Table 7: Required Approvals Prior to International Travel. 10 12-27-2016 4. Export Control Training Program Plan Expanded and updated Chapter 4 to reflect additional granularity regarding and available products. 11 12-27-2016 List of Figures Expanded from 18 to 27 figures. 12 12-27-2016 List of Tables Expanded from 4 to 8 tables. 13 12-27-2016 Appendix C: Key Definitions Multiple key definitions have been updated and added. Table of Contents
Five Product Groups A Systems, Equipment, and Components B Test, Inspection, and Production Equipment C Material D Software E Technology *Primary categories NASA uses. DOC also maintains lists of certain persons, including businesses, research institutions, government and private organizations, and individuals that are subject to specific license requirements for the export, re-export, and/or transfer (in-country) of specified items. Some of these persons comprise the Entity List (see ), established for reasons of proliferation concern, and are subject to licensing requirements and policies supplemental to those found elsewhere in the EAR. Others comprise the , which are entities that have violated U.S. export control or other laws. DOS DOC DOS and DOC have respective definitions for various export control terms. DOS definitions only apply to the ITAR; DOC definitions only apply to the EAR. The same term can be used in both regulations but may have very different meanings, and some terms are only used by one or the other (e.g., “commodity” and “technical assistance” are EAR terms). The “” section of this manual divides up ITAR and EAR terms for ease of reference. Consult your Center Export Control Staff (ECS) while applying appropriate definitions. See . Table 3: DOS v. DOC Definitions DOS – Software definition included in the ITAR DOC – Software definition included in the EAR
Table 7: Required Approvals Prior to International Travel Elements of international travel that require approval Vehicle for Approval Approved by Time needed to process request Travel Request for NASA individual Concur Travel System Foreign Travel Coordinator (FTC) At least 30 days prior to travel non-IT (e.g., test kit, white board, etc.) NF-892 (property pass) Property Custodian At least 30 days prior to travel items accompanying the traveler; commodities, software, technical data, and/or technology (e.g., laptops, cellphones, etc.) NF-892 (property pass) Property Custodian At 30 days prior to travel OCIO approval of IT resources OCIO At least 30 days prior to travel Export authorization using process* Center Export Control At least 30 days prior to travel (more, if a license is required) Presentation Materials intended for release (e.g., PowerPoint slides, handouts, etc.) Approved and signed NASA Form (NF) 1676* Center Export Control At least 30 days prior to travel
The level of interactivity (LOI) is the level of active learner participation. Raising the level of interactivity in online training creates a more active learning environment and results in longer retention of content. Within each level, there are varying degrees of interactivity and use of multimedia to facilitate the learning environment. Figure 24: Increasing the Level of Interactivity (LOI) LOI 1 Examples: Watching the Export Control Awareness Videos, or viewing a multi-media animation of technical equipment operation. LOI 2 Examples: The simplest example be using knowledge checks throughout the module. The following is an example of a more complex use of LOI level 2. The learner is presented with a scenario, asked to determine if an exemption or exception should be used for the export and the learner makes selections from available options. (Questions are asked, decision-making criteria is available and selectable on-screen for review), the learner continues to make decisions/selections, until arriving at a results screen. Feedback can be provided via the results screen using various delivery methods. LOI 3 Example: Computer simulation of a task with many steps which the learner must perform in the correct order at correct time, e.g., Orbital Maneuvering System (OMS) burn on the shuttle. Learner sets dials and switches, watches gauges and lights which change based learner actions/responses; learner follows procedures from a manual or list; makes choices to move switches; learner hears two alternating audios, one provides instructions from command control center, and the other provides sound feedback (alarms) for right and wrong choices, learner makes final decision to start and stop OMS burn based on feedback. LOI 4 Examples: Real-world, real-time simulation of task performance; live situation or experience. Figure 25: Future Training Development for Export Control 3
8: Summary of EC Program Training NASA’s Export Control Program Training Plan Training Product Audience and Description Media Selection Level of Interactivity 1-4 (LOI) Recommended Frequency and Tracking Awareness Training NASA’s Export Control Awareness Audience: New NASA employees and contractors Description: 7-minute video covering basic export awareness information Online/SATERN SATERN Course ID: AG-ECP-001 LOI 1 On boarding (new personnel) EC Management Awareness Audience: Center & Mission Directors and management staffs including Program & Project Managers Description: 7-minute covering basic export awareness information Online/SATERN) SATERN Course ID: LOI 1 On boarding (new personnel) NASA’s Export Control Processes: On-the-Job Training NASA’s Export Control Processes: On-the-Job Training Module 1: Introduction Audience: All Personnel Description: This module provides an overview of export control laws and regulations and NASA’s Export Control Program and is the foundation for NASA’s Export Control On-the-Job training modules 2 and 3. Note: Online/SATERN and/or F2F with CEA Instructor SATERN Course ID: LOI 2 As required and/or assigned by CEA; Completion of a topic/course is tracked by the LMS; A Completion Certificate is available to download or print from the Learning Plan history. Learning Activities for Module 1: Currently are 2 Learning Activities (LAs) for Module 1 topics. Learning Activities may Online/SATERN (and/or F2F with CEA Instructor) LOI 2-3 As required and/or assigned by CEA; Completion Certificate sent to CEAs and/or
not be appropriate for every topic. Center SATERN Coordinator NASA’s Export Control Processes: On-the-Job Training Module 2: Processes for All Personnel Audience: In general, all NASA personnel with potential involvement in exports on behalf of the Agency, or whose job may involve elements of export control including contractors including: Program & Project personnel Export Control Staff (ECRs and CERs) Points of Contact (POCs) Description: Module 2, has 12 standalone topics which may be assigned as appropriate by the CEA to personnel, or completed by individuals for professional growth in the field of Export Control. Online/SATERN or F2F with CEA Instructor SATERN Course ID: LOI 2 As required and/or assigned by CEA; Completion of a topic/course is tracked by the LMS; A Completion Certificate is available to download or print from the Learning Plan history. Learning Activities for Module 2: Currently are 9 Learning Activities (LAs) for Module 2 topics. Learning Activities may not be appropriate for every topic. Online/SATERN (and/or F2F with CEA Instructor) LOI 2-3 As required and/or assigned by CEA; Completion Certificate sent to CEAs and/or Center SATERN Coordinator NASA’s Export Control Processes: On-the-Job Training Module 3: Processes For NASA Export Control Staff Audience: All NASA Center Export Control (ECS) and others within programs and projects at the Centers, including Export Control Representatives and Center Export Representatives. Description: This module includes the detailed procedures and steps in the process to perform EC functional requirements; determining jurisdiction and classification; In development (estimated release date- first half of 2017) Online/SATERN LOI 2-3 CEAs may determine and assign the topics within this module to ECS personnel, and others as appropriate. Completion of topic/course is tracked by LMS; A Completion Certificate is available to download or print from the Learning Plan history.
13 **The visitor is authorized access to NASA technological data regarding [ __________ ] provided, these items and corresponding use of technology are eligible for license-free to (country). Active 14 **Approved access is limited to information that would be approved for the public domain and to specific non-public domain NASA data required under Space Act Agreement. Controls to restrict the individuals access only to export-controlled information that is allowed under the [ISS] agreement that is not controlled for Missile technology reasons. Active 15 [__________] is responsible for acquiring export license authority if required. Active 16 Visit is in support of [__________] activity and should be coordinated with [__________]. Active 17 Host should confirm [__________] approval. Active 18 Copies of the visit approval provisos/conditions are to be provided by the JPL host to all JPL employees and on-site contractor employees working with this foreign person. Active 19 No access to U.S. Government or NASA technical data, IT systems/networks, equipment, software (including source code), programs and systems authorized, except as authorized by approved Technical Assistance Agreements. Active 20 **Access to the CERN/HOSC computer is remote access only and only approved in the partitioned area, and only valid for 2 years at a time. Active 21 ***Any Remote IT Access is only permitted from an IP Address within the U.S. Access from an IP Address within China is prohibited Active 22 ***Visit is only approved for 2 years-(through ---) Active 23 **Approved access for one year and require annual updates-through (___). Active 24 Remote access only. No physical access to NASA facilities Active 25 **Caltech/JPL is authorized to transfer only that NASA-controlled technical data regarding (-------) necessary to fulfill its obligation under TA (----). Transfer of other NASA non-public domain technical data in support of this TAA requires prior NASA approval. Active