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Technology Control PlanCrow Precision Components, LLC d/b/a W. Pat CrowChange HistoryDate09/26/201411/19/2014I.AuthorCesar GarzaCesar GarzaSummary of ChangesDraft for internal WPC review.Initial release.SCOPEThe procedures contained in this plan apply to all elements of W. Pat Crow ("WPC"),200 Luxton St., Fort Worth TX 76104-1720.Disclosure of classified or unclassified technical data to foreign persons, as defined byInternational Traffic in Arms Regulations ("ITAR") § 120.10, or controlled for exportunder the Export Administration Regulations ("EAR"), in the course of employment or onextended visitor status is considered an export under ITAR and/or EAR and is subject toa Department of State license or agreement or an equivalent Department of Commercelicense. (Note: there is no classified information at WPC at the present time, and WPCdoes not maintain a current facility security clearance.)II.PURPOSEThe purpose of this Technology Control Plan is to delineate and inform employees andvisitors of WPC about the controls necessary to ensure that no transfer of technicalinformation or data or a defense service (as defined in ITAR paragraphs § 120.10 &§ 120.9) occurs unless authorized by the Directorate Defense Trade Controls (DDTC).III.BACKGROUNDWPC is a forger of metal components primarily for commercial and military aircraft basedin Fort Worth, Texas. Founded in 1951, the company forges and machines primarilyaluminum and steel into mission critical aircraft components, among other end markets.The Company focuses on structural aircraft components, such as landing gear, whichhave a need for frequent replacement over a relatively predictable replacement cycle.The majority of the components produced by WPC are aftermarket replacement parts formature aircraft platforms that have been in production for several years or in some casesthat are in active service and no longer being produced. In addition to its forgingcapabilities, WPC offers a full-range of services for the design and manufacturingprocess including tool design, prototyping, heat treatment, and final inspection. TheCompany holds various certifications that are generally required by customers as astandard across the aerospace industry including ISO 9001, AS-9100 and NADCAP. Itmaintains a current registration as a manufacturer/exporter with the State Department'sDirectorate of Defense Trade Controls.
Crow Precision Components, LLC d/b/a W.Pat CrowIV.Technology Control PlanFOREIGN PERSONSNo Foreign Person will be given access to unclassified and/or classified material on anyproject or program that involves the disclosure of technical data as defined in ITARparagraph 120.10 until that individual’s license authority has been approved by theOffice of Defense Trade Controls Licensing (DTCL).WPC employees who have the supervisory responsibility for foreign persons mustreceive an export control/licensing briefing that addresses relevant ITAR/EARrequirements as they pertain to classified and controlled unclassified information.Foreign persons employed by, assigned to (extended visit) or visiting WPC, shall receivea briefing that addressees the following items:V. Prior to the release of classified material or controlled unclassified information toa foreign person an export authorization issued by DTCL and/or BIS needs to beobtained by WPC. Ensure foreign persons adhere to the WPC’s security rules, policies andprocedures and in-plant personnel regulations. Outline the specific information that has been authorized for release to them. Address WPC’s in-plant regulations for the use of facsimile, automatedinformation systems and reproduction machines. Any classified information they are authorized to have access and need toforward overseas will be submitted to WPC’s security department fortransmission through government-to-government channels. Information received at WPC for the foreign national and information that theforeign national needs to forward from WPC shall be prepared in English. Violations of security procedures and in-plant regulations committed by foreignnationals are subject to WPC sanctions.ACCESS CONTROLS FOR FOREIGN PERSONSWPC has devised a set of controls to insure that foreign nationals do not obtainunauthorized access to any classified or controlled unclassified information. Theprincipal features are: Badges: All visitors are required to wear a badge during their visit. Foreignperson badges shall be uniquely marked in Red. Foreign persons shall not bepermitted access to restricted areas without security examination of this badge andvisual verification that the badge belongs to the holder. Employees must beinformed of the limitations and restrictions imposed for each different badge type.- A RED badge with NO FACILITY ACCESS indicates that an individual is aWPC visitor foreign person as defined above. This badge does not allow anyaccess to ITAR- or EAR-controlled technical information and requires full escortwhile at WPC facilities.- A RED badge with LICENSED WPC EMPLOYEE indicates that an individual isa full time WPC foreign-person employee who is covered by the appropriate2
Crow Precision Components, LLC d/b/a W.Pat CrowTechnology Control PlanITAR and/or EAR export license. The direct supervisor of such badgedemployees, in coordination with the WPC Export Compliance Officer ("ECO"),shall insure that the scope(s) of any ITAR or EAR personnel export license issufficient to enable free access to the WPC manufacturing facilities by saidemployee. If the authorized scope in any employee license is less than thescope of what is observable or accessible in the WPC facilities, then theemployee's direct supervisor shall work with the ECO to define a procedure tocircumscribe the employee's access appropriately.- All WPC foreign-person employees, on-site contractors and visitors arerequired to wear badges at all times while on WPC premises. Badges shall bedisplayed at the waist or above and be visible at all times so that identificationis easily determined. A full escort is required while in a WPC ITAR/EARrestricted area. Please check with the Company ECO. Escorts: It shall be the responsibility of the WPC host employee to escort, orarrange for an escort of a foreign person visiting WPC facilities at all times. TheWPC escorting employee shall confirm with the company ECO the facility locationsthat the foreign person can visit and make sure that there shall be no exposure tocontrolled unclassified information. (NOTE: WPC supervisors of foreign personemployees shall ensure that foreign nationals are escorted in accordance withU.S. Government regulations and WPC practices. Segregated work area(s):- The segregated areas at WPC include offices and a conference room, clearlylabeled for the purpose with signage indicating that display or discussion ofcontrolled technical data is not permitted therein, except by direct, writtenapproval of WPC's ECO. Such labeled segregated areas are not dedicated,but rather set up on an ad hoc basis, as needed for foreign-person visitors, orthose visitors who do not present personal identification upon entry sufficient toestablish that they count as "U.S. Persons".- Any WPC foreign-person employee who is the subject of a pending personnelexport license from the Department of State or the Department of Commerceshall be restricted to a section on the factory floor where they can perform theirwork without being exposed to controlled data or drawings, and shall not haveunescorted access beyond that until their license is approved by the USG. At all locations, visitors shall sign the entry log-sheet and display proof of U.S.citizenship or permanent residency. There shall be no exceptions to this rule. Allvisitors shall be escorted at all times. Any visitor or employee not known to be aU.S. person shall be treated as a foreign person for access-control purposes. Important: All foreign persons are subject to the security procedures in this TCP,including any individuals who have an ownership stake in WPC, specificallyincluding those owners so-identified in WPC's annual DS-2032 RegistrationStatement.VI.EXPORT-CONTROLLED INFORMATIONThe specific elements of unclassified information (there is no classified information atWPC at the present time) will involve technical information about any item that has been3
Crow Precision Components, LLC d/b/a W.Pat CrowTechnology Control Plandefined as an ITAR or controlled-for-export EAR item, and similar systems beingdeveloped, including such items as Interface Control Documents, source code fordefense article sensor drivers etc.VII.NON-DISCLOSURE STATEMENTAll foreign persons shall sign a non-disclosure statement (specified by DTCL) thatacknowledges that classified and controlled unclassified information will not be furtherdisclosed, exported or transmitted by the individual to any foreign national or foreigncountry unless DDTC authorizes such a disclosure and the receiving party isappropriately cleared in accordance with its government’s personnel security system.VIII.SUPERVISORY RESPONSIBILITIESSupervisors of cleared personnel and foreign national employees and foreign nationalvisitors shall ensure that the employees are informed of and cognizant of the following: Technical data or defense services that require an export authorization are not tobe transmitted, shipped, mailed, hand-carried (or any other means of transmission)unless an export authorization has already been obtained by WPC and thetransmission procedures follow U. S. Government regulations. All employees are cognizant of all regulations concerning the handling andsafeguarding of classified information and controlled unclassified information. Foreign-person employees execute a technology control plan (TCP) briefing formacknowledging that they have received a copy of the TCP and were briefed on thecontents of the plan. U.S.-person employees are knowledgeable of the information that can bedisclosed or accessed by foreign nationals.Point of contact for this TCP:Signature:Name & Date:/ /Senior Management Official:Signature:Name & Date:IX./ /EMPLOYEE RESPONSIBILITIESAll WPC employees who interface with foreign nationals shall receive a copy of the TCPand a briefing that addresses the following: Documents under their jurisdiction that contain technical data are not released toor accessed by any employee, visitor, or subcontractor who is a foreign national4
Crow Precision Components, LLC d/b/a W.Pat CrowTechnology Control Planunless an export authorization has been obtained by WPC in accordance with theITAR or the Export Administration Regulations (EAR). If there is any question as to whether or not an export authorization is required,contact the ECO promptly. Technical information or defense services cannot be forwarded or provided to aforeign national regardless of the foreign nationals location unless an exportauthorization has been approved by DDTC and issued to WPC.By signature below I certify that I have read the above Technology Control Plan andhave been briefed on its contents, and I agree to abide by the stated terms andconditions to the best of my ability.Employee:[** Insert name]: Signature and Date: / /5
International Traffic in Arms Regulations ("ITAR") § 120.10, or controlled for export under the Export Administration Regulations ("EAR"), in the course of employment or on extended visitor status is considered an export under ITAR and/or EAR and is subject to a Department of State license or agreement or an equivalent Department of Commerce
