Export Control (EAR/ITAR)

What are Export Controls?

Export Controls are federal laws that govern how technology, technical data, technical assistance, and items or materials (from software to satellites and more) are physically or electronically exported, shipped, transmitted, transferred, or shared from the U.S. to foreign countries, persons, or entities. 

Michigan Engineering research primarily falls under the following two regulations:

  1. International Traffic in Arms Regulations (ITAR) (link is external) from the U.S. Department of State (Directorate of Defense Trade Controls) which covers items and services related to military/defense applications, including spacecraft and satellites.
  2. Export Administration Regulations (EAR) (link is external) from the U.S. Department of Commerce (Bureau of Industry and Security) which covers “dual use” civilian/military items and technology.

Export Control Security Services – Shared Responsibilities

Roles and Responsibilities of Staff Members:

  • Michigan Engineering Data Security Analyst (DSA): Act as consultants for the IT staff who are responsible for creating TCP plans on behalf of researchers. They are available to answer questions and do security research as security subject matter experts during every stage of the TCP creation process. They coordinate any needed risk assessment with the ITS information assurance risk assessment team.
  • IT staff: Are the primary person responsible for assisting researchers in the TCP creation process and implementation. They participate in the submission of the TCP as needed and may request a risk assessment if needed.    
  • Researchers:  Are the business owners of the Technology Control Plan.  Assist their supporting IT Staff in the creation of the Technology control and its research implementation.  They sign off on TCPs, submit it to OVPR as part of their research administration process and ensure that it is followed by the research team.

Research Security Services

Categories Tasks Shared Responsibilities Effort
MichEngin DSA IT Staff Researchers
PCI Security Architect (ITS) NA NA NA
Treasurer's Office Consultant Primary NA
Risk Assessment Consultant Participate NA
RTP Consultant Primary NA
FISMA SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
SSP Creation Primary Participant Participant
SSP Implementation Consultant Primary Participate
SSP Submission Primary Participant Participant
RISK Assessment IA Coordination / Participant Primary Participant
RTP Consultant Primary Participant
CUI SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
SSP Creation Primary Participant Participant
SSP / ARC Implementation Consultant Support ARC and Researchers Participant
SSP Submission Primary Participant Participant
RISK Assessment IA Coordination / Participatant Primary Participant
Export Control TCP Discovery Consultant Primary Participant
Security Architect Consultant Primary Participant
TCP Creation Consultant Primary Participant
TCP Implementation Consultant Primary Participant
TCP Submission Consultant Participant Primary
RISK Assessment IA Coordination / Participatant Primary Participant
FAR 52.204-21 SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
SSP Creation Consultant Primary Participant
SSP implementation Consultant Primary Participant
SSP Submission Consultant Participant Primary
RISK Assessment IA Coordination / Participatant Primary Participant
HIPPA SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
RISK Assessment IA Coordination / Participatant Primary Participant
Michigan Medicine Corporate Compliance approval Primary Participant Participant
3rd Party Vendor Security and Compliance SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
PSSP Creation Consultant Primary Participant
3rd Party Information Security Requirements (TPISR) (e.g., GM) SSP Discovery Primary Participant Participant
Security Architect Consultant Primary Participant
PSSP Creation Primary Participant Participant