Jamie Hamilton - CVG Strategy

EMC Test Plans, A Requirement for Proper Testing

February 2, 2026January 21, 2022 by Jamie Hamilton

EMI/EMC Test Plans

EMI/EMC Test Plans are important in preparing for your trip to the lab. The test plan should communicate all relevant information about testing requirements and the nature of the system to be tested. This will allow the test laboratory to sufficiently assess the requirements needed to complete testing. These requirements include: size of chamber, number of antennae positions, numbers of cables to be tested, power supplies, and specific measurement and susceptibility equipment.

Equipment Modes of Operation

Representative functionality is a requirement in EMI/EMC testing for both commercial and military applications. The EMI/EMC test plan should include a description of all modes of operation that the Equipment Under Test (EUT) is to be tested. The plan should also provide a description of all peripheral and support equipment required to attain this functionality.

A description of the EUT’s normal operation should be defined for susceptibility testing. This description should include any accepted deviations from normal operation so that an assessment can be made in evaluation of susceptibility.

Standard Specific Requirements

Every standard will have requirements for EMI/EMC test plans. These include: product identification, description, power requirements, cable requirements and descriptions. Certain standards, like MIL-STD-461, have very detailed EMI/EMC testing requirements and require specific information to be present in the test plan.

The Value of Proper Test and Evaluation Documentation

Product Test and Evaluation is a critical step in any product development program and a sizable investment of resources. Properly prepared test documentation will help ensure that the testing performed will both verify and validate a product. Test plans are essential for proper execution of a test by defining tasks to be performed by both the test facility and the test witness. They also provides the necessary information for the lab to create a viable Test Report which is a necessary record of your product’s conformity to applicable requirements.

CVG Strategy Test Plan Templates

CVG Strategy offers Test Plan Templates for EMI/EMC and Electrical Compatibility Testing. These plans have been developed for MIL-STD-461, MIL-STD-1275, MIL-STD-1399, and MIL-STD-704.

EMI/EMC and Electrical Test Plan Packet

Test Plan Template (protected PDF). This document provides essential information concerning: Equipment Under Test (EUT) set up, execution of each procedure, pass/fail criteria, and tolerances per the relevant standard. All test plans are written per the requirements of DI-EMCS-80201C.
Test Plan Addendum (Word Document). This document is to be completed by the customer. It addresses equipment to be tested specific information including: EUT Description, EUT Set up, Modes of operation, and Performance Checks.
Test Lab Data Sheet (PDF form). This document is used to document procedures to be performed and essential test parameters. It also documents test facility report requirements per DI-EMCS-80201C.
Test Label (Word document) This label is to be used to identify the test performed in photographs.
Tests to Be Performed (PDF form). This form communicates to the test facility all test procedures to be performed during test sequence.
Procedure Specific Worksheets (PDF form). These worksheets are included where appropriate to assist the test witness in recording test events.

CVG Strategy

Our experts at CVG Strategy have extensive experience in EMI/EMC. We can provide requirement analysis, write EMC test plans, perform test witnessing, and provide troubleshooting and analysis of EMI/EMC test failures.

We also have expertise in Environmental testing and evaluation of product design in a number of industries and products, both military and commercial. CVG Strategy specializes in Independent Developmental Testing and Evaluation including: Development of Life Cycle Environmental Profiles, Test Plans, Test Witnessing and Troubleshooting.

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.

Quality Management System Documentation Creation

January 20, 2022 by Jamie Hamilton

ISO 9001: 2015 Quality Management System Requirements

Proper documentation is the cornerstone of ISO 9001:2015. Creating a system of documentation that is appropriate to your company’s requirements is crucial. This is because the documentation defines the manner in which it will conduct business. Paying attention to the design of your Quality Management System (QMS) at the offset can provide an efficient system that avoids a cumbersome bureaucratic framework.

Types of documents that comprise ISO 9001:2015 documentation are:

Scope Statement
Quality Policy
Quality Objectives
Process Flowchart
Work Instructions
Records

Fitting the Documentation to a Company’s Requirements

The formation of each of these categories is critical and requires detailed analysis to properly implement. There is no specific requirement as to format or layout. Because each company has a unique business model, “cookie cutter” methods of implementing a quality system can have diminishing returns.

Quality Management System Documentation should be created understanding the context of the organization. This requires that all stakeholders be included. Moreover it should be concise and user oriented.

ISO 9001:2015 documentation provides instructions on how your QMS is run and ultimately how your company is run. Therefore, properly structured documentation can actually make your operations easier. This is because well designed program can integrate ISO-14001, lean methodologies, and regulatory requirements into your QMS.

Defining a Continuous Improvement System

An ISO 9001:2015 QMS, if well incorporated and conceived in its documentation, is a powerful tool that can enhance a business’s potential by creating intelligent processes, quality products, and a satisfied customer base.

As your company grows, so too will its QMS. A program started out on the right path can therefore easily grow to facilitate new aspects and players in your company’s scope, objectives, and goals. It can also adapt to non-conformities in your products and services that arise and create viable opportunities for improvement.

Control of Documented Information

Documents included in a QMS include those specified by the standard and those deemed necessary by the organization to support its activities, products, and services. Once created, these documents require controls to ensure and maintain their validity. These controls include mechanisms for identification, review, and approval.

This information is then required to be readily available to its intended users, to be appropriately preserved, and have effective version control. These document control mechanisms must themselves be documented.

Evaluation of Effectiveness

Once a QMS is defined it can be put into action and evaluated. These evaluations assess the ability of the polices and procedures to meet customer requirements and manage risks. When conformity of products and services or the degree of customer satisfaction is found to be less than desirable, improvements to the quality management system and its documentation can be executed.

These evaluations can be the result of monitoring, measurement analysis, or internal audits. The results from these findings are to be reviewed by the management of the organization so that relevant solutions can be developed and discussed.

Benefits of ISO 9001:2015

Competitive advantage

A properly tailored QMS ensures that business objectives constantly feed into your processes and working practices. By establishing a suitable framework around the context of organization and effectively implementing assessments and evaluation, a Quality Management System can evolve as your business grows.

Improves business performance

Having a comprehensive ISO 9001:2015 QMS helps your managers to raise the organization’s performance above and beyond competitors who aren’t using management systems. The certification also makes it easier to measure performance and better manage business risk.

It establishes criteria for expectation for your supply chain in terms of product quality and dependable delivery. It also instills confidence in your brand by consistently meeting customer requirements.

Quality Management Attracts Investment

Achieving ISO 9001 certification can greatly enhance brand reputation and can therefore be a useful promotional tool. It sends a clear message to all interested parties that your company committed to high standards and continual improvement.

Saves you money

Evidence shows that the financial benefits for companies that have invested in and certified their quality management systems to ISO 9001 include operational efficiencies, increased sales, higher return on assets and greater profitability. Other saving can be gained by effectively identifying and mitigating risks such as product liability and product recalls.

CVG Strategy QMS Consultants

CVG Strategy quality experts focus on processes and process improvement in all our work. Understanding Quality Management System Documentation development is a fundamental aspect of our work as consultants, helping our customers make their business run more efficiently and improving customer satisfaction.

There are many consulting companies providing support in ISO 9001:2015. What sets CVG Strategy apart from the rest is our approach. We fine-tune our statement of work depending on your capability and goals. Some clients have us serve as an advisor while they generate the documentation and implement the program themselves.

Many of our clients outsource the Quality Manager role to one of our experts, and we write the quality manual and supporting documentation set and provide all the training. Some use our expertise to include other quality guidelines and standards into their ISO 9001:2015 QMS including food, hazardous materials, and products for department of defense.

ISO 27001 Prevents Cyberattacks – ISMS for Data Security

January 20, 2022January 19, 2022 by Jamie Hamilton

ISO 27001 Prevents Cyberattacks

Implementing an ISO 27001 Information Security Management System (ISMS) prevents cyberattacks. The Ponemon Institute in a 2017 study found that a typical firm experiences 130 security breaches each year.

Mitigating these breaches requires more than advanced IT practices, it requires a dedicated management system. ISO/IEC 27001 is such a system. It includes processes for human resource security, physical and environmental security, and dealing with information security incidents.

The Real Cost of Cyber Attacks

The Cost of Malicious Cyber Activity to the U.S. Economy , released by the Whitehouse in February of 2018, estimates that such attacks cost the U.S. economy between $57 billion and $109 billion in 2016. In 2021 an insurance company paid out $40 million in ransom. However, these attacks can inflict damage that is difficult to assess or quantify in dollar amounts. While most incidents are kept out of the public eye, a few attacks, like the Colonial Pipeline attack in May of 2021, do make headlines.

What is ISO 27001?

ISO 27001 is an international standard and widely accepted Information Security Management System. The role of an ISMS is to preserve confidentiality, integrity and availability of information. It accomplishes this task by applying risk management processes. An effectively tailored program can meet this challenge because it is part of the organization’s processes and management structure.

Implementation of an effective ISMS requires an assessment of the organization’s objectives, security requirements, and organizational processes. These assessments include a consideration of the size and structure of the organization so that the ISMS is scaled to meet the needs of the organization.

Once these influencing factors have been defined a risk assessment can be conducted. This process should:

identify the information security risks
identify the risk owners
assess the potential consequences of an undesired occurrance
assess the realistic likelihood of the occurrence
determine the levels of risk
establish priorities for treatment of the risk (e.g. implementation of information security controls)

The Advantage of Implementing an ISMS

Because ISO 27001 is configurable to your company’s requirements it is an effective means of organizing data security. This is because it includes a complete process and involvement of all stakeholders in monitoring and preventing cyberattacks. ISO 27001 also includes training to maintain a high state of awareness for all employees.

An ISMS can readily address numerous issues because centers it around policies and processes that are adopted from top management down and includes all stakeholders including third parties.

As and example, a continual challenge of organizations is to ensure that software is up to date. However, this can be a challenge in organizations because of segregation of tiers and organizational turf battles. With an effective ISMS these issues are identified and dealt with at a management level and communicated through policies, procedures, and work instructions. Additionally, because metrics are established for criteria, monitored, and analyzed, deficiency in processes can be identified and remedied.

The security of data is not only of great concern to your organization. It is of interest to your customers, investors, and partners. ISO IEC 27001 certification shows that your company is a responsible partner and maintains an active interest in monitoring and mitigating cyberattacks.

CVG Strategy Cyber Security Consulting and Training

Cyber Security Consulting

CVG consultants have over a decade of experience with ISMS, Quality Management Systems (QMS) and Export Compliance. We understand that each business has a unique set of requirements that demand tailored solutions. Developing these solutions assessing an organization’s culture and involving all stakeholders. Using this information, we can develop programs that are effective and can adapt as a business grows.

Cyber Security Training

Training is an essential component for any viable ISMS. Despite major advances in organizational cyber security, human error continues to be a major cause of data breach.

While more sophisticated variants of malicious software are being developed, phishing remains a prominent way for hackers to gain access to sensitive information. Thus, a very well designed cybersecurity framework can be defeated by an employee clicking on an email attachment. This is a cause of increased concern as the remote workforce continues to expand.

Proper cyber protocols must be consistently reinforced through training that is informative and engaging. Effective training should include review of basic procedures such as using appropriate network security and not allowing unauthorized access to work areas. It should also include a review of all ISMS policy and procedure changes.

CVG Strategy has been involved in business training for over a decade. Our experts take pride in effective and engaging training sessions that ensure that participants retain important information.

Product Test Standards and Specifications

February 2, 2026January 18, 2022 by Jamie Hamilton

Using Product Test Standards to Develop a Test and Evaluation Program

There is a seemingly endless amount of product test standards and specifications. These documents set criteria for compliance, provide guidance for evaluation, and sometimes assist in the development of analysis and test programs of both consumer products and military products. They are all constantly evolving as new revisions are released periodically.

Some product test standards offer very clear and concise parameters for product evaluation. Other test standards can be vague in the details of their requirements. The quality of writing and organization can also greatly vary. Many have annexes and appendices full of extremely in depth information that can clarify a test’s methodologies and intents.

Military Test Standards

MIL-STD-810

MIL-STD-810 – Environmental Engineering Considerations and Laboratory Tests is a prominent standard for the evaluation of climatic and dynamic stresses that occur in the expected life cycle of a defense product. It is a vast standard comprised of 29 test methodologies and numerous appendixes and addendums.

Utilizing this standard fully involves understanding how to tailor testing to adequately reflect expected environmental stresses. The determination of these stresses is accomplished through a Life Cycle Environmental Profile (LCEP). These stresses and their severities serve as inputs to the Environmental Issues/Criteria List (EICL) which in turn provide a baseline for design and aid in the selection of relevant test procedure parameters.

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.

MIL-STD-1275

MIL-STD-1275, Characteristics of 28 Volt DC Input Power to Utilization Equipment in Military Vehicles, specifies test methodologies that simulate the nominal 28 VDC voltage characteristics in military ground vehicles power distribution networks. General Requirements for Equipment Under Test (EUT) include; Operational Voltage Ranges, Transient Waveforms, Ripples, Spikes, Surges, and Starting Disturbances.

MIL-STD-704

This standard is used to evaluate a product’s ability to operate as specified when powered in an aircraft power distribution network. MIL-HDBK-704-1 thru -8 define the test methods and procedures. These each of these documents cover a specific power type such as; AC 60 Hz, AC variable frequency, AC 400Hz, as well as tests for DC power equipment.

MIL-STD-1399 Parts 1 and 2

As with equipment designed for use in aircraft and land vehicle, there are electrical compatibility requirements for shipboard equipment. This standard provides test methodologies to ensure that these products meet requirements for operating in extremely noisy electrical power networks.

IEC 60529

IEC 60529 is a standard used in a variety of industries. This standard provides means of evaluating a product’s ingress protection. Product ratings are defined an IP code. This code 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.

Using Product Test Standards to Develop a Test and Evaluation Program

Each product test standard should be treated by the reader as unique as to its perspective and purpose. MIL-STD-810H for example places a huge emphasis on tailoring parameters of test methods to reflect the environmental stresses the product to be tested will encounter throughout its life cycle. This perspective is not as applicable to standards for compliance where strict parameters and procedures are required.This can present a challenge to managers of test programs,especially those who are working with a product that is being released to new markets.

Allocating the time and resources to grasp the entirety of required test procedures can be daunting. Test laboratories can provide guidance but it is beyond their scope to advocate management strategies to best establish programs fit for your product. Test laboratories cannot give recommendations on product test standards and still remain an independent evaluating body.

CVG Strategy Experts

CVG Strategy has experience in developmental test and evaluation for a wide variety of industries including military and automotive. Because of this we understand looking beyond a test to pass perspective. We can help develop a test program that will return meaningful data and verify a products ability to survive harsh environments.

We also have extensive experience in environmental, EMI/EMC, and electrical compatibility testing for both military and commercial products. CVG Strategy specializes in Independent Developmental Testing and Evaluation including development of Test Plans, providing Test Witnessing, and Analysis. We also provide MIL-STD-810 Training Seminars and Webinars to enable product developers to create tailored test programs.

Export Restrictions on Cambodia Increase in 2022

January 14, 2022January 13, 2022 by Jamie Hamilton

ITAR Restricts Export to Cambodia

The Department of State has amended the International Traffic in Arms Regulations (ITAR) to apply export restrictions on Cambodia. The United States will now deny licenses and other approvals to export and import defense articles and services to Cambodia. These restrictions, which became effective December 9, 2021 reflect a new stance by the U.S.

Specific changes in the final rules apply to CFR § 126.1 country policy chart (d)(2) and adding the nation of Cambodia to paragraph (o). The changes to ITAR also preclude the use of exemptions from licensing or other approval requirements.

The new ruling reflects concerns over the increased presence of the People’s Republic of China (PRC) in Cambodia. These concerns were expressed in a statement by the Department of State on June 1, 2021. The concerns included the China’s military presence and other activities that threaten to erode the sovereignty of Cambodia.

The Department perceives the presence of PRC military bases in Cambodia as a regional security threat. Additionally, government corruption and significant human rights abuses by the country are seen to have negative impacts on U.S.-Cambodia relations. .

Restrictions Also Placed on Cambodia Under EAR.

The Department of Commerce has also increased restrictions on exports to Cambodia under the Export Administration Regulations (EAR). These restriction apply to exports and reexports to, and transfers within the country. The Department of Commerce stated concerns over recent changes in Cambodian foreign policy. It has determined that these changes are posed undermine regional security, U.S. national security, U.S. and foreign policy interests.

Changes the Department of Commerce have made to the EAR include more restrictive licensing of exports to Cambodia:

Under § 742.4(b)(7) Cambodia has been added the list of countries subject to licensing.
Cambodia was added to the list of countries subject to military end use and end user controls in § 744.21.
The nation has been added to the list of countries subject to military intelligence end user and end user controls in § 744.22.
Additionally Cambodia has been include to Country Group D:5 which lists of arms embargoed countries.

Treasury Department Actions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Cambodian government officials. The indviduals, Chau Phirun and Tea Vinh, have been designated by the U.S. government as perpetrators of government corruption and human right abuses.

As a result of these sanctions, all property and interests in property in the U.S. are blocked. This also applies to entities that are owned, directly or indirectly by these individuals. These actions were taken under the intent of the Global Magnitsky Human Rights Accountability Act.

The Treasury Department went further by issuing a business advisory on interactions with Cambodia. Special emphasis was placed on activities involving the financial sector, real estate, casinos, and infrastructure.

A Trend of Things to Come

The growing presence in nations by the People’s Republic of China is not likely to diminish. It is likely therefore, that actions taken by the United States against Cambodia are likely to be taken against other nation states. Additionally, these actions may also be taken by U.S. allies and trading partners.

This stresses the need for organizations to remain up to date in their awareness of change in export compliance legislation and be prudent in initiating transactions in countries where actions of this type are likely to occur.

CVG Strategy Export Compliance Expertise

While many export compliance providers offer programs geared toward compliance with a single set of regulations, CVG Strategy offers a harmonized program that will ensure that your company is compliant to all of these regulations. Furthermore we consolidate this program in a collection of documents that can be integrated into a quality management system.

The CVG Strategy team has over 20 years of experience in U.S. export controls. We can help you develop an ITAR Compliance Program appropriate to your organizations requirements and provide training to prevent occurrences. We also have the experience to assist in guidance when unforeseen incidents do occur to develop strategies to prevent future violations.

DoD Announces CMMC 2.0 to Ease Requirements

November 12, 2021November 10, 2021 by Jamie Hamilton

In an effort to ease requirements for the protection of Controlled Unclassified Information (CUI), the Department of Defense (DoD) has announced CMMC 2.0. This new version of the Cybersecurity Maturity Model Certification (CMMC) program will pare down the scope and requirements placed on the Defense Industrial Base.

Initial CMMC Cybersecurity Requirements Daunting

CMMC was created by the DoD to protect sensitive information by incorporating a standardized approach to Information Security Management. This action was undertaken to respond to increased attacks by adversaries and non-state actors.

Members of the Defense Industrial Base (DIB) had voiced desires for standardization of the DoD marking practices for CUI. They sought to limit requirements to directly relate to contract performance. The DIB has also voiced concern as to how the Defense Federal Acquisition Regulations (DFARS) Interim Rule would be adjudicated. Additionally, many smaller subcontractors had feared that the complexity of the proposed CMMC were creating barriers to participation in the DoD acquisition process.

DoD Announces CMMC 2.0 in Response to Industry Feedback

Jesse Salazar, Deputy Assistant Secretary of Defense for Industrial Policy, said, “CMMC 2.0 will dramatically strengthen the cybersecurity of the defense industrial base. By establishing a more collaborative relationship with industry, these updates will support businesses in adopting the practices they need to thwart cyber threats while minimizing barriers to compliance with DoD requirements.”

Key Features in CMMC 2.0

In March 2021, an internal review of CMMC’s implementation was conducted to respond to more than 850 public comments to the interim DFARS rule. This has resulted in a refinement of policy and program implementation from cybersecurity and acquisition leaders within the DoD. Changes to the CMMC requirements include the following:

Model Now Has 3 Compliance Levels

The first streamlining has been to reduce the compliance levels from five to three. The levels currently proposed are:

Level 1 – Foundational is comprised of the 17 practices described in FAR 52.204-21 and requires an annual self assessment.

Level 2 – Advanced is comprised of 110 practices which are aligned with the NIST SP 800-171 Revision 2 standard. 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

Level 3 – Expert includes over 110 practices based on the NIST SP 800-17 standard and includes further controls. There is also a requirement for triennial assessments conducted by government representatives. Details are still in development for Level 3

Assessment Requirements

The newly released requirements for assessments should support businesses in adopting CMMC. The new requirements will reduce costs for companies at Level 1 and some companies at Level 2 by allowing self assessments to demonstrate compliance.

Emphasis has also been placed on increasing the oversight of third-party assessors to ensure professional and ethical standards.

Increased Flexibility in Implementation

In an attempt to establish a more collaborative partnership, the DoD will now allow companies under certain circumstances to achieve certification by making Plans of Actions and Milestones (POA&Ms). These POA&Ms will require adherence to strict timelines. The CMMC will also now, in some cases, allow waivers for requirements.

CMMC 2.0 Timeline

These changes will be implemented through the rulemaking process. Companies that handle or access CUI will be required to comply once the rules go into effect. As with previous proposed versions of CMMC a public comment period will be in effect. The DoD considers stakeholder input critical to establishing effective cybersecurity standards.

The DoD announced that it intends to suspend the current CMMC Piloting efforts and will not require CMMC in DoD solicitations. Official estimates that final implementation of CMMC may take as long as 2 years.

CVG Strategy Can Help

CVG Strategy cybersecurity experts are here to help small business DoD contractors ready themselves for evolving CMMC requirements. We can assist your organization develop a tailored cybersecurity program and then perform the required assessments.

We understand that each business has a unique set of requirements that demand tailored solutions. Developing these solutions assessing an organization’s culture and involving all stakeholders. Using this information, we can develop programs that are effective and can adapt as a business grows.

Cyber Security Training

Training is an essential component for any viable information security management system. Despite major advances in organizational cybersecurity, human error continues to be a major cause of data breach. Proper cyber protocols must be consistently reinforced through training that is informative and engaging.

Effective training should include review of basic procedures such as using appropriate network security and not allowing unauthorized access to work areas. It should also include a review of all ISMS policy and procedure changes. CVG Strategy has been involved in business training for over a decade. Our experts take pride in effective and engaging training sessions that ensure that participants retain important information.

Using the Tailoring Process in MIL-STD-810

October 27, 2021 by Jamie Hamilton

The Evolution of the Tailoring Process in MIL-STD-810

MIL-STD-810 Environmental Engineering Considerations and Laboratory Tests is a standard for environmental developmental test and evaluation. Its purpose is to provide guidance for the development of analysis and test criteria to evaluate materiel, identify deficiencies and defects, and demonstrate compliance. The tailoring process develops valid test criteria for evaluation of materiel in MIL-STD-810.

In its early revisions, it was a set of test procedures and parameters. It provided defined procedures for testing the effects of environmental stresses. Revision A had one sentence about tailoring. “When it is known that the equipment will encounter conditions more severe or less severe than the environmental levels stated herein, the test may be modified by the detail specification.”

What is Tailoring

The concept of tailoring has evolved in MIL-STD-810. The tailoring process provides input for evaluation based on the life cycle environmental conditions of the specific materiel. Because of the environmental stresses it will encounter, the life cycle of materiel intended for use on the inside of a ground vehicle will be very different life cycle than those on the outside of an aircraft.

It is therefore, the responsibility of the designer of the equipment to assess which environmental effects require testing and what the specific parameters of those tests should be.

MIL-STD-810 provides specific guidance for this assessment by creating a tailoring process. Tailoring is a management process that uses engineering common sense. Moreover, it involves systematically considering all environmental factors on a system throughout its service life to ensure a proper degree of design and test.

Six tasks are contained in the MIL-STD-810 tailoring process:

Define specific managerial roles
Profile the life cycle of the product from transport from manufacture facility to end of life
Document operational environmental information
Document specific environmental criteria
Develop Test Plans
Create Test Reports

MIL-STD-810 also provides guidance for the tailoring process in Part 3 World Climatic Regions. This section provides valuable data to assist in the selection of appropriate test methods and the tailoring of parameters for those methods. These parameters include temperature, humidity, solar irradiance, vibration profiles as well as severities and durations.

Using the Tailoring Process

It is important to profile the life cycle of the product early in product development. The Life Cycle Environmental Profile (LCEP) maps environmental stresses encountered in all phases of the product. This includes logistical transport, storage, tactical transport, and operational. This allows identification of the most critical environmental factors for product specification and evaluation.

These environmental factors serve as input in the tailoring process to select appropriate laboratory test methods, parameters, and procedures of test in MIL-STD-810. Other inputs include specifications from procurement agencies and available measured data.

MIL-STD-810 Training

We offer MIL-STD-810 Training designed for Program Managers, Project Leads, Test Engineers, Design Engineers, and Qualification Test Procedure/Plan Writers. It is also applicable for Test Laboratory Personnel responsible for generating quotes for customers. It covers all of the Dynamic and Climatic tests described in MIL-STD-810.

This class places emphasis on the processes necessary to develop a comprehensive test program. This includes development of 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. These stresses include those found in logistical, tactical, and operational phases.

The LCEP serves as an input for a Environmental Issues/Criteria List (EICL) which is a collection of justified environmental parameters for design and product test.

CVG Strategy Test and Evaluation Experts

CVG Strategy has expertise and experience in using the tailoring process in MIL-STD-810 to assist in the creation of effective product evaluation programs. Furthermore, our test and evaluation team can manage evaluation programs, write test plans, witness testing, and create test report summaries. We have decades of experience in environmental and EMI/EMC testing in both commercial and military applications.

Spyware a Growing Concern for Businesses

October 22, 2021 by Jamie Hamilton

According to a number of leaders in cybersecurity, spyware is becoming an issue of growing concern for businesses. Malwarebytes, in its 2021 report, Malwarebytes 2021 State of Malware Report, observed that business spyware detections increased 51% in 2020. These spyware infections can be found on both computers and mobile devices.

What is Spyware?

Spyware is a type of malware that infiltrates a device to collect sensitive information. Information is collected by monitoring internet activity and using keylogger type technology to relay information to outside parties. This information can be used to track users or to commit cybercrimes.

Often this information is sold to third party data firms without a user’s consent. This data can include various types of personal information including:

Login credentials
Credit Card Details
Account PINs
Clipboard data
Email data
Bank Account Information
Text messages
User location
Activation of device microphones and cameras
Documents and photos

Types of Spyware

There are a variety of types of spyware programs currently being used. Often these pose as legitimate software offerings. These programs use technologies that can range from relatively simple methods that rely on unmitigated software security flaws or highly sophisticated hacks that can compromise advanced security systems. Because these methods employ endpoint attacks they are immune to end-to-end encryption security measures.

Cookie Trackers

Cookie trackers monitor internet browser history. Although this data has been a free target, a growing number of nation states and organizations have made moves to control its collection and use. This includes the European Unions General Data Protection Regulation (GDPR) and ePrivacy Directive (ePR), and the California Consumer Privacy Act (CCPA). These actions have resulted in the terms and conditions additions on websites.

Adware

Adware tracks not only browsing habits but monitors downloads and basic computer user activity. This type of malicious software not only share this information with outside parties but can slow down systems by using processor resources.

System Monitors

System monitors pose an even more malicious threat in that they can often capture vital information such as login credentials, messaging, and basically any information created or received on the device. This can lead to loss of proprietary information and identity theft.

Stalkerware

Stalkerware is software designed to surreptitiously run in the background of smartphones. Its purpose is to keep tabs on activities and report it to an outside party. Data captured can include location, phone calls and text messages, passwords, contacts, emails, and photos.

Security Practices for Preventing Spyware

The Cybersecurity and Ifrastructure Security Agency (CISA) provides the following advice for preventing unintended spyware installation:

Avoid interaction with links within pop-up windows. CISA recommends clicking on the “X” icon in the title bar instead of using the “close” button inside the window.
Select “no” or “cancel” when queried by unexpected dialog boxes that suggest running a program.
Be especially wary of free downloadable software. These programs may not perform as advertised and create security issues. In fact any software should be carefully scrutinized before installation.
Utilize browser security setting preferences to limit pop-up windows and cookies.
Incorporate valid malware protection programs that include anti spyware detection.

Information Management Security Systems

Spyware is a growing concern for businesses and organizations of any size. To effectively mitigate cybersecurity risks and their effects, it is important to institute effective Information Management Security Systems (ISMS).

An Information Security Management System is a collection of policies, procedures, and controls that systematically address information security in an organization. It is a framework based on risk assessment and risk management. The most widely recognized and instituted ISMS in the business environment is ISO 27001. It shares many of the features of a quality management system such as ISO 9001.

CVG Strategy Information Security Management System Consultants

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.

Test and Evaluation for Robustness

October 20, 2021October 20, 2021 by Jamie Hamilton

Test and Evaluation for Robustness

Test and Evaluation for robustness of a product is an involved process. For electrical and electronic equipment an evolution of design engineering evaluation has been required to meet acceptable failure rates for fielded product. Instituting these test methodologies requires looking beyond a test to pass approach.

Robustness in Military Applications

In the military this requirement was apparent following World War II where new materiel had often failed to meet performance criteria when introduced to its operational environment. This led to the creation of AAF Specification 41065 in 1945. This specification was comprised of ten methods for developmental product evaluation with preset parameters. This standard later became MIL-STD-810 Environmental Engineering Considerations and Laboratory Tests.

As this standard evolved, it became more and more apparent to those writing it the limitations of a cookie cutter approach. Environmental issues are far too complicated and nuanced to be easily defined in a manner that is appropriate for all applications. Because of this, every revision of the standard has increasingly stressed the need for tailoring tests to meet the anticipated environmental stresses in the lifetime of the product.

Because industry largely ignored the requirements for tailoring, a tailoring process was created in revision G in 2008. Despite this though, developmental test and evaluation of products has often not been adequately performed. This has led to costly redesigns in operational testing phases and caused delays in final systems.

Part one of MIL-STD-810 now details the creation of a design and evaluation management system. This system identifies environmental stressors expected to be encountered in the life cycle of the product including logistical transport, tactical transport, storage, and operational. Proper implementation of these processes allows for release of product that is capable of meeting its mission requirements.

Robustness in Automotive Applications

As electronics were first introduced in automobiles failure rates were excessive. These failures were caused by climatic, mechanical, chemical, electrical, and electromagnetic stresses in vehicle applications. As the industry moved towards longer warrantied products, emphasis shifted from the detection of failures at the end of the development process to prevention of failures throughout the full life cycle.

This prevention requires designing for ruggedness at concept development with a Zero-Defect Strategy. Here again developmental test and evaluation is seen as essential for success. A test to pass approach that does not return useful data is not desirable. A detailed analysis of this approach can be found in SAE J1211: 2012 Handbook for Robustness Validation of Automotive Electrical/Electronic Modules.

SAE J1211:2021

Like MIL-STD-810, SAE J1211defines a Robustness Validation process that involves both the user and the supplier to define and establish requirements and acceptance criteria based on the end vehicle’s specific application. These requirements and criteria are based on a defined Mission Profile with the goal designing out susceptibility to failure mechanisms.

This Robustness Validation process relies first on knowledge-based modeling simulation and analysis methods in the design phase. These designs are then to be verified and validated testing protocols including test-to-failure and failure/defect susceptibility testing to confirm or identify Robustness Margins

The standard categorizes these failure mechanisms as follows:

Thermal
Mechanical
Radiation
Dust
Humidity
Water
Chemical
Electromagetic Compatibility (EMC)

As with MIL-STD-810 the automotive industry’s approach examines the synergetic effect of environmental stressors. This approach requires a comprehensive analysis when a test and evaluation program is initiated.

Understanding Environmental Stresses

For any application of ruggedness design, an understanding of the environmental stresses involved is essential. This therefore requires an assessment and identification of all probable environmental factors, their frequency of occurrence, and intensities. In MIL-STD-810 parlance this is accomplished through the development of a Life Cycle Environmental Profile (LCEP).

For automotive applications this is done through a Mission Profile. These profiles should include all phases of product life including transit and storage. They should also include lessons learned from similar product histories.

Once these stressors have been identified, their criteria can be used for development of design specification. These criteria are also used to develop a test master plan with relevant stress values to be used in robustness tests.

CVG Strategy

Military and automotive applications require design and test methods that ensure ruggedness. The development of a test and evaluation program that will verify a design and return significant data must be initiated at the concept stage of product development. This is true when ruggedness is required of any product.

Technical Data and Export Law – Canada and the U.S.

March 3, 2025October 18, 2021 by Jamie Hamilton

Technical Data and Export Law

Understanding what technical data is and how it pertains to export law is important for companies doing business in the U.S. and Canada. Both countries have different requirements and regulations controlling how technical data is stored and transferred. Additionally, these regulations are subject to change.

What is Technical Data?

Definitions under U.S. Law

Under the International Traffic in Arms Regulations (ITAR), technical data, which is defined in 22CFR 120.10(4), is information which is specifically required for the design and production of defense articles and services such as drawings, instructions, or other documentation. It also includes software that is directly related to defense articles.

The Export Administration Regulations (EAR), which are administrated by the Department of Commerce, define controlled technical data as an export of technology that is required for the “development, production or use” of items on the Commerce Control List (CCL). Under the EAR transfer of technical data is defined as a Deemed Export.

Under both sets of U.S. export control regulations, transfer of technical data to a foreign nation or foreign persons will in most cases require an export license.

Definitions under Canadian Law

The Canadian Controlled Goods Program (CGP) defines technical data as Technical data is any information, such as blueprints, drawings, plans, computer software or technical documentation that could be developed or adapted for use in military or space equipment.

Canadian Export Regulations for Cloud Service Providers

Canada’s Controlled Goods Program, as of April of 2021, has placed requirements on cloud service providers that provide storage for controlled goods data. These cloud service providers must now be registered regardless of encryption protocols utilized.

Registrants that currently store data on unauthorized servers outside of Canada are required to remove all controlled goods data from the foreign service and move that data to local secure servers or cloud service providers registered in the Controlled Goods Program.

Differences in Canadian and U.S. Requirements

These cloud service requirements contrast with the Directorate of Defense Trade Controls (DDTC) interim final ruling, released on December of 2019, concerning transmissions or storage of unclassified technical data which is controlled for export under (ITAR).

The current ITAR requirements (§ 120.54) allow for storage of unclassified ITAR technical data on foreign servers if end to end encryption compliant with the U.S. National Institute of Standards and Technology (NIST) requirements.

This variance in requirements places increased complexity in compliance programs for organizations that conduct business in both Canada and the United States.

Protection of Technical Information

Both the U.S. and Canada are actively engaged in securing access to export controlled information to protect their national security interests.

In the United States protecting Controlled Unclassified Information (CUI) has been a priority for the Department of Defense (DOD) for many years now. DoD contractor CMMC requirements have been in development since 2015 in an on going effort to safeguard Controlled Unclassified Information (CUI).

In 2020 the Defense Acquisition Federal Regulation Supplement (DFARS), mandated that private DoD Contractors adopt cybersecurity standards according to the NIST SP 800-171 cybersecurity framework as an interim measure until the Cybersecurity Maturity Model Certification (CMMC) is finalized.

CVG Strategy

CVG Strategy is a consultancy dedicated to assisting businesses navigate increasing requirements for export compliance and information security.

Export Compliance Expertise

Navigating international import and export laws can be extremely challenging for organizations. This is especially the case for those whose products are defense related. CVG Strategy export compliance experts have over a decade of experience in assisting businesses establish and maintain export compliance programs.

CVG Strategy has helped companies comply with both U.S. and Canadian regulations. We can answer your export compliance questions to keep your organization in compliance to regulations. We can also provide essential training to ensure that your team is up to date on ever changing export laws.

Cybersecurity Expertise

CVG Strategy is committed to helping businesses protect the United State’s controlled unclassified information by helping them establish effective cybersecurity programs. We know that 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.

ISO 9001 Business Management Beyond Quality

October 4, 2021 by Jamie Hamilton

ISO 9001 provides tools for business management beyond the scope of product quality. Incorporating these tools can help an organization effectively and consistently manage specific issues and requirements strategically. Furthermore, because ISO 9001:2015 requires involvement from top management and relevant stakeholders, it ensures that these issues will be addressed comprehensively.

Context of the Organization

“Context of the Organization”, Clause 4 of ISO 9001:2015, provides a means of encompassing wider business planning activities into a Quality Management System (QMS). This clause places requirements to ascertain, monitor and review both internal and external issues that are relevant to an organization’s specific purpose and strategic direction. The importance of these various factors should be assessed through risk management.

External issues can include an array of concerns including legal, financial, social, regulatory and cultural factors. By identifying these issues when creating a quality program by they can be addressed in a process approach that provides continual improvement.

ISO 9001 Business Management Opportunities

Export Compliance

Organizations providing products and services are subject to a number of export regulations. For exporters in the United States these include the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). These laws prevent export of controlled items to hostile entities. With regards to the ITAR, these include the export of defense related materials.

Violation of export compliance can result in fines, imprisonment, and export debarment (organization not allowed to export). Therefore, export compliance is an important external factor that can be addressed through ISO 9001 business management policies, processes, and procedures. Once these have been implemented they can be monitored so that corrective actions can be taken to prevent violations.

Product Design Protocols

Many industries are faced with specific design protocols requirements. These requirements can involve inputs from customers, engineering, government procurement agencies, sales, and upper management. Such is the case for product developers that must meet standard requirements under MIL-STD-810.

MIL-STD-810H establishes distinct processes for conducting a Whole Life Assessment (WLA) of a product under development. This process is to be initiated at the product concept phase.

Proper implementation of these processes allows for identification of relevant environmental stressors likely to be encountered in the product’s life cycle. These include development of a Life Cycle Environmental Profile and an Environmental Issues/Criteria List. Once these assessments have been conducted, design specifications and testing requirements can be created.

These processes can be incorporated into a quality management system to that is initiated at the concept phase of development. These processes should include all stakeholders to ensure that a complete WLA is conducted.

Implementing ISO 9001 for Your Organization

Achieving the highest possible return on investment is important, regardless of which quality management systems standard you organization implements. Taking advantage of all the features of that standard requires an understanding of Quality Management Systems and the growing number of requirements businesses face in their specific sectors.

Effective management of these requirements in a single program can create a more productive and efficient organization that consistently improve its performance and stay in compliance of regulations.

CVG Strategy Quality Management Expertise

Our Exemplar Global and Probitas Certified Quality Experts provide quality consultation in the Quality and Inspection disciplines to customers across North America. Our quality strategy allows clients new to Quality Management Systems to rapidly implement a tailored system.

We have assisted customers in implementing business management opportunities into their quality management systems by coupling our QMS expertise with our extensive experience in export compliance and product test and evaluation. This allows to readily deliver compliant procedures and work instructions.

CMMC Under Review Before Final Release

January 14, 2022September 16, 2021 by Jamie Hamilton

CMMC Under Review by DoD

The DoD is finalizing changed to the Cybersecurity Maturity Model Certification program (CMMC) in an attempt to sufficiently address national security requirements without overburdening the defense industrial sector. According to an article recently published at the Federal News Network, these changes are to be released soon as a finalized plan of implementation.

Chief technology officer for the deputy assistant secretary of defense for industrial policy, Christine MIchienzi said that We are, again, including feedback from industry on that to make sure that this is the system that is going to be the best system for the department and for industry”.

The Pentagon announced it was reviewing the current approach in April of 2021. This announcement was followed by minor updates in congressional testimonies in June of 2021. Since this time, however, the Department of Defense (DoD) has been silent on its intentions until this latest announcement of reviews. This has raised questions as to the Biden’s administration’s commitment to CMMC achieving its stated goals.

Growing Apprehension Among Defense Contractors

This silence has created apprehension in an industry that has scrambled to meet future requirements without a clear view of exactly what these requirements are to unfold. This has hindered the industry’s ability to create budgets and engage in meaningful strategic planning. Additionally, many smaller subcontractors fear that the complexity of the proposed CMMC may be creating barriers to participation in the DoD acquisition process.

Members of the defense industrial base have voiced desires for standardization of the DoD marking practices for Controlled Unclassified Information (CUI) and limit requirements to directly relate to contract performance.

Another area for concern is the Defense Federal Acquisition Regulations (DFARS) Interim Rule released in September 2020. In a letter to the DoD, industry consortiums ITI, PSC and NDIA stated that it is unclear how this rule has been or will be adjudicated. It then encouraged the DoD to conduct public hearings if further changes were anticipated.

All Parts of CMMC Are Being Reconsidered

The DoD is reviewing all aspects to its approach to CMMC. Included in this reassessment is the CMMC accreditation body’s role. Other options to this could be certification from the Defense Contract Management Agency or self certification at certain CMMC levels.

This further action has muddied the waters as to what the future holds for contractors, subcontractors, and suppliers to the DoD. This is especially the case for for commercial vendors who may defer investments in developing a CMMC program in the midst of such uncertainty. In response to these apprehensions about the scope, timeline, and manner of implementation, the Pentagon has encouraged companies to stay the course as cybersecurity systems will still need to be in place and will require verification and validation.

CVG Strategy Can Help

Bad Actor Foreign Governments like China are making considerable efforts to steal U.S. IP. While the U.S. Counterintelligence Agencies are focused on stopping this in its tracks. But, they cannot do this without industry taking up some of the workload and responsibility.

CMMC will help to secure the supply chain and are critical to plugging the data leaks to bad actors. Cybersecurity must be incorporated across all parts of the supply chain for government contractors, and this is the goal for CMMC. Just like other new standards and requirements, the first contractors who achieve an appropriate level of certification will likely get more and newer contracts over their competitors.

Regardless of the final format of CMMC, a sound cybersecurity system must be in place to ensure conformity. The level of soundness of a system can be accomplished by performing a Supplier Performance Risk System (SPRS) Cybersecurity Assessment. Under the current system, this is a requirement for businesses providing products or services to the Department of Defense (DoD). This Supplier Performance Risk System assessment is to be completed by the contractor before DoD contracts can be awarded.

CVG Strategy is ready to perform an SPRS cybersecurity assessment for your organization. Our Certified ISO 27001:2013 Lead Auditors can help you meet future CMMC requirements. Additionally, CVG Strategy can assist in the development of an effective Information Security Management System ISMS to protect CUI and instill confidence in your clients.

Military Product Testing – Verifying Reliability

March 17, 2021 by Jamie Hamilton

Military product testing is performed at various stages of a products development and service initiation. The earliest phase of this testing is known as Developmental Test and Evaluation. This phase is conducted by the product developer and includes a detailed regime of climatic, dynamic, EMI/EMC, and electrical compatibility test procedures.

The United States Department of Defense (DoD) has consistently had issues with the quality of testing provided by its vendors. Defense systems that fail to meet their required level of reliability are less capable of fulfilling their intended missions and endanger the lives of personnel operating and depending on them. Additionally these reliability issues can delay project implementation, involve costly redesign, and result in higher costs of operation.

As stated in Reliability Growth – Enhancing Defense System Reliability, issues exist with the quality of both operational and developmental test and evaluation currently being performed. By adequately engaging in the preparation, execution, and analysis of developmental test and evaluation, designers of defense materiel can achieve higher levels of reliability, avoid redesign issues, and learn important lessons for future product design specifications.

Elements of a Viable Product Test Program

Knowledge of Applicable Standards

For defense product developers a wide range of defense test standards are applicable. These military standards include:

MIL-STD-810
MIL-STD-461
MIL-STD-1275
MIL-STD-1399-300
MIL-STD-704
MIL-STD-202
MIL-DTL-901

The test program manager should have a good working knowledge of these standards and understand their interrelation in terms of product development. This knowledge should then be applied to the development of a test program that addresses perceived component vulnerabilities and prioritizes design verification testing of those concerns. Ultimately, a test program must be created that addresses all requirements and returns important data for analysis.

Life Cycle Analysis

For environmental testing (climatic and dynamic) MIL-STD-810 “Environmental Engineering Considerations and Laboratory Tests” requires a thorough examination of the stresses likely to be encountered by the product during its service life, including logistical transit, tactical transit, maintenance, and operation. This is accomplished by conducting a Life Cycle Environmental Profile (LCEP). The LCEP along with customer requirements and any measured data provide data for the Environmental Issues/Criteria List.

From these documents a tailored list or Test and Evaluation Master Plan (TEMP) of required test methods with appropriate levels of stress can be created that will establish a basis for required testing.

Test Plan Preparation

Test plans must be developed that inform all personnel involved in testing, including the testing laboratory, of exactly how the test is to be performed, and what data is to be captured. As most testing should be performed with the test item in an operational mode representative of expected service, the plan must include information as how these modes should be executed, monitored and recorded. Additionally procedures for verifying the test items functionality before, during and post testing should be included.

Management of Complex Programs

Military product testing for military equipment involves a large number of mil-std tests. Often these tests will be run concurrently. Some tests can be performed in a few hours, others may require months for completion. Staying abreast of test program activities, addressing failures, troubleshooting and providing root failure analysis are but a few of the responsibilities of a test program manager.

The manager must also coordinate all activities with product development engineers, laboratories, and shipping services. Additionally interim and final reporting of the test program must be created.

CVG Strategy Product Test Consultants

CVG Strategy Test Management experts have extensive experience in military product testing as well as, commercial, aerospace, defense, and automotive product test and evaluation. They have worked with numerous standards that apply to environmental and EMI/EMC testing. They are adept at coordinating with product development teams to provide value added test programs that provide confidence in a products capabilities and reliability.

We can tailor a statement of work to include any number of tasks that might be required. This can include:

Test Standards Technical Support for proposals and customer inquiries
Defining Test Requirements
Design of Simulation and Monitoring Equipment
Development of Required Test Fixtures
Development of Required Documentation
Test Scheduling
Onsite support
Laboratory Test Witnessing
Company representative and advocate at Test Lab
Subject Matter Expertise

Military End User List Added to Export Admin. Regulations

May 13, 2024January 26, 2021 by Jamie Hamilton

BIS Adds Military End User List (MEU) to the EAR

The U.S. Department of Commerce announced on December 21, 2020 that the Bureau of Industry and Security (BIS) will add a Military End User List (MEU) to the Export Administration Regulations (EAR). The MEU can be found in supplement 7 to part 744. The list’s first tranche of entities include one hundred and three military end users, which are from China, Russia, or Venezuela.

Entities listed as Military End Users, as defined in § 744.21, are considered to be directly related to the national armed services of their respective nations. As such, exports, reexports, or transfers (in country) destined to these entities will require a license due to unacceptable risk of diversion to a military force. Applications submitted for license to MEUs will be reviewed with a presumption of denial.

This action by the BIS will assist exporters by notifying them of known entities for which export will likely be prohibited. It does not however, infer that, entities not on the list are cleared. Parties involved in export, reexport, or transfer of goods must still execute due diligence in ensuring that they are not doing business with military end users.

MEU Revised to Add Skyrizon

On January 14, 2021, the Bureau of Industry and Security announced that the Chinese National Offshore Oil Corporation (CNOOC) had been added to the Entity List for intimidation of China’s neighbors in the South China Seas.

It was also announced that Skyrizon had been added to the Military End User List for its continued efforts to acquire foreign military technologies. This action is seen as a direct threat to the U.S. national security and foreign policy.

Further MEU Revisions

The End-User Review Committee, which is comprised of representatives from The Department of Defense (DoD), Department of State, Department of Energy, Department of Commerce, and the Treasury, will convene to add or remove entities to the MEU. Parties named on the MEU will have the opportunity to file petitions as to why they are not military end users or affiliated with military end users.

Related EAR Actions Concerning China

Removal of Hong Kong as Separate Destination

The creation of the MEU was concurrent to the removal of Hong Kong’s status as a distinct EAR destination. On the same day as the MEU announcement, the Federal Register announced that it had implemented amendments to Sections 2 and 3 of Executive Order 13936 had removed Hong Kong’s special status.

This effectively places the region on the same status as the People’s Republic of China, Country Group D, and curtails the export of sensitive U.S. technologies to the region. These actions were taken because, actions taken by China, towards Hong Kong, have undermined Hong Kong Special Administrative Region’s (HKSAR) autonomy. Here again the risk of export to Communist Chinese Military Companies was the overriding concern.

Department of State Sanctions on Fourteen Individuals

On January 22, 2021 the State Department announced that fourteen individuals who are or have been involved in the implementation of China’s National Security law undermining Hong Kong autonomy, are subject to blocking of properties or interests with in United States.

Conclusions Concerning the DEU

The international political stage is in a very dynamic state as China and Russia continue to engage in hostile actions. The MEU provides the U.S. government with an effective tool for exposing entities engaged or cooperating in those actions. As such it serves as a notification to those entities of the immediate consequence of those actions. It also serves as an additional tool for businesses engaged in export, reexport, or in country transfers to screen prospective customers.

CVG Strategy Export Compliance Expertise

CVG Strategy consultants can tailor an export compliance program that meets your organization’s specific requirements. We have extensive experience in ITAR, EAR, Anti-Boycott Regulations, Export Control Classifications, and the Canadian Controlled Goods Program (CGP). We provide a number of services to businesses of all sizes including: Export Compliance Training, Technical Assistance Agreements, and answering your export compliance questions.

Preparing for EMI Testing – Important Considerations

February 2, 2026September 25, 2020 by Jamie Hamilton

Preparing for EMI Testing can save time and money. Most EMI tests do not provide the news we want to hear on the first trip, therefore preparing to go the lab then is a task that should be thought out.

Emissions and immunity testing is an important part of your product development. Successful testing can provide compliance to relevant international standards and allow you to get your product to market. It can also ensure your product is not susceptible to interference that can cause damage, injury, and product recalls.

Pre Compliance Testing

There are many EMC pre-compliance tools available to product developers today. These can provide screening to prevent trips to a lab when a product would clearly fail. They can also aid in troubleshooting to evaluate required design modifications. While these tools can definitely provide an edge for emissions testing they are not as useful for immunity, susceptibility, and power compatibility testing.

Equipment to be Tested

We can start by taking a close look at what the product item we are sending. Is it truly representative of the finished product? Will it be running with representative firmware and software? Are the cables representative of the finished product? All of these factors will greatly effect the veracity and data provided from the test.

Often early manufactured samples of a product will have coatings where they shouldn’t be. Check your test item for unwanted paint or powder coat that could interfere with grounding of enclosures and connectors. Removing paint at the lab is time consuming and time goes by very quickly at the lab.

Have EMI/EMC Test Plans

Another way to prepare for EMI testing is to know what tests are required and understand which sequence of tests are to be run. Write EMI test plans to communicate product specific information among the design team, the test lab, and the customer. These information can include pass/fail criteria for modes of operation to be tested in immunity testing.

In the defense industry, a test plan can be a contract requirement. Aside from documentation of desired procedures the writing of the procedure will reinforce and deepen the Test Witnesses understanding of test details.

The Kitchen Sink

When preparing for EMI testing make sure you have appropriate support hardware to exercise the equipment under test so that operational modes are representative of the product in its intended usage.

Bring extras of everything. If you have had enough forethought to provide extra component places on printed circuit boards near I/O connectors for ferrites and capacitors bring plenty of different values to play with if required. Bringing your own soldering equipment can be useful as well. Always bring multiple samples of the equipment to be tested and extra cables.

Most importantly, bring an appropriate mind set to your EMI test. Everybody wants to bring home a win, but bringing back important data from a test failure is invaluable. Remain flexible and be prepared to change course so that you can best isolate and analyze the causes of failure. This will involve cooperation with lab personnel so developing and maintaining a good working relationship with these people is very important.

CVG Strategy Experts

Our experts at CVG Strategy have extensive experience in Environmental/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.

Components for Hypersonic Applications – Considerations

February 27, 2025September 2, 2020 by Jamie Hamilton

Components for hypersonic applications are required for an increasing number of Department of Defense (DoD) projects. These components and assemblies must be able to function under very demanding circumstances. Typical stresses include altitudes exceeding 100,000 feet, rapid temperature changes, vibration, pyroshock, and acceleration. This provides unique challenges to designers and those involved in test and evaluation.

Design Challenges for Components for Hypersonic Applications

Current defense designs can involve flight speeds of anywhere from Mach 5 (3,800 mph) to Mach 10 (7,600 mph). Future designs may reach speeds near Mach 30 (23,000 mph). This produces high levels of vibration, shock, and heat.

These stresses require that each device for a printed circuit board must be carefully selected. Furthermore, care must be taken in the design of circuit boards to avoid failures at connection points. Care must also be taken to prevent resonances that can destroy components or cause intermittent failures due to to piezoelectric effects.

These requirements for rugged designs are driving development of new cooling, adhesive, and dampening solutions. The outcomes will likely result in revolutionary technologies.

Hypersonic Test and Evaluation Requirements

Often testing for these designs must be performed for both qualification and acceptance of system components. This requires vast resources of test equipment and test facility time. Additionally, because parameters are extreme, equipment capable of performing a test can be difficult to find.

To complicate matters, test values can often fall outside the capabilities of test equipment at both ends of the spectrum. This can be the case with pyroshock where a value is too large for an electodynamic shaker systems but beyond the lower limits of a resonant beam device. Pyroshock is a critical test because it involves dynamic forces with a frequency range extending to 10,000 Hz.

CVG Strategy Product Testing Services

CVG Strategy provides program management for defense and commercial test and evaluation. We can work with multiple test facilities to coordinate testing on high end test equipment required for analysis where reliability is essential. Our experts can ensure that testing is performed as required and that essential data is recorded. Contact us for answers and solutions to your test and evaluation challenges.