Jamie Hamilton, Author at CVG Strategy

Acceleration MIL-STD-810 Method 513

June 15, 2023 by Jamie Hamilton

Acceleration MIL-STD-810 Method 513 is a test method used to evaluate equipment’s ability to withstand steady state inertia loads and ensure that the test item does not create a hazard after being subjected to crash inertia loads. This testing is intended primarily for equipment that will be installed on aircraft, helicopters, aerospace vehicles, aircraft stores, and ground-launched missiles. Acceleration should not be mistaken for shock which excites a dynamic resonant response as opposed to a steady inertial stress.

Procedures for Acceleration

Four test procedures are available for acceleration testing:

Procedure I – Structural Test; ensures that equipment can structurally withstand in service acceleration loads.
Procedure II – Operational Test; Is used to evaluate equipment’s ability to operate while being subjected to acceleration g forces expected in its service environment.
Procedure III – Crash Hazard Acceleration Test; is used to ensure that restraining mechanisms such as fasteners do not fail in a crash scenario, creating a hazard to personnel or blocking paths of ingress and egress.
Procedure IV – Strength Test; added in revision H, uses sine burst testing on a vibration table to expose the test item to quasi-static loads.

Selection of tests to be performed should be based on requirements and criteria derived from the Life Cycle Environmental Profile (LCEP). This testing should be conducted after environmental transportation and storage methods towards the end of the test sequence.

Test Levels

System specific g levels for various platforms are provided in the standard. These designate values for fore, aft, up, down, and lateral axes. While these values are representative of forces expected in vehicle types, measured data should be used when available.

Levels for fighter and attack aircraft include provisions for materiel that is intended for locations away from the aircraft’s center of gravity. Formulae are provided for calculating the additional loads experienced in roll, pitch and yaw maneuvers in various directions.

Test Apparatus for Performing Acceleration Testing

Acceleration testing can be performed using different types of test equipment. For most applications, centrifuge testing is performed due to scheduling and budget considerations. However, when required, Track/rocket powered sled testing can be performed. Due to vibration caused by the rocket engine and track roughness, sled testing is generally more severe than that expected in general service life of the test item.

Additionally, sine burst testing is used for Procedure IV. This testing, although limited in its level of evaluation, offers an economical alternative for verification testing performed early in development because vibration tables are generally more available and testing on them requires less set up time.

Detailed Environmental Test Plan Templates

CVG Strategy offers EZ-Test Plan Templates for MIL-STD environmental (climatic/dynamic) and EMI/EMC testing documentation. Our Detailed Environmental Test Plans (DETP)s are written as specified in MIL-STD-810 Task 405. They are available for specific applications such as Ground Mobile, Ground Stationary, and Shipboard Controlled, Shipboard Uncontrolled, and Aircraft Military.

These DETPs include appropriate test methods, (such as Acceleration Mil-Std-810 method 513) addendums for product specific information, test labels for photo identification and data sheets for collection of required data. Profile (LCEP).

Our Electromagnetic Interference Test Plans are written as specified by the Department of Defense. They contain the test methodology, addendums for product specific information, test labels for photo identification and data sheets. These plans are available for procedures listed in MIL-STD-461 and are also available for MIL-STD-1275, MIL-STD-704, and MIL-STD-1399-300 testing standards.

Custom Test Plans are also available for applications not covered in the EZ-Test Plan offerings. These plans can be written for any number of applications and their relevant standards.

MIL-STD-810 Training Classes

This course is available online or onsite. Ample time is available for questions and comments so that participants are encouraged to keep engaged. Check here for our online Training Registration Schedule.

Put CVG Strategy’s Experience to Work for You

Companies of all sizes, from start up to established product developers, face challenges in product test and evaluation. This can particularly be the case when a product is developed for a new market sector or expanding sales internationally.

Properly tested products prevent costly product recalls, product redesign, and product liability. They maintain customer satisfaction and keep your company’s reputation in good standing. Contact CVG Strategy to see how our testing services can assist your engineering team with MIL-STD-810 acceleration testing or any other product test and evaluation concern.

Immersion MIL-STD-810 Method 512

June 9, 2023 by Jamie Hamilton

Immersion MIL-STD-810 Method 512 is used to evaluate the ingress protection capabilities of products against water intrusion. This is normally used for military equipment where immersion in water is a probable event in that product’s life cycle, including logistical and tactical transport. Performance of this testing does not necessarily preclude a requirement for Blowing Rain testing, as this environmental stressor presents different challenges for gasket design.

Procedures for Immersion

There are two test procedures available for Immersion testing. Procedure I (Immersion) evaluates the ability of enclosed equipment to withstand water immersion. Procedure II (Fording) evaluates vehicles traversing a body of water or material secured to such vehicles. As in other MIL-STD-810 test methods, operational testing is required when indicated by requirements or the Life Cycle Environmental Profile (LCEP).

Typical complete immersion duration is 30 minutes for both procedures. For Procedure I, a standard depth of 3.28 ft (1 m) is used. This depth is measured from the surface of the water to the top of the test item. For Procedure II test depth is determined by the class of vehicle the equipment is designed for.

When testing to depths greater than 1 meter is required, a pressure vessel may be used with the test item completely submerged.

Pretest Temperature Conditioning

Temperature differentials between the test item and water are known to increase the likelihood of ingress. This is caused by pressure differentials created as enclosure interiors cool. Therefore, it is required to preheat the test item before immersion.

For items that are subject to heating due to solar radiation, the prescribed temperature is 49 °F (27 °C) above the measured water temperature. For other items the Unit Under Test (UUT) should be preheated to 18 °F (10 °C) above water temperature. It is important to ensure that the item has been heated such that the item interior temperature meets requirements. Where the interior temperature is unknown, the item should be heated for two hours.

When the item being tested is too large for a test facility’s environmental chambers, testing can be performed without preheating if the immersion depth is compensated for the calculated pressure differential that would be caused by heating.

IEC 60529 Ingress Protection

IEC 60529 Ingress Protection is a commercial standard for evaluation. This method includes dust and penetration tests, water splash, immersion, water jet spray, and high pressure and temperature water jet spray testing. This standard is typically applied to commercial products and their ability to keep the environment from interfering with the operation of a product.

The standard includes equipment ingress classifications (IP code) defined by the letters IP followed by two digits and an optional letter. As defined in international standard IEC 60529, it classifies the degrees of protection provided against the intrusion of solid objects (including body parts like hands and fingers), dust, accidental contact, and water in electrical enclosures.

Detailed Environmental Test Plan Templates

These DETPs include appropriate test methods, (such as Immersion MIL-STD-810 Method 512) addendums for product specific information, test labels for photo identification and data sheets for collection of required data. Profile (LCEP).

Custom Test Plans are also available for applications not covered in the EZ-Test Plan offerings. These plans can be written for any number of applications and their relevant standards.

MIL-STD-810 Training Classes

Put CVG Strategy’s Experience to Work for You

Properly tested products prevent costly product recalls, product redesign, and product liability. They maintain customer satisfaction and keep your company’s reputation in good standing. Contact CVG Strategy to see how our testing services can assist your engineering team with Immersion MIL-STD-810 Method 512.5, IEC 60529 or any other test and evaluation concern.

CGP Security Plan Development Requirements

May 23, 2023 by Jamie Hamilton

Canadian Controlled Goods Program (CGP) security plans are a requirement for work sites where goods are examined, possessed, or transferred. This is a requirement for all companies registered in the CGP as described in section 10 of the Controlled Goods Regulations.

Controlled goods are primarily items, components and technical data that have been designated as having military or national security significance including International Traffic in Arms Regulations (ITAR) items. These goods are controlled by the Canadian government under the Defence Production Act. Controlled goods can be in the form of tangible items such as parts or components, printed material or electronic data.

Developing a Security Plan

A unique plan must be implemented for each business location of the registered organization. The plans must be based on a risk assessment for each location based on the specific goods stored, location of site, and levels of criminal activity in the area. This security assessment will allow for informed decision making as to the extent of measures to be taken.

The security plan should include a list of security responsibilities that identifies the individuals involved in those activities. It should include procedures to control the transfer, possession, or examination of controlled goods. It should also include documented procedures for reporting security breaches. Additionally, the plan should include training programs for export compliance team members.

Security briefings for visitors who be on site to examine, possess, or transfer controlled goods should be described in procedures. Visitors not exempt from the program must not be allowed access to controlled items.

Documented Procedures for Monitoring Controlled Goods

It is essential to document what specific controlled goods the company is working with. These should be categorized as components, physical objects, written documents, or digital information. The procedures must then identify how those items are to be received, stored, and transferred.

Security breaches that result int the theft, loss, unlawful examination, transfer, or possession of controlled goods must be reported. Documented procedures must be in place that describe the investigative steps the company will take in response to these incidents.

Putting the Plan in Action

Once a plan has been created, it must be approved by a compliance inspector. The inspector will guarantee that the plan complies with the regulations set forth by the Controlled Goods Regulations and is suitable for the company and its particular location.

A security plan must be in effect during the entire period that the organization is registered with the Controlled Goods Directorate. As with any management plan, the security plan must be regularly reviewed to ensure effectiveness. Upon review, where deficiencies or opportunities for improvement are identified, the program should be updated accordingly.

CVG Strategy Export Compliance Management Programs

Establishing a CGP security plan is an important part of this complex set of export regulations. Failure to follow these regulations can result in fines, penalties, and imprisonment. CVG Strategy export compliance experts can help you establish and maintain a viable Canadian Export Compliance Management Program.

CVG Strategy has been helping our clients with their export compliance programs for over a decade. We can also assist with product Export Control Classification Determination. Our experts can also provide guidance and the essential training to ensure that your personnel understand these important laws.

Explosive Atmosphere MIL-STD-810 Method 511

May 19, 2023 by Jamie Hamilton

Explosive Atmosphere, MIL-STD-810, Method 511, is used to evaluate how equipment will function in an explosive fuel-air environment. This method has two procedures. Procedure I – Explosive Atmosphere evaluates the ability of equipment to operate in a fuel-air environment without causing the fuel air mixture to ignite. Procedure II – Explosive Containment evaluates the equipment’s ability to contain an explosion resulting from a malfunction.

This testing is appropriate for equipment designed for environments where aircraft, automotive, and marine fluids or vapors exist. The test is representative of conditions at or above sea level where flammable fluids or vapors are present. This testing is performed in a test chamber and should only be performed by qualified personnel.

Test Fuel

These tests normally use N-hexane for fuel sources as these have similar properties to JP-4 and JP-8 jet engine fuel, and high-octane aviation gasoline. It is important to keep in mind that N-hexane is a hazardous material and that exposure to humans should be limited.

The fuel-air ratios are specified in detail for the explosive atmosphere test. These ratios must be homogeneous in the test chamber. Temperature for chamber is to be the highest ambient temperature that the test item is to operate in during its life cycle.

Altitude Simulation

Because the corona effect makes electrical devices more susceptible to arcing and creating sparks, both procedures are performed at simulated altitudes. For Procedure I the test item is normally exposed to a chamber pressure of 40,000 ft. (12,200 m) plus 6,600 ft (2,000 m).

The specified volume of n-hexane is introduced into the chamber and is allowed to mix and circulate with the chamber air. The pressure is then adjusted to 40,000 ft. (12,200 m). After each chamber pressure and corresponding n-hexane a test sample of the fuel-air mixture is subjected to a spark to verify the mixture’s explosiveness.

Because of the low levels of oxygen present at the 40,000 ft. level, ignition may not always occur. If the test sample is not ignited the chamber must be purged and the test restarted.

If the fuel-air mixture is verified, then the test item is exercised to simulate all operational modes. If the test item does not cause ignition, the sequence is repeated for at least three more sequences at lower altitudes. The final test occurring at site ambient pressure.

Procedure II Test Sequence

For Procedure II – Explosion Containment, the test item of model of same volume is installed into the test chamber. Humidity, dew point and specified operating temperatures are established in the chamber. The air pressure is set for a simulated altitude of 6,600 ft (2,000 m).

The fuel-air mixture is introduced, and the chamber pressure is returned to site ambient pressure. The mixture within the test item is ignited and if explosion occurs the test is complete.

Detailed Environmental Test Plan Templates

CVG Strategy offers EZ Test Plan Templates for MIL-STD environmental (climatic/dynamic) and EMI/EMC test documentation. Our Detailed Environmental Test Plans (DETP)s are written as specified in MIL-STD-810 Task 405. They are available for specific applications such as Ground Mobile, Ground Stationary, and Shipboard Controlled, Shipboard Uncontrolled, and Aircraft Military.

These DETPs include appropriate methods, (such as Explosive Atmosphere MIL-STD-810 Method 511) addendums for product specific information, test labels for photo identification and data sheets for collection of required data. Profile (LCEP).

Our Electromagnetic Interference Test Plans are written as specified in MIL-STD-461. They contain the test methodology, addendums for product specific information, test labels for photo identification and data sheets. These plans are available for procedures listed in MIL-STD-461 and are also available for MIL-STD-1275, MIL-STD-704, and MIL-STD-1399-300.

Custom Test Plans are also available for applications not covered in the EZ Test Plan offerings. These plans can be written for any number of applications and their relevant standards.

Put CVG Strategy’s Experience to Work for You

Properly tested products prevent costly product recalls, product redesign, and product liability. They maintain customer satisfaction and keep your company’s reputation in good standing. Contact CVG Strategy to see how our services can assist your engineering team with Explosive Atmosphere MIL-STD-810 Method 511 or any other test and evaluation concern.

BIS Assessing Civil Space Industrial Base

May 21, 2025March 24, 2023 by Jamie Hamilton

The Bureau of Industry and Security (BIS) is Assessing the Civil Space Industrial Base in the United States in partnership with the National Oceanic and Atmospheric Administration (NOAA) and the National Aeronautics and Space Administration (NASA) to better understand this important supply chain network. This study will use surveys to collect data from U.S. organizations involved in the research, design, and manufacture of space related products and services. It will involve research centers, commercial entities, universities, and laboratories.

Reasons for CSIB Assessment

The BIS, under the auspices of the Department of Commerce, and the Office of Technology Evaluation (OTE) are evaluating the U.S. Civil Space Industrial Base (CSIB) by means of the authority of Section 705 of the Defense Production Act and Executive Order 13603. The intent is to gather information that will provide guidance for the formation of governmental policies and proposals.

These policies are generated in an effort to protect and advance U.S., national security, foreign policy concerns, and economic base. The assessment was requested jointly by NASA, NOAA, The NOAA Office of Space Commerce (OSC), and the National Environmental Satellite, Data, and Information Services (NEDIS). Members of the commercial space sector that are chosen for involvement in this study will be required to participate. Although this assessment is a one-time event the possibility for further studies is possible.

The Complexities of Export Compliance

The BIS has been changing its scope and enforcement policies in recent years to address the increased complexities of the international political arena. Export Administration Regulations have continually been changing as more items are being added to the Commerce Control List (CCL). Additionally, the agency has increased its focus on the use of sanctions and denied parties lists to protect these sensitive technologies.

As the BIS places controls on a growing number of technologies, it poses challenges for organizations involved in export transactions. If a business produces or provides military articles or services, there is at the very least an understanding that ITAR export controls will probably be in place. For those involved in dual-use items however, the requirements for export compliance are much less clear.

CVG Strategy Export Compliance Expertise

The BIS Assessing Civil Space Industrial Base is just one example of the U.S. government’s and its international partner’s concern for developing controls that will ensure that potentially threatening technologies are not exported to hostile entities. In the past several years, the BIS, along with its international partners have greatly increased their activities in the generation and enforcement of regulations.

If you are part of a large corporation or a small company with a part-time compliance person, CVG Strategy has the compliance and training programs to help you meet International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) rules and requirements. As the BIS place controls on a growing number of technologies it becomes increasing difficult for smaller businesses to stay abreast of regulatory developments. Because of this, we provide Export Compliance Management Programs (ECMP) for businesses of all sizes.

CVG Strategy, LLC is recognized the world over as the premier provider of Export Compliance Consulting and Export Compliance Programs for businesses involved in export in the U.S. and Canada. We also provide the essential training that ensures that your team is up to date on governmental regulations, including the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), the Canadian Controlled Goods Program, and Office of Foreign Asset Controls (OFAC) and other regulatory agencies and more.

Temperature Shock MIL-STD-810 Method 503

March 1, 2023 by Jamie Hamilton

MIL-STD-810 Temperature Shock testing (Method 503) is used to evaluate equipment’s ability to withstand sudden changes in temperature. This laboratory test method is conducted in environmental test chambers and can be tailored to replicate the anticipated thermal profiles during storage, transit, and operation. Such shock could be experienced when a jet fighter on a tarmac in the desert rapidly climbs to high altitudes or conversely an article being air delivered by means of parachute to a high temperature environment.

Rapid change in temperature per this standard is defined as a change greater than 18 °F (10°C) per minute. Exposure to these environmental stresses can cause failures due to differential expansion and contraction of dissimilar materials. It can cause failures in electronics due to changes in components due to temperature changes. It can also cause failures in equipment due to the formation of frost.

Procedure Selection

The military standard MIL-STD-810 provides four test procedures for Temperature Shock:

Procedure I-A: One-way Shock(s) from constant extreme temperature This procedure is appropriate for equipment that will be not regularly exposed to thermal shock and when those shocks will occur only in one direction. Equipment air dropped from aircraft would be an example.
Procedure I-B: Single Cycle Shock from constant extreme temperature This is intended for equipment that is expected to be exposed to a single shock in each direction.
Procedure I-C: Multi-cycle shocks from constant extreme temperature An example of this would be a jet fighter taking off from a desert location and then landing at the same location.
Procedure I-D: Shocks to or from controlled ambient temperatures This would be applicable to equipment that is stored in environmentally controlled structures that must work in extreme hot or cold environments.

Determining Appropriate Test Values

It is necessary to tailor appropriate test temperature cycle and temperature range values from requirements, measurements, and those derived from the Life Cycle Environmental Profile (LCEP). Geographic climatic information is available in Part 3 of the standard to assist in value determinations. As with most MIL-STD-810 methods, measured data when available is preferred for determining test values. This is particularly the case in situations in which solar radiation may be a factor in determining maximum temperatures.

Generally, humidity is not a factor in Temperature Shock testing, but when required appropriate values should be determined based on expected areas of use. For testing of Air delivery the standard recommends a starting temperature equivalent to that found at 26,000 ft (8 km). These environmental conditions can be found in Method 520 Combined Environments.

Considerations During Testing

Temperature chambers specifically designed for thermal shock testing incorporate dual chambers side by side or on top of each other that allow a rapid transfer between the two test temperatures. Generally, availability of these chambers at test facilities is limited. When these chambers are not available the Unit Under Test (UUT) must be transferred between two separate chambers as quickly as possible.

Transfer time should be recorded during testing and be included in any required post test reporting. MIL-STD-810 encourages transfers between chambers to one minute or less. This can be challenging when the item is being tested in an operational mode or where the test item is large. When this is the case, justification for longer periods of transfer should be documented.

Detailed Environmental Test Plan Templates

These DETPs include appropriate test methods, (such as MIL-STD-810 Temperature Shock) addendums for product specific information, test labels for photo identification and data sheets for collection of required data. Profile (LCEP).

Custom Test Plans are also available for applications not covered in the EZ-Test Plan offerings. These plans can be written for any number of applications and their relevant standards.

Put CVG Strategy’s Experience to Work for You

Properly tested products prevent costly product recalls, product redesign, and product liability. They maintain customer satisfaction and keep your company’s reputation in good standing. Contact CVG Strategy to see how our testing services can assist your engineering team with MIL-STD-810 Low Temperature Testing or any other test and evaluation concern.

Disruptive Technology Strike Force to Enforce EAR

May 10, 2024February 22, 2023 by Jamie Hamilton

The Department of Commerce has initiated the Disruptive Technology Strike Force which will partner the Bureau of Industry and Security (BIS) with the Department of Justice (DoJ) in the enforcement of the Export Administration Regulations (EAR). Export Administration Regulations (EAR) control the export of commodities determined to be dual-use. Dual-use items refer to commodities and technologies that normally are used for civilian purposes but may also be used for military purposes. The specific regulations can be found in 15 CFR §730.

Agencies now included in this enforcement will include the FBI and Homeland Security Investigations (HFI). This ongoing enforcement will include fourteen different U.S. Attorney’s Offices centered in twelve metropolitan regions. These regions include Boston, Atlanta, Chicago, Dallas, Houston, Los Angeles, Miami, New York City, San Jose, Phoenix, Portland and Washington D.C.

Actions to Protect Sensitive Technologies

These joint actions are being taken to target illicit actors attempting to acquire and export sensitive technologies from the United States to Russia, North Korea, Iran, and China. These states are using these technologies to enhance their military capabilities which, aside from posing a threat to U.S. national security can also be used to enable actions against human rights. Additionally these violations of export controls threaten economic security by threatening business that create these advanced technologies.

Pulling Out All the Stops

In enacting this enforcement U.S. enforcement agencies will use use advanced data analytics, and enhanced intelligence to coordinate actions. They will be performing more training of field agents and furthering coordination between agencies in the Intelligence Community. Furthermore there will be efforts to enhance partnerships in the private sector as well as with international partners.

The strike force will fall under the joint leadership of Assistant Attorney General Matthew G. Olsen from the National Security Division of the Justice Department and Matthew Axelrod who serves as Assistant Secretary for Export Enforcement from the Bureau of Industry and Security.

Semiconductors a Focus

The BIS has been specifically focusing on the export of semiconductors and technologies involved with the design an manufacture of semiconductors. In May of 2022, the BIS added export controls pursuant to Section 1758 on two substrates of ultra-wide bandgap semiconductors and Electrical Computer Aided Design (ECAD) tools. These actions are being taken because these types of devices have significant potential for use in military applications. Effected ECCN classifications are listed in Document Number 2022-17125.

A Call to Actions for Businesses Involved in Export

The announcement of the Disruptive Technology Strike Force shows the Department of Commerce’s commitment to continue ramping up enforcement of Export Administration Regulations. This action is the latest in a series of steps that show how serious the U.S. government is in protection of dual use items. Additionally, partners of the U.S. are coordinating efforts to enforce export control laws. Aside from enforcement, penalties both civil and criminal are increasing.

Businesses must ensure that they do not violate export regulations by enacting viable Export Compliance Management Programs (ECMP). These programs are a requirement for both the Export Administration Regulations and the International Traffic in Arms Regulations (ITAR). While businesses involved with the ITAR have been proactive in compliance, many involved with the export of dual-use goods enumerated in the EAR have been less diligent.

Export Compliance Management Programs establish clearly defined policies and procedures for all departments within an organization. They ensure that registration, item classifications, license applications, denied part screening, and security measures are taken that will prevent violation. They also ensure that training, auditing, and record keeping are maintained according to requirements.

CVG Strategy Export Compliance Management Programs

Export Compliance is an important subject for businesses engaged in sales of items that are intended for international sales or could result in international sales. Failure to comply with regulations can result in criminal prosecution including imprisonment and fines. It can also result in civil penalties and disbarment from export activities.

CVG Strategy can help you in understanding Export Administration Regulations and establishing a coherent and effective export compliance system. We can perform export control classifications, perform audits, and educate your team. Regardless of whether your business falls under EAR or ITAR, CVG Strategy has the expertise to help. Contact Us with you export regulation questions.

Delays in CMMC 2.0 Final Ruling

February 9, 2023February 9, 2023 by Jamie Hamilton

As 2023 opens it appears that there may be further delays in CMMC 2.0 reaching a final ruling as the Pentagon considers additional revisions of the proposed rule. These reconsiderations are, as reported on ClearanceJobs, the result of internal politics and concerns on the impact on businesses. Because the rule is in proposed status, it is still open for public comment. In the past this feedback has led to major changes in CMCC that led to the release of CMMC 2.0.

Cybersecurity Maturity Model Certification

In 2013 the Defense Federal Acquisition Regulation Supplemental (DFARS) 252-204-7000 went into effect in an effort to establish requirements for safeguarding Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) held by DoD contractors in the Defense Industrial base. This was followed by the DFARS clause 7012 in 2016, which established NIST-SP-800-171 as the mechanism for providing this desired protection.

In 2019 the Department of Defense (DoD) announced the Cybersecurity Maturity Model Certification (CMMC) to provide an external mechanism for certifying levels of cyber hygiene of an organization. Following industry professionals’ concerns for the complexity, cost, and proposed timeline, the DoD released CMMC 2.0 in 2021. Among other changes, the levels for compliance were reduced from five to three.

Currently CMMC 2.0 requirements are divided into three levels of compliance:

CMMC Level 1 – Foundational is comprised of the 17 practices described in FAR 52.204-21 and requires an annual self-assessment.
CMMC Level 2 – Advanced is comprised of 110 practices which are aligned with the NIST SP 800-171 Revision 2 This is a set of security practices and security standards for non-governmental organizations that handle CUI. It requires that a third-party assessment by conducted every three years for information deemed critical for national security. It also requires an annual internal assessment.
CMMC Level 3 – Expert includes over 110 practices based on the NIST SP 800-17 cybersecurity standard and includes further controls. There is also a requirement for triennial assessments conducted by government representatives.

Establishment of a Certification Body

The Cyber AB was established as a non-governmental agency as the official accreditation body for CMMC. Its primary mission is to accredit organizations that will be responsible for conducting third party assessments. These organizations when accredited become part of the CMMC Third-Party Assessment Organizations (C3PAO).

While there has been progress in accrediting these organizations, concerns have been raised that there are still not enough accredited personnel to service the number of non-governmental organizations that require certification. Additionally, there have been several mishaps in the formation of the Cyber AB that have hampered its ability to function optimally.

CMMC Requirements Are Here to Stay

While delays in CMMC 2.0 roll out continue, the requirements will remain. Non-governmental organizations in possession of CUI and FCI will have to receive certification sooner or later. Establishing and implementing a CMMC program within an organization requires time and effort. Once the requirements have been met these systems must be integrated into the day-to-day operations of the organization.

While NIST SP 800-17 does contain a number of requirements for establishing and maintaining a cybersecurity program, it often comes up short in detailed descriptions on how non-IT functions are to be executed. This is particularly the case for critical functions such as auditing and management review. These functions must be performed regularly to ensure that the cybersecurity program is effectively addressing cyber risks.

CVG Strategy Information Security Management System Consultants

To assist businesses to meet the challenges in adopting CMMC 2.0 standards, CVG Strategy has developed an approach that combines the requirements of CMMC compliance with the ISO 27001 information security management system. This provides a coherent methodology for implementing and maintaining essential cybersecurity for businesses of any size.

We can help you meet your information security management system goals. CVG Strategy QMS experts are Exemplar Global Certified Lead Auditors. We can provide the training required to understand and engage in a ISMS and make it meet desired objectives. This process includes defining the context of your organization, creation of internal auditing processes and much more.

Export Compliance Program Guidelines – DDTC

January 25, 2023 by Jamie Hamilton

The Directorate of Defense Trade Control (DDTC) has released Export Compliance Program Guidelines to provide businesses with an overview of best practices for complying with the International Traffic in Arms Regulations (ITAR). These guidelines encourage organizations to adopt robust policies and procedures to ensure that compliance with export controls for items enumerated in the United States Munitions List (USML) is maintained.

Management Commitment

As with any effective business undertaking, top management must show commitment to export compliance by creating a culture of compliance. This culture can be created by management at all levels through words and actions that place a priority on avoiding export violations. These priorities should be regularly communicated to all employees, contractors, suppliers, and customers.

All employees should understand that export compliance is an expected responsibility. This should be communicated in an Export Compliance Manual that sets forth all policies and procedures. They should be encouraged to recommend methods for improving compliance and reducing risk. Additionally, all employees should be made aware of disciplinary actions for non-compliance.

Creating a Compliance Program

When creating an export compliance service it is important to tailor the program to identify and address the specific risks that could lead to violations. Policies and Procedures can then be created to address these risks. This should include a management commitment statement that underscores the organization’s commitment to export compliance.

These policies and procedures must receive adequate resources and be regularly reviewed by top management to assess their performance. Resources required for a program should include training, funding, adequate personnel, information security management, and organizational management. The adequacy of these resources should be continually reviewed throughout an organization’s evolution.

Responsibilities, authorities, and points of contact should be clearly defined and communicated within the organization. Export Compliance Officers (ECO) and Empowered Officials (EO) should overseeing and implementing functions of the compliance program and for investigating, identifying, and correcting causes for any ITAR violations.

Activities Associated with Export Compliance

Classification

Export Control Classification is required of businesses selling products that fall under the jurisdiction of any federal regulations. An export can include sale of goods within the United States to a person or entity that is not a U.S. person. A transfer of technical data can also be considered an export which can be conducted by means of a phone call or email.

Export Control Classification begins with the defining the technical specifications for the item to be transferred. This applies to actual shipments as well as transfers of technical data. It is important to note that a given product may fall under numerous classifications based on how regulations are interpreted.

It is essential to ensure that a thorough analysis be conducted to ensure that due diligence for compliance has been met. Therefore it is not prudent to rely on a customer’s or supplier’s classification as there are severe consequences for non-compliance.

Registration

The DDTC Export Compliance Program Guidelines outline the many activities that are part of a compliance program. These of course begin with registration with the the DDTC, which is a requirement for any manufacturer, exporter, or broker of defense products or services. The agency also details types of registration and requirements for registration changes.

Licensing, Agreements and Approvals

Other activities include applying for licenses, agreements, or other approvals from the DDTC for export, reexport, retransfers or temporary import of controlled goods and services. The activities include Manufacturing Licensing Agreements (MLA), Technical Assistance Agreements (TAA), and Distribution Agreements.

Restricted Party Screening.

Significant emphasis was given in the guidance to the performance of restricted party screening for all parties involved in a transaction. This activity is often overlooked or performed with insufficient care in many organizations. Restricted Party Screening should also be performed on all personnel and any other parties who may come in contact with controlled items or data thereof.

Cybersecurity

Although the ITAR does not include specific cybersecurity requirements, there are regulatory requirements to protect information and data of controlled items. CMMC is a requirement for organizations contracting with the Department of Defense (DoD) that handle Controlled Unclassified Information (CUI).

The guidance suggests the use of cybersecurity protocols and encryption to protect this sensitive data. It also recommends the establishment of policies and procedures for employees traveling with mobile devices.

Recordkeeping

It is a requirement of ITAR to maintain records pertaining to the manufacture, acquisition, and disposition of defense articles. These records must be maintained for a minimum of five years. They should include licenses, exemptions, technical data exports, brokering activities, and any political contributions, fees, and commissions. The DDTC again calls for documented policies and procedures that define what activities must be documented and allocate specific responsibilities for the creation and maintenance of those records.

Detecting, Reporting, and Disclosure of Violations

The DDTC understands that violations of export regulations often occur through error. However, because these violations can cause harm to the national security and foreign policy of the United States, it is important that organizations detect these violations, investigate the cause of the violation, take corrective actions to mitigate further violations, and report these violations through the Voluntary Disclosure mechanism.

Training

It is essential that organizations perform training programs that provide sufficient levels of education for all employees, especially those members of the organization’s export compliance team. This training should be up to date and utilize knowledgeable and experienced trainers. Furthermore the depth of the training should reflect the level of activity that person has in the compliance program.

Risk Assessments

It is important to continually reassess risks that may lead to ITAR violations. Considerations in the reassessments should include changes in the organization, the physical and cybersecurity infrastructure, the organizations, employees, customers, suppliers, and other third parties. These should occur as required throughout the year.

Audits and Compliance Monitoring

Independent and objective audits must be performed regularly to provide inputs in determination of the compliance programs effectiveness. These audits should include interviews with relevant personnel, review of documentation, site security, and IT security. Various types of audits should be included including functional level audits focusing on specific areas, program level audits, and external audits.

CVG Strategy Can Help

The DDTC’s Export Compliance Program Guidelines underscore the importance of viable export compliance programs for businesses engaged in sales of defense articles and defense services. These programs should be incorporated into an organization’s management system to ensure effective mitigation of risks associated with violations.

MIL-STD-461 RE102 Radiated Emissions

January 17, 2023 by Jamie Hamilton

MIL-STD-461

MIL-STD-461 is an EMI/EMC standard for developmental test and evaluation. This standard is broken out into nineteen various methods. These methods include Radiated Emissions, Conducted Emissions, Radiated Susceptibility, and Conducted Susceptibility.

MIL-STD-461 testing includes radiated and conducted test methods. These methods involve simulations of magnetic, radio frequency, Electrostatic Discharge (ESD), and Electromagnetic Pulse (EMP) sources of potential disturbance. Susceptibility requirements are determined by type of equipment, type of platform the equipment is to be operational on, and location of the equipment on that platform.

RE102 Radiated Emissions Testing

RE102 is the MIL-STD-461 method for evaluating electromagnetic field radiated emissions from systems and subsystems enclosures and cabling designed for U.S. military applications. Requirements and testing to this military standard vary for platform of intended installation. The frequency ranges applicable for various platforms are:

Ground: 2 MHz to 18 GHz
Surface Ships: 10 kHz to 18 GHz
Submarines: 10 kHz to 18 GHz
Aircraft (Army and Navy): 10 kHz to 18 GHz
Aircraft (Air Force): 2 MHz to 18 GHz
Space: 10 kHz to 18 GHz

By the numbers, limits imposed on emissions are severe and well below most commercial standards. The numbers however, do not tell the entire story, because test values measured are peak values, not average or quasi-peak. Measurements are also made with antennas positioned 1 meter away from the edge of the test set up.

In short there is not an apple to apple comparison that can be made between RE102 and other standards; the emission limits are lower, the frequency ranges are larger, and the measurements are performed in a more severe manner.

Special Test Requirements for AIAA S-121A

AIAA S-121 specifies general design practices and sets recommended verification and validation requirements for space vehicles and launch vehicles. This standard can be used for tailoring MIL-STD-461 methods for space applications that may exceed those of MIL-STD-461. This can often be the case for radiated emissions where the limits for certain frequency bands are extremely low.

To achieve these measurements, tailored testing involving scans at reduced Resolution Bandwidths (RBW). Performing these tests requires detailed communications with test facilities to ensure that testing is performable and to calculate required time for test performance.

Getting it Right

While RE102 testing should be performed as early in product development as possible, it is important that the test item be as representative as possible. This means that enclosure, PCB revisions, firmware, software, and cabling should be fully representative of the final product. Care should also be taken in creating the ability to simulate normal modes of operation so that testing can be performed on the Equipment Under Test (EUT) that reflects its intended use.

All of these parameters should be reflected in an Electromagnetic Test Procedure (EMITP) that is constructed in accordance to MIL-STD-461 requirements as described in DI-EMCS-80201. Other important data for inclusion in the EMITP are descriptions of stimulation and monitoring equipment, operating frequencies, performance checks, and a description of cable types complete with construction details.

Facing the Music About MIL-STD-461 RE102

The simple fact is that most product developers do not pass MIL-STD-461 RE102 testing the first time. Retest and redesign cost money and time. Adding patchwork cures such as filtered connectors can add significantly to product cost and often not provide the required attenuation. Often the most cost effective solution is to perform an evaluation of the product to assess sources of the emissions and make design changes to mitigate them before they can couple onto wiring and power sources.

CVG Strategy Experts

Our experts at CVG Strategy have extensive experience in EMI/EMC testing for a number of industries and products, both military and commercial. We also have expertise in testing for space requirements including AIAA S-121A. Our industry experts can assist in developing tailored test plans, test witnessing and troubleshooting. We can also provide design analysis and guidance for product compliance.

Our EZ-test plans are available for military applications for EMI/EMC and environmental testing. Our Electromagnetic Test Procedures are recognized by A2LA Certified Test Labs as reliable and comprehensive. We have included, in addition to guidance from the standards, additions including best practices which we have learned in test program management of equipment designed to Department of Defense standards.

CVG Strategy is a consultancy offering coaching, mentoring, training and program development focused on areas including Business Process Improvement, ITAR and Export Compliance, Cyber Security and Quality Management Systems.

Maintaining a CMMC Program – Best Practices

January 25, 2023December 20, 2022 by Jamie Hamilton

Maintaining a CMMC program requires that organizations engage management system principles in their daily cybersecurity programs. These activities will be essential for Department of Defense (DoD) contractors to remain compliant.

Current CMMC Requirements

Currently CMMC 2.0 requirements are divided into three levels of compliance:

CMMC Level 1 – Foundational is comprised of the 17 practices described in FAR 52.204-21 and requires an annual self-assessment.
CMMC Level 2 – Advanced is comprised of 110 practices which are aligned with the NIST SP 800-171 Revision 2 This is a set of security practices and security standards for non-governmental organizations that handle Controlled Unclassified Information (CUI). It requires that a third-party assessment by conducted every three years for information deemed critical for national security. It also requires an annual internal assessment
CMMC Level 3 – Expert includes over 110 practices based on the NIST SP 800-17 cybersecurity standard and includes further controls. There is also a requirement for triennial assessments conducted by government representatives.

Upon further investigation, one will find that NIST SP 800-171 involves references to over half a dozen other documents which are comprised of thousands of pages. While these documents describe the implementation of controls and development of a risk management framework, they often fail to provide solutions easily integrated into business practices.

The Dynamics of Cybersecurity

Maintaining an Information Security Management System (ISMS) requires that the organization conduct regular risk assessments. These assessments should include internal and external factors that are regularly in flux. These would include external threat dynamics and changes in the systems and locations of CUI within the organization.

The organization should also consider third parties involved with the organization. These would include contractors and vendors who may impact the confidentiality, integrity, or availability of information. Regular review of these external providers is advisable.

Beyond Technology

The weakest link in a cybersecurity program can often not reside within the digital realm. People and places provide very real risks that can be easily overlooked. Reviews should regularly be given to screening of persons who will have access to CUI.

Those who have been screened should receive sufficient education and training on information security policies and practices. Physical controls should be regularly reviewed to ensure that areas are secure, that clear desk and clear screen practices are being employed.

The Importance of an Internal Audit

Internal audits are utilized in businesses to access the organization’s ability to maintain compliance. These audits should be conducted regularly and their criteria and scope should be adequately defined. They should include an examination of procedures and security plans to evaluate their effectiveness and whether they are being implemented in actual operations as envisioned. The findings from these audits should be presented in a way that is relevant to management as these audits serve as a major input for management review.

The Role of Management Review

It is essential that management be involved with a cybersecurity program to ensure that requirements are integrated into organizational processes. Management must maintain responsibility in seeing that all objectives are met and that the program has sufficient resources. To make these decisions it is necessary that all functions of the program are monitored and measured.

Management review should consider actions of previous reviews to ascertain their effectiveness. They should also changes both within and external to the organization that may effect information risks. Considerations should also be given to incidents and events that may have occurred so that improvements to the program can be instituted.

CMMC in Action

Much emphasis has been placed on implementing CMMC and for good reason. It is of great national security that important information be kept out of the hands of hostile nation states. However, maintaining a CMMC program, once put in place, will require continual due diligence. This will require a coordinated effort by all parties and functions within an organization.

CVG Strategy Information Security Management System Consultants

To assist businesses meet the challenges in maintaining a CMMC program, CVG Strategy has developed an approach that combines the requirements of Cybersecurity Maturity Model Certification compliance with the ISO 27001 information security management system. This provides a coherent methodology for implementing and maintaining essential cybersecurity for businesses of any size.

Electrical Power for MIL-STD-810 Testing

December 15, 2022 by Jamie Hamilton

Electrical Power considerations for MIL-STD-810 testing create a new level of detail for functional and operational tests. The standard has placed increased emphasis in recent revisions, to changes in voltage, frequency, phase displacement, and other power deviations that are expected to be present in the normal operation of the device to be tested.

Guidance for these power fluctuations can be found in the following standards:

MIL-STD-704 Aircraft Electrical Power Characteristics
MIL-STD-1275 Characteristics of Volt DC Input Power to Utilization Equipment in Military Vehicles
MIL-STD-1399 Interface Characteristics for Shipboard Equipment
RTCA DO-160 Environmental Conditions and Test Procedures for Airborne Equipment

Where these electric power system fluctuations could cause test item failure or pose a significant threat to the safety of personnel it may be necessary to perform an electrical survey of the intended platforms power characteristics.

MIL-STD-810 Testing Purpose

MIL-STD-810 Environmental Engineering Considerations and Laboratory Tests, is a series of laboratory methods to verify and validate equipment for a wide variety of environments. As such the standard places a heavy emphasis on tailoring testing to replicate, as nearly as possible, environmental stresses that will be present in the intended environment. Furthermore it stresses, where applicable, to examine the synergetic and cumulative effects that may affect equipment operation.

Method 520 Combined Environments

Electrical power fluctuations may affect the operation and reliability of equipment. These effects may be more pronounced when combined forcing functions are present such as, high temperature, low temperature, altitude, and humidity. Method 520 Combined Environments provides information on these electrical stresses that is applicable for testing in other methods.

Method 520 is intended for evaluation of equipment for utilization on aircraft. This method includes procedures for Engineering Development, Flight or Mission Support, and Platform Envelope. This method considers electrical power stresses incurred from ground support equipment and during mission profiles. Specific conditions it considers are:

Normal AC system stresses
ON/OFF cycling during normal operation
Mission related transients within platform electrical systems
Safety related stresses for abnormal or emergency conditions for flight critical and safety critical components

These factors can then be included in a mission profile so that electrical power fluctuations can be integrated into a mission profile that is included in laboratory testing. This approach can be utilized for testing of other equipment types such as military vehicle, ground stationary, or shipboard where the equipment is mission critical or safety critical.

The Role of Developmental Test and Evaluation

MIL-STD-810 is intended for developmental test and evaluation of equipment intended for use in military systems. It is also utilized in commercial industries where rugged equipment is essential. To ascertain which testing should be performed and determine test parameters it is essential to engage in a tailoring process. This process integrates measured data from specific areas of intended use and data compiled in Part Three of the standard. This data is collected in a Life Cycle Environmental Profile (LCEP).

An LCEP is an analysis of the environmental stresses likely to be encountered during the entire life of a product, from manufacturing to end of life. It serves as an input for a Environmental Issues/Criteria List (EICL) which is a collection of justified environmental parameters for design and product test. These stresses include those found in logistical, tactical, and operational phases.

Once this analysis is completed, Detailed Environmental Test Plans can be created that detail the exact procedure to be performed, operational and functional test to be run, essential data to be collected, and specific pass/fail criteria for the Unit Under Test (UUT).

CVG Strategy Test and Evaluation Experts

CVG Strategy engineers can help you integrate fluctuations in electrical power for MIL-STD-810 testing. Our experts at CVG Strategy have extensive experience in Climatic/Dynamic and EMI/EMC testing for a number of industries and products, both military and commercial. CVG Strategy specializes in Independent Developmental Testing and Evaluation including development of Test Plans, Test Procedures, Test Witnessing and Troubleshooting.

Huawei and ZTE Designated Threats to Security

January 3, 2023November 29, 2022 by Jamie Hamilton

The Federal Communications Commission (FCC) and Homeland Security Bureau have designated Huawei and ZTE as threats to U.S. national security. Because both Chinese companies are subject to the Chinese Communist Party, they are required by law to cooperate with China’s intelligence gathering activities. China has developed an arsenal of cyber capabilities to target U.S. information security. The use of these companies’ products therefore allows the communist party to exploit network vulnerabilities and compromise critical communication networks.

FCC Prohibits Import of Telecom Equipment

On November 25, 2022 the FCC announced that it had adopted final rules to bar the sale or import of telecommunications equipment manufactured by Huawei and ZTE. It also included products from Dahua Technology Hangzhou Hikvision Digital Technology Co. and Hytera Communications. This action was unanimously approved by the four FCC commissioners. This is the first time in history that the FCC has voted to prohibit electronic equipment to protect national security.

While protecting government concerns, the actions taken do not provide complete protection from questionable devices. The ban does not block all products from these companies but focuses on equipment intended for public safety, government facility security, critical infrastructure surveillance, or national security purposes.

The United States is not alone in these bans. The United Kingdom, Canada, Australia, and New Zealand have also acted against Chinese companies involvement in telecommunications, especially equipment involved with 5G technologies. This action will likely bring to focus banning other equipment generated by hostile state-controlled companies.

Similar actions by the U.S. federal government are taking place against Chinese firms as the FBI has voiced concerns about TikTok’s use of U.S. citizens’ user data to the House Committee on Homeland Security by Director Christopher Wray. The Chinese owned social media app currently has over one billion monthly users. Among the FBI’s concerns is that the Chinese government could conduct influence operations with the app or use it to gain control of millions of user devices.

FCC Bans Universal Service Fund For These Companies

The FCC banned the use of the agency’s Universal Service Fund for the purchase services or equipment from Huawei and ZTE in 2020. This fund is currently 8.3 billion dollars per year and is used to provide affordable communications for schools, libraries, and rural health care. At that time carriers receiving monies from the fund were required to purge their networks of such equipment.

At that time both agencies claimed ample evidence justifying these actions. In fact the agency spent 1.9 billion dollars in 2021 to remove Huawei and ZTE gear that was being used in U.S. rural areas.

Huawei No Stranger to U.S. Scrutiny

The Bureau of Science and Industry (BIS) restricted Huawei’s semiconductor manufacturing capabilities in May of 2020. BIS took this action to prevent the company from acquiring semiconductors that are the direct product of U.S. technologies and software. These technologies now fall under the Export Authorization Regulations (EAR). In the same year Homeland Security prohibited the company from engaging in government contracting services under the Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment.

The Department of Justice also prosecuted a case against the company for participation in a fraudulent scheme to export banned U.S. goods and technologies for its business in Iran. Although Huawei denied these allegations, company records show that the company was directly involved in these actions.

CVG Strategy Cybersecurity Solutions

FCC concerns about Huawei and ZTE illustrate the severity of cybersecurity threats to businesses in the United States. IT solutions alone are not sufficient to combat these forces. Viable solutions include all stakeholders in an enterprise. They include people, policies, procedures, risk analysis, incident responses, and an internal auditing process that yields constant improvement.

CVG Strategy provides cybersecurity consulting and training for large and small organizations. Our experts can tailor a program using risk management process to identify information assets and interested parties. We can create the documentation and provide the essential training to establish your ISMS and guide you through certification audits.

CVG Strategy also provides consulting services for NIST 800-171 and CMMC Certification for those businesses and institutions providing services to the Department of Defense and other government agencies.

MIL-STD-810 Classes Are Available

October 28, 2022 by Jamie Hamilton

CVG Strategy MIL-STD-810 classes will provide you with the ability to develop and conduct an environmental test program. Our two day course not only provides you with valuable information about climatic and dynamic test methods but also includes training in the methodology to correctly apply test tailoring. This course is available online or onsite. Ample time is available for questions and comments so that participants are encouraged to keep engaged. Check here for our online Training Registration Schedule.

Course Description

In this two day course you will learn:

The history and evolution of MIL-STD-810
Use of Parts I of the standard to support test program development and test tailoring
Use of Part III of the standard to evaluate expected climatic conditions
How to conduct a Life Cycle Environmental Profile
Developing a Detailed Environmental Test Plan (DETP)
Preparing for Laboratory Testing
Considerations for vibration test fixtures
Description and purpose of each test method

MIL-STD-810 Applications

MIL-STD-810 Environmental Engineering Considerations and Laboratory Tests is comprised of 29 test methods that address a broad range of environmental conditions. These methods include climatic testing such as high and low temperature, humidity, salt fog, and sand and dust. The standards also provides test methods for evaluating the effects of dynamic stressors such as vibration, shock, and acceleration.

This important standard has been used by product developers in the the United States and internationally to evaluate both defense and commercial products’ ability to perform as designed when subjected to the environmental stressors that are expected in their life cycle. This testing can therefore verify and validate the environmental worthiness and overall durability of a system design.

Test Program Tailoring

MIL-STD-810 does not impose test specifications. Instead, it describes the environmental tailoring process that results in realistic materiel designs and test methods. This process combines requirements and information derived from Whole Life Assessments (WLA) to provide criteria for selection of appropriate test methods. It will also provide criteria for selecting appropriate severities and durations to perform for each test.

CVG Strategy Test and Evaluation Expertise

Our team of test and evaluation experts can assist you in creating a meaningful test program that meets requirements and prevents costly failures at the operational test stage. CVG Strategy provides an array of services to help you with environmental and EMI/EMC testing.

Our instructors have decades of experience in laboratory test and evaluation of military and commercial products. We understand the importance of testing and getting a properly designed product to market in a timely fashion.

In many cases, testing requirements can be met or enhanced through compliance by analysis. Such analysis can involve computer modeling and simulation, acceptance by similarity, or testing of coupon samples. These types of analysis can also serve to identify design deficiencies early in product development and thereby streamline product to market schedules.

Restructured ITAR Streamlines Export Regulations

May 21, 2025October 26, 2022 by Jamie Hamilton

The Directorate of Defense Trade Controls (DDTC) has restructured ITAR in an effort to streamline the regulations and clarify definitions. While no substantive changes were made to the International Traffic in Arms Regulations (ITAR), revisions in definitions may effect those under the regulation’s purview.

Changes to Part 120 – Purpose and Definitions

Part 120 of the ITAR has received massive reorganization. This section is now broken up into three parts; General Information, General Policies and Processes, and Definitions enumerated as subparts A through C. Subpart A – General Information details purpose and legislative authority for the regulations. Subpart B – General Policies and Processes provides an overview of general policies and processes within the regulations. Subpart – C Definitions provides a centralized locations for terms used throughout the document.

Prior to this revision, definitions had been scattered throughout the regulations. They are now arranged in Subpart – C in a logical order proceeding from larger conceptual items to those of lesser importance. Subsequently those definitions have been removed from other sections. Additionally, these terms have undergone clarification and been moderately reworded. Examples of terms that have undergone revision include:

Defense Article
Defense Service
Technical Data
Public Domain
Compositional Terms
U.S. Person
Foreign Person
Regular Employee
Specially Designed
Export
Reexport

Missile Technology Control Regime

The Missile Technology Control Regime (MTCR) Annex which had previously been a part of the ITAR has now been removed in its entirety. The content of this annex is now reflected with notations in the United States Munitions List (USML). Articles enumerated in the USML that relate to MTCR controls are now annotated with (MT).

CVG Strategy Export Compliance Services

Because the the DDTC has restructured ITAR, providers of military goods and services will have to make adjustments to their export compliance programs. This will involve adjustments to program documents and assessing revised definitions to assure that compliance requirement are met and maintained.

CVG Strategy, LLC is recognized the world over as the premier provider of customized Export Compliance Consulting, Export Compliance Programs, and Training that address critical U.S. Government and Canadian laws and regulations, from Export Administration Regulations (EAR), to the International Traffic in Arms Regulations (ITAR), Office of Foreign Asset Controls (OFAC), Canadian Goods Program (CGP) and other regulatory agencies.

CVG Strategy ITAR and Export Compliance experts have managed manufacturing and distribution businesses and have worked for multi-national organizations. CVG Strategy’s experts are not ex-government employees, they understand the needs and goals of small to medium-sized operations in managing compliance requirements. They also have expertise in the implementation and maintenance of a wide variety of management system standards.

Vibration Test Fixtures – A Reason For Concern

September 2, 2022September 2, 2022 by Jamie Hamilton

The Importance of Vibration Test Fixtures

For most projects, the design of vibration test fixtures is often left to the last minute. Regardless of your industry, vibration testing is one of the most important tools in product test and evaluation. A well designed fixture will provide ample rigidity to prevent resonances that can result in product over test. It will help provide confidence that the vibration encountered by the unit under test is representative of the required spectrum.

Using you own

Using your own vibration test fixture as opposed to using one from a test facility has many benefits. Fixtures laying around test labs are often drilled out and adapted for any number or customers’ immediate requirements. If retesting is required, having your own fixture assures you of a more repeatable test regardless of the test facility you may use.

The same fixtures can also be used for shock testing where rigidity and strength are requirements. Using vibration test fixtures in environmental chamber tests for can facilitate proper orientation of equipment and prevent accidental damage to interconnected test items during removal from the chamber.

Designing your Fixture

Rigidity

Rigidity is the major consideration in vibration fixture design. A microscopic deflection in any part of the fixture can result in alarming resonances and nulls. Aluminum is an excellent material for vibration test fixtures as it provides the required rigidity while minimizing weight. Consider the intended orientations of test items and provide mounting holes for test items so that they can be easily installed and removed.

Weight

Weight is also a consideration when designing a fixture. This is particularly the case if multiple units undertest are to be tested simultaneously. Material selection can help reduce the overall weight requirements for the vibration table. Aluminum is a good material for most fixtures. It is relatively inexpensive and is light as compared to steel. It is easily worked and can be constructed to provide the required rigidity.

Magnesium provides the best material for tensile strength to weight ratio. It also has better dampening at high frequencies. It is however, more costly and is not as easy to machine. It is therefore usually reserved for high test performance requirements.

Computer Modeling

A well designed fixture will provide repeatable testing and provide the required excitation to the product being tested without resonances or nulls. To accomplish this, computer modeling should be performed. These evaluations are will ensure that the fixture has a minimum of harmonic distortion over the bandwidth of planned testing.

Validating your Fixture

Before using your vibration fixture in testing it is beneficial to perform a resonance scan to check for any unwanted responses. This is accomplished by attaching multiple accelerometers to the fixture, and sending low-level random signals that cover the frequency range of your intended test.

CVG Strategy Experts

CVG Strategy engineers can design and build vibration fixtures to meet you specific test requirements. We have decades of experience in vibration and shock testing. Let our expertise keep your test program on schedule by letting us assist you with your test and evaluation needs.

Our experts at CVG Strategy have extensive experience in Climatic/Dynamic and EMI/EMC testing for a number of industries and products, both military and commercial. CVG Strategy specializes in Independent Developmental Testing and Evaluation including development of Test Plans, Test Procedures, Test Witnessing and Troubleshooting.