Feb. 1, 2001
Export Control Training
Q: I received an electronic mail message this morning from the Division training specialist which said, among other things: LIR 406-03-10.0 now requires that all University of California employees and other Laboratory contractor personnel complete Annual Export Control Training. All Training Plans in regards to this training will show up as "Incomplete" in the Employee Development System (EDS) until the training has been completed.
ALL employees? What a stunning example of time wasting. The great majority of us have nothing to do with anything which impacts exports, or are covered by the regulations. But we ALL have to take the course? Of course, there is a head-set which says "Just do it, it won't take long." But "not too long" multiplied by the number of employees is still a waste. By the way, I object on principle to the use of "training." You train dogs! You don't even "educate" people. You give them access to information, and they educate themselves.
A: Laboratory policy has elevated national security awareness to the highest level, as embodied in the Integrated Safeguards and Security Management plan and the general issuance of security-related LIRs. The Labwide training requirement is an expression of the Laboratory's commitment to comply with export control laws and regulations.
The rationale for all employees needing export control awareness is that virtually any employee can be contacted by a foreign national requesting information (a copy of a technical report, for example). Although these requests may typically be directed to our technical staff (such as the author of a report), in many cases, these requests are handled by support staff. For example, many technical staff ask their administrative support personnel to fax or ship things overseas for them. Laboratory workers need to understand that they are exporting when they do this, and to follow all Laboratory procedures to show export control laws and regulations have been followed for every foreign transaction. It is possible for anyone to come into contact with a foreign national here at the Lab or elsewhere in the United States. Laboratory workers need to understand that providing technical data to a foreign national, whether in written or oral form, is an export.
--Sarah Maynard, Project Leader, Property Management (BUS-6)
Customs Office