the database 

being developed.

3. We believe that our report accurately states that none of the items on the 

bilateral exchange list are under State’s export control jurisdiction.

4. We have revised the text of the report to clarify this fact.
Page 26 GAO/NSIAD-00-14 Export Controls

Appendix IV

Comments From the Department of 

Commerce ApendxiIV

Note: GAO comments 

supplementing those in the

report text appear at

the end of this appendix.
Appendix IV

Comments From the Department of 

Commerce

Page 27 GAO/NSIAD-00-14 Export Controls

See comment 1.

Now on p. 14.
Appendix IV

Comments From the Department of 

Commerce

Page 28 GAO/NSIAD-00-14 Export Controls

GAO Comments The following are GAO’s comments on the Department of Commerce’s 

letter dated October 21, 1999. 

1. We recognize that parties involved in the ISS Program have signed 

Memorandums of Understanding (MOU). Signing these agreements is 

recognition by the partners of their responsibility and obligation to comply 

with the terms of the agreement. However, we believe a mechanism that 

provides assurance that the partners are complying with the terms of 

exports is a necessary step in NASA’s implementation of its export control 

policy. In our opinion, NASA’s procedures for verifying that exports of 

certain items are at their intended destinations do not provide adequate 

assurance that the items are being used for the intended purpose.

(707379) Letr
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Appendix IV

Comments From the Department of 

Commerce

Page 30 GAO/NSIAD-00-14 Export Controls

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