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EBSISOverview
(UK Patent Pending)
Mark Jones
MT&L Consulting Ltd
Tel: 0787 680 3690
www.mtlconsultingltd.co.uk
THE EXPORT CONTROL ISSUE:
• ITAR requires the through life management and tracking of all US Munitions List Defence Articles and associated Technical Information.
• ITAR has a 100% see through rule from discrete ITAR controlled “CHILD” articles, requiring the elevation of management, End Use Restrictions and authorised Consignees and Intermediate Consignees to a “PARENT” asset when transacting at the higher level.
• Depending on the End Use and ECCN categorisation, EAR also requires through life management and tracking of specific US EAR Listed Dual Use articles.
• There are also other, non-Export Control reasons as to why a customer may want to identify and actively track particular articles such as cost, safety or security etc.
THE PROBLEM STATEMENT:
• How do I know what assets are ITAR and what are EAR?
• How does this result in contaminated “PARENT” articles and how can I identify them?
• How do I know what the specific US Export Authorisations are for each article to enable me to prevent an ITAR Violation?
• How do I know where to focus my resources on what is important to my business?
THE SOLUTION - EBSIS (UK Patent Pending)
An Equipment Breakdown Structure Information System, proven solution, accurate and used across multiple live Defence Platforms by OEM organisations.
All Products and Platforms have an Equipment Breakdown structure.
However, some “PARENT” Articles will contain Export Comtrolled “CHILD” articles resulting in an ITAR asset management requirement of the discrete ITAR Article.
Export Controlled
Article
This also results, due to the 100% see through rule, the requirement to identify and manage contaminated “PARENT” articles to the same authorizations as the discrete ITAR Article
CONTAMINATED
CONTAMINATED
CONTAMINATED
Export Controlled
Article
This approach and system of work can be used to identify:
• Assets required to be tracked and controlled by ITAR regulations including 100% see through rule CONTAMINATED Articles;
• Assets that have been moved from the US ML to the US CCL under the “Series 600” category which still require the 100% see through rule to be applied;
• Assets that are listed on the US CCL and must be managed under the US EAR regulations and are subject to the 25% or 10% De-Minimus rule, a more detailed assessment of the EBS is required to fully understand the implications of the regulations implementation requirements;
• Assets that are listed on the US CCL with a DEMIL code “Q” therefore requiring US Commerce Department Licencing controls to be applied;
• Assets that are not listed on the US CCL but have a DEMIL Code “A” and therefore the Consignor MUST reference the US CONSOLIDATED SCREENING LIST;
• NOTE: The INTEGRATION of a US CCL listed article onto a Military Parent asset is deemed a DEFENCE SERVICE and therefore MUST be managed under ITAR regulatory conditions.
THE APPROACH:
• Step 1 – The EBSIS process starts by obtaining the Master Parts List (MPL) of the platform being assessed.
• Step 2 – Identify the discrete Parts that require tracking due to regulations i.e. ITAR articles listed within the MPL, EAR articles listed on the US CCL, asset required to be tracked for engineering reasons etc;
• Step 3 – Assess the MPL LCN (Logistic Control Number) into it’s component layers to define the “PARENT – CHILD” relationships embodied within the Product’s or Platform’s structure;
• Step 4 – Apply algorithms to the data set to allow the identification of not only the discrete ITAR articles but also identifies the contaminated “PARENT” articles.
• Step 1 – The process starts by obtaining the Master Parts List (MPL) of the platform being assessed.
RD NAME NSN DEMIL UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN0 LCN1 LCN2 LCN3 LCN4
1A5 POWER SUPPLY ASSEMBLY6130012001835 1 0 0 0 0
1A5A2 PANEL,POWER SUPPLY 1 0 0 0 0
1A5A2MP3 PANEL 1 0 0 0 0
1A5A3 BRACKET,MOUNTING5342011682455 1 0 0 0 0
1A5A3MP1 BRACKET,MOUNTING 1 0 0 0 0
1A5A3MP4 NUT,SELF-LOCKING,PL5310009884515 1 0 0 0 0
1A5A4 PLATE,BASE 1 0 0 0 0
1A5A5 PLATE,REAR 1 0 0 0 0
1A5A6 GUSSET,SIDE 1 0 0 0 0
1A5DS1 SWITCH,PUSH5930011778763 1 0 0 0 0
1A5DS1EP1 BASIC UNIT1285011673821 1 0 0 0 0
1A5DS1MP1 FILTER,INDICATOR LIGHT6210011944086 1 0 0 0 0
1A5DS1MP2 LENS,LIGHT6210013028298 1 0 0 0 0
• Step 2 – Identify the discrete Parts that require tracking due to regulations i.e. ITAR articles listed within the MPL, EAR articles listed on the US CCL, asset required to be tracked for engineering reasons etc;
RD NAME NSN DEMIL UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN0 LCN1 LCN2 LCN3 LCN4
1A5 POWER SUPPLY ASSEMBLY6130012001835 A 0 0 1 0 0 0 0
1A5A2 PANEL,POWER SUPPLY 0 0 1 0 0 0 0
1A5A2MP3 PANEL 0 0 1 0 0 0 0
1A5A3 BRACKET,MOUNTING5342011682455 A 0 0 1 0 0 0 0
1A5A3MP1 BRACKET,MOUNTING 0 0 1 0 0 0 0
1A5A3MP4 NUT,SELF-LOCKING,PL5310009884515 A 0 0 1 0 0 0 0
1A5A4 PLATE,BASE 0 0 1 0 0 0 0
1A5A5 PLATE,REAR 0 0 1 0 0 0 0
1A5A6 GUSSET,SIDE 0 0 1 0 0 0 0
1A5DS1 SWITCH,PUSH5930011778763 A 0 0 1 0 0 0 0
1A5DS1EP1 BASIC UNIT1285011673821 B 1 1 1 0 0 0 0
1A5DS1MP1 FILTER,INDICATOR LIGHT6210011944086 A 0 0 1 0 0 0 0
1A5DS1MP2 LENS,LIGHT6210013028298 A 0 0 1 0 0 0 0
• Step 3 – Assess the MPL LCN (Logistic Control Number) into it’s component layers to define the “PARENT – CHILD” relationships embodied within the Product’s or Platform’s structure;
RD NAME NSN DEMIL UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN0 LCN1 LCN2 LCN3 LCN4
1A5 POWER SUPPLY ASSEMBLY6130012001835 A 0 0 1 0 0 0 0 1A5
1A5A2 PANEL,POWER SUPPLY 0 0 1 0 0 0 0 1A5A2
1A5A2MP3 PANEL 0 0 1 0 0 0 0 1A5A2MP3
1A5A3 BRACKET,MOUNTING5342011682455 A 0 0 1 0 0 0 0 1A5A3
1A5A3MP1 BRACKET,MOUNTING 0 0 1 0 0 0 0 1A5A3MP1
1A5A3MP4 NUT,SELF-LOCKING,PL5310009884515 A 0 0 1 0 0 0 0 1A5A3MP4
1A5A4 PLATE,BASE 0 0 1 0 0 0 0 1A5A4
1A5A5 PLATE,REAR 0 0 1 0 0 0 0 1A5A5
1A5A6 GUSSET,SIDE 0 0 1 0 0 0 0 1A5A6
1A5DS1 SWITCH,PUSH5930011778763 A 0 0 1 0 0 0 0 1A5DS1
1A5DS1EP1 BASIC UNIT1285011673821 B 1 1 1 0 0 0 0 1A5DS1EP1
1A5DS1MP1 FILTER,INDICATOR LIGHT6210011944086 A 0 0 1 0 0 0 0 1A5DS1MP1
1A5DS1MP2 LENS,LIGHT6210013028298 A 0 0 1 0 0 0 0 1A5DS1MP2
• Step 4 – Apply algorithms to the data set to allow the identification of not only the discrete ITAR articles but also identifies the contaminated “PARENT” articles.
RD NAME NSN DEMIL UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN0 LCN1 LCN2 LCN3 LCN4
1A5 POWER SUPPLY ASSEMBLY6130012001835 A 1 0 TRUE 1 0 0 0 0 1A5
1A5A2 PANEL,POWER SUPPLY 0 0 FALSE 1 0 0 0 0 1A5A2
1A5A2MP3 PANEL 0 0 0 1 0 0 0 0 1A5A2MP3
1A5A3 BRACKET,MOUNTING5342011682455 A 0 0 FALSE 1 0 0 0 0 1A5A3
1A5A3MP1 BRACKET,MOUNTING 0 0 0 1 0 0 0 0 1A5A3MP1
1A5A3MP4 NUT,SELF-LOCKING,PL5310009884515 A 0 0 0 1 0 0 0 0 1A5A3MP4
1A5A4 PLATE,BASE 0 0 0 1 0 0 0 0 1A5A4
1A5A5 PLATE,REAR 0 0 0 1 0 0 0 0 1A5A5
1A5A6 GUSSET,SIDE 0 0 0 1 0 0 0 0 1A5A6
1A5DS1 SWITCH,PUSH5930011778763 A 1 0 TRUE 1 0 0 0 0 1A5DS1
1A5DS1EP1 BASIC UNIT1285011673821 B 1 1 0 1 0 0 0 0 1A5DS1EP1
1A5DS1MP1 FILTER,INDICATOR LIGHT6210011944086 A 0 0 0 1 0 0 0 0 1A5DS1MP1
1A5DS1MP2 LENS,LIGHT6210013028298 A 0 0 0 1 0 0 0 0 1A5DS1MP2
lcn UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN 0 LCN 1 LCN 2 LCN 3 LCN 4 LCN 5A1612 1 0 TRUE 1 0 0 0 0 A1612A1612001 0 0 1 0 0 0 0 A1612001A1612002 0 0 1 0 0 0 0 A1612002A1612003 0 0 1 0 0 0 0 A1612003A1612004 0 0 1 0 0 0 0 A1612004A1612005 0 0 1 0 0 0 0 A1612005A1612006 0 0 1 0 0 0 0 A1612006A1612007 0 0 FALSE 1 0 0 0 0 A1612007A1612007AAA 0 0 1 0 0 0 0 A1612007AAAA1612007AAA 0 0 1 0 0 0 0 A1612007AAAA1612008 0 0 FALSE 1 0 0 0 0 A1612008A1612008AAA 0 0 1 0 0 0 0 A1612008AAAA1612008AAA 0 0 1 0 0 0 0 A1612008AAAA1612009 0 0 1 0 0 0 0 A1612009A1612010 0 0 1 0 0 0 0 A1612010A1612011 0 0 1 0 0 0 0 A1612011A1612012 0 0 1 0 0 0 0 A1612012A1612013 0 0 FALSE 1 0 0 0 0 A1612013A1612013001 0 0 1 0 0 0 0 A1612013001A1612013002 0 0 1 0 0 0 0 A1612013002A1612014 1 0 TRUE 1 0 0 0 0 A1612014A1612014001 1 1 FALSE 1 0 0 0 0 A1612014001A1612014001AAA 0 0 1 0 0 0 0 A1612014001AAAA1612014001AAA 0 0 1 0 0 0 0 A1612014001AAAA1612014AAA 0 0 1 0 0 0 0 A1612014AAAA1612015 0 0 1 0 0 0 0 A1612015A1612016 0 0 1 0 0 0 0 A1612016A1612017 0 0 1 0 0 0 0 A1612017A1612018 0 0 FALSE 1 0 0 0 0 A1612018A1612018001 0 0 1 0 0 0 0 A1612018001A1612018002 0 0 1 0 0 0 0 A1612018002A1612020 0 0 1 0 0 0 0 A1612020
Example: The table below details an set of base data with a discrete ITAR article identified at lcn A1612014001
lcn UID ITAR CONTAMINATED ATL / BTL HAZMAT SECURITY VALUE OTHER LCN 0 LCN 1 LCN 2 LCN 3 LCN 4 LCN 5A1612 1 0 TRUE 1 0 0 0 0 A1612A1612001 0 0 1 0 0 0 0 A1612001A1612002 0 0 1 0 0 0 0 A1612002A1612003 0 0 1 0 0 0 0 A1612003A1612004 0 0 1 0 0 0 0 A1612004A1612005 0 0 1 0 0 0 0 A1612005A1612006 0 0 1 0 0 0 0 A1612006A1612007 0 0 FALSE 1 0 0 0 0 A1612007A1612007AAA 0 0 1 0 0 0 0 A1612007AAAA1612007AAA 0 0 1 0 0 0 0 A1612007AAAA1612008 0 0 FALSE 1 0 0 0 0 A1612008A1612008AAA 0 0 1 0 0 0 0 A1612008AAAA1612008AAA 0 0 1 0 0 0 0 A1612008AAAA1612009 0 0 1 0 0 0 0 A1612009A1612010 0 0 1 0 0 0 0 A1612010A1612011 0 0 1 0 0 0 0 A1612011A1612012 0 0 1 0 0 0 0 A1612012A1612013 0 0 FALSE 1 0 0 0 0 A1612013A1612013001 0 0 1 0 0 0 0 A1612013001A1612013002 0 0 1 0 0 0 0 A1612013002A1612014 1 0 TRUE 1 0 0 0 0 A1612014A1612014001 1 1 FALSE 1 0 0 0 0 A1612014001A1612014001AAA 0 0 1 0 0 0 0 A1612014001AAAA1612014001AAA 0 0 1 0 0 0 0 A1612014001AAAA1612014AAA 0 0 1 0 0 0 0 A1612014AAAA1612015 0 0 1 0 0 0 0 A1612015A1612016 0 0 1 0 0 0 0 A1612016A1612017 0 0 1 0 0 0 0 A1612017A1612018 0 0 FALSE 1 0 0 0 0 A1612018A1612018001 0 0 1 0 0 0 0 A1612018001A1612018002 0 0 1 0 0 0 0 A1612018002A1612020 0 0 1 0 0 0 0 A1612020
Example: This results in not only this discrete article requiring control, but it also contaminates lcns A1612014 and A1612 which results in, even though they are not discretely listed as being ITAR, they MUST be managed in accordance with the authorizations defined for their ITAR listed Child.
As shown in the base data table, other considerations can also be taken into account when identifying what articles require enhanced identification, management and impacts on the EBS structure.
These can be:
• ITAR;• EAR;• Engineering requirements;• Safety;• Cost;• Security etc
All can be accommodated within the EBSIS methodology.
The Final Step –
Produce the final output in a format that fits the Customer’s need;
Either:
Deliver the information back to the customer in an adapted form of the original MPL;
Or
Migrate Applied data into the EBSIS solution, providing an accurate and searchable “PROTECTED - READ ONLY” breakdown of the entire platform.
EBSIS Example.
ID 11475
niin_short 014902029
DEMIL_Code D
Licence EBSIS MASTER\EXPORT LICENCES\TEST DSP5 - COMPANY B - NIIN –
lcn A1612007AAA
UID 1
ITAR 1
CONTAMINATE 0
HAZMAT 0
SECURITY 0
VALUE 0
LCN 0
LCN 1
LCN 2 A1612007AAA
LCN 3
LCN 4
LCN 5
THE BENEFITS:
• Reduced Cost of Expensive Enhanced Asset Management;
• Reduced Costs of Expensive Disposal;
• Identify all articles requiring control to enable Export Control Compliance;
• Demonstrate Effective Export Controlled Article Identification under audit activities;
• Reduce the risk of Export Control Violations due to improved information availability to inform Export Control Compliance business processes;
• Inform Business Decisions to focus Asset Management resources on those Articles important to the business output;
• Inform the possibility of article replacement to reduce Export control liability;
• Can be adapted and deployed across any Platform or product, anywhere across the Globe.
Mark Jones
MT&L Consulting Ltd
Tel: 0787 680 3690
www.mtlconsultingltd.co.uk
