ITAR Compliance Policy

 I. Scope
This document covers Kreischer Optics’ ITAR compliance policy for custom manufacture of loose optical components and simple sub-assemblies to domestic      customers.

  1. A. Kreischer Optics does not employ or have on premises on a regular basis, any foreign nationals.  This document shall be revised prior to this situation changing.

  2. Kreischer Optics does not do any design of ITAR restricted items.  Any ITAR controlled items manufactured at Kreischer Optics will be done according to customer supplied specifications.

  3. Kreischer Optics does not export ITAR controlled items.  Export of ITAR controlled items is not covered by this document.

  4. Kreischer Optics is reliant upon the customer to notify us if a product falls under ITAR control.

  1. Kreischer Optics does not process unique capabilities or processes                                         which do not exist outside the USA.

  2. There is nothing inherent in the lens components and sub-assemblies themselves which Kreischer Optics produces, to indicate that they are used in an ITAR controlled device.

 II. Safeguards on ITAR controlled documents – Internal

  1. All copies of ITAR controlled documents shall be so labeled across their face.

  2. Restricted Access

  1. When not in use, ITAR controlled documents shall be kept in a locked drawer accessible only to management level employees.

  2. Any ITAR controlled documents in electronic format shall be stored only in a computer or electronic medium which is password controlled and accessible only by management level employees.

  3. When in use (traveling with parts in process) drawing shall be kept in a manila folder labeled “ITAR controlled” to prevent casual viewing by people without a “need to know”.

  1. Working copies of drawings

  1. For internal use during manufacturing, working copies of ITAR controlled drawings will be made which remove any information not needed by manufacturing.

  1. Anti-reflection coating information

  2. Next assembly level

  3. End product designation

 III. Safeguards on ITAR controlled documents – External

  1. ITAR controlled documents will not be transmitted outside of Kreischer Optics without specific need.

  2. Prior to transmitting ITAR controlled documents, the recipient will be contacted as to the ITAR restriction, and they must first agree to follow all ITAR guidelines with said documents.

  3. Prior to transmitting documents, unnecessary information will be removed, such as next assembly level, etc.