Most people have never heard of ITAR unless they dwell in the defense manufacturing sector. But for metal finishing companies, especially those looking to partner with aerospace or defense contractors, it’s the literal door that allows you to quote on certain jobs.
ITAR stands for International Traffic in Arms Regulation. It’s a controlled set of regulations implemented by the U.S. government that controls who has access to defense-related technical data and articles. So, if you’re coating, plating or treating parts destined for military systems, guided missiles, fighter jets or satellite systems, you fall within ITAR regulations.
What Finishing Companies Need to Know About Security Regulations
Where ITAR is different from other quality certifications is that ITAR does not concern itself with your process capability or quality management system. ITAR instead implements government-mandated security regulations of who’s working on parts and where those parts are and how the technical data is protected.
For starters, anyone that could potentially be in the presence of ITAR controlled items must be a U.S. Person. A U.S. Person is a U.S. citizen or lawful permanent resident (green card holder). Foreign nationals cannot freely wander through a manufacturing facility if work is being done on ITAR items. This poses additional challenges that many metal finishing shops don’t encounter on the commercial side.
In addition, there are physical access challenges. There must be controlled access work areas or rooms where work is done, which for smaller shops is not a problem, but for larger shops working with sensitive applications must have cameras and more documented access entry procedures – who can come in? Who cannot? Is there a visitor log? Must a specific area be marked so nobody can accidentally wander in?
When Do Defense Contractors Care
When a defense contractor sends components to a metal finishing supplier, it’s not just sending parts. It’s sending specifications, technical drawings, material requirements for a fabrication process and performance data that includes offense and/or defense applications as defense articles in alignment with ITAR.
If that finishing company is not registered and compliant with ITAR, as the supplier, the defense contractor has violated federal law. The repercussions are severe – fines of hundreds of thousands to millions of dollars, revocation of export privileges and even criminal consequences in extreme circumstances. Therefore, prime contractors will rarely consider a finishing house unless it proves ITAR compliance.
Therefore, companies serious about working with defense contractors must be ITAR certified and able to show their employees are properly vetted (with citizenship checks) to prove they have proper security protocols. This is no longer an additional quality credential that would be nice to have; this is the current baseline of assumed compliance.
The Process Is More Than You Might Realize
Therefore, it’s not just about filling out forms with the Directorate of Defense Trade Controls (DDTC) to get ITAR registered; it’s like your own IT department – every detail matters as it relates to your company structure and what you’ll represent for national security concerns.
The application includes payment – approximately $3,000 annually for most manufacturers – and then detailed information about ownership structure, prominent personnel, business goals and activities and what fields and specifications the defense articles fall under.
The registration payment is easy. The hard part comes with creating the structure and requirements for compliance.
There are written procedures for how employees will prove they are U.S Persons. There are procedures for marking when something is an ITAR-controlled document or what the guidelines are if someone sees something they shouldn’t see without proper clearance.
What Day-to-Day Compliance Looks Like
Once you’re registered, day-to-day compliance means changed orders, stored parts and even spoken communications.
Technical data protection is the hardest aspect to align. Understanding that a drawing with dimensions and tolerances related to the assembly of a missile is an ITAR-controlled document…an email requesting those specifications of plating for a defense application might not be…it’s problematic to constantly assume what’s an ITAR controlled document (even pictures can be deemed technical data).
This means your network needs the proper access control. Your employees must understand what they cannot share. You must have a separate location for technical data assembly versus technical data shared (versus commercial data shared).
Physical segregation helps ease this challenge. Many finishers will create a dedicated area for all defense-related work, regardless of additional commercial possibilities, where access can be logged and controlled. Some finishers maintain a separate network as well which ensures that any misfiled correspondence isn’t misused or sent to someone who shouldn’t see it.
Is Your Employee Trained Component
Your employees need to know what ITAR is and why it means everything; that part in the chromate Plater might look like just another aluminum component – but if it’s for an F-35 or satellites it has different rules.
Training covers all aspects of what should be controlled versus civilian use; restricted transfers and who to contact if anything seems off or needs further clarification. Most companies will hold initial ITAR training for any employee who might see defense work before annual renewals thereafter.
But turnover destroys this. Every new employee needs compliance before working on anything with ITAR connections which adds time and expense to onboarding that does not otherwise exist in commercial projects.
Why Metal Finishers Avoid It
With so many requirements post-registration – and afterward – many metal finishers would rather recede into the commercial sector instead with automotive parts, electronics components – anything that does not fall under defense trade controls – or else risk losing time, money and resources required during registration challenges.
And this is entirely justifiable as a business decision; ITAR compliance requires consistency of attention – that if it’s worth it for a small percentage of the bottom line, it doesn’t make sense.
But it’s interesting because some of the most lucrative work comes out of aerospace and defense; this type of work requires better precision tolerances, faster turnaround times and willingness to pay much more than commercial pricing just to avoid questions down the road about compliance issues where companies get burned when they shouldn’t.
Companies who can prove their ITAR certifications along with their quality certifications (Nadcap, etc.) have better advantages competitively toward contracts than companies who shy away from such registrations because they’re easy money vs revenue losses long-term when high-revenue projects get canceled for no reason at all (at least due to NO reason beyond compliance failures)!
The Bigger Picture
For metal finishers seeking defense work as one of their market segments, ITAR certification makes sense – it involves an extensive commitment to usability registration beyond paperwork filings – operating from facilities to procedures through the information systems relative to employee management compliance.
The ongoing consistent effort required means self-audits should regularly be scheduled. To those who want to work with defense contractors, it provides peace of mind that without proper registration and compliance programs rightfully exposed is not working to your advantage.
Defense contractors will never take the risk no matter how well your capabilities line up with finishing outcomes due to specifications quality control – if it’s too easy to avoid compliance integrity – and not protect national security concerns – it won’t fly.
This means people need to understand what compliance means compared to quality certification measures; it’s not parts production – that fails to meet expectations – it’s security protocols and access protection with sensitive information that dictates acquisition from one of manufacturing’s most demanding yet rewarding sectors at market value.
