Case Study

Data Validation and ITAR Assessment of Phalanx Close-In Weapons System for UK Ministry of Defence 

A strategic approach to ITAR streamlines reporting and cuts costs

Project Overview:  When the UK MoD adopted the Phalanx Close-In Weapon System (CIWS), it faced the daunting task of tracking all 60,000 components of these highly complex systems to meet ITAR (International Traffic in Arms Regulations) requirements. Camcode Global leveraged its expertise in data validation and the practical challenges of unique identification (UID) labeling to collaborate closely with the UK MoD.
Together, we developed a solution that streamlined ITAR compliance, reduced the costs associated with labeling components, and simplified the ongoing management of compliance. This tailored approach ensured the MoD could maintain a high level of operational readiness while adhering to stringent international regulations

Challenges

The MoD’s problems with ITAR compliance and audit failure for Bowman assets arose from several complex factors:

Unreliable inventory management
of these assets worldwide, with many of the assets included ITAR-controlled components such as radios and encrypted master control units.
Poor inventory management accountability
Frequent software upgrades and enhancements
resulting in changes to part numbers and NATO Stock Numbers (NSN), necessitating constant and accurate updates to maintain effective configuration management.

Camcode Global’s Role

Camcode Global developed a solution that included implementing Def Stan 05-132 for asset marking and applying the Wassenaar Code to identify and track assets subject to export controls. Key elements of the solution included:

UID Marking: Applying globally unique, STANAG 2290-compliant barcodes to each Bowman asset, which provided accurate, machine-readable data for reporting asset location, condition, and value.

Export Compliance: Ensuring assets subject to export controls were linked to original export licenses and technical agreements, improving ITAR compliance.

Data Reconciliation: Developing methods to validate and reconcile legacy data with updated asset records, ensuring serial numbers, part numbers, NSNs, and NCAGE codes were kept accurate during software upgrades.

On-site Label Production: To meet the operational demands of global deployments, Camcode Global established on-site label production capabilities, including in conflict zones like Afghanistan, ensuring that operations were not disrupted by system upgrades or changes.

Through the WATERGUARD Program and Asset Subject to Special Controls (ASSC) Service, Camcode Global UID marked approximately 414,000 Bowman assets, including over 336,500 subject to ITAR, enhancing asset visibility, compliance, and traceability.

Key Benefits

  • Improved ITAR Compliance: Ensuring export-controlled assets are linked to export licenses, mitigating risks of non-compliance and preventing potential fines from the U.S. State Department.
  • Successful NAO Audits: Financial accounting improved to meet audit requirements, addressing previous failures and ensuring the MoD’s inventory systems are fully accountable.
  • Accurate Configuration Management: Utilisation of Def Stan 05-132 and STANAG 2290 standards, ensuring data accuracy through machine-readable barcodes, improving operational efficiency.
  • Supply Chain Automation: Enhanced automation of supply chain processes, reducing manpower requirements while improving asset management and traceability.
  • Increased Operational Efficiency: The seamless integration of UID marks and AIT solutions enabled the MoD to maintain high data accuracy and asset visibility across global operations, ensuring operational readiness and compliance with export controls.
Camcode Global provided the UK MoD with a comprehensive, compliant, and efficient management system for Bowman assets, ensuring both ITAR compliance and successful audits, while improving overall supply chain performance and data accuracy