Leading the World in Human Space Exploration, One Export Control at a Time

As the global leader in aerospace and science, NASA has a unique responsibility to safeguard its sensitive technologies and those of its international, interagency, and industry partners. A critical part of that responsibility involves remaining in full compliance with all U.S. export control laws, policies, and regulations.

Export controls apply to the transfer of certain goods, services, software, technical data, and technology out of the United States or to a foreign person or entity. These regulations ensure that information and technology do not fall into the wrong hands and cannot be used to threaten U.S. national or economic security.

Shivpal Vansadia, export administrator for NASA’s Johnson Space Center, explained that export controls funnel down to individual agency centers from federal regulators. Rules are set by the Departments of State and Commerce, as well as the Nuclear Regulatory Commission. NASA leadership and the export administrator for NASA Headquarters then establish the agency-specific directives and requirements for centers to comply with and provide guidance for employees.

Vansadia noted that export control is especially crucial at Johnson. “In 2023 and throughout history, we have conducted more exports of hardware, software, and data than all NASA centers combined,” he said. “This is due to our role as the hub of human spaceflight. With many significant NASA projects originating or passing through here, we experience a substantial amount of international engagement.”

Vansadia emphasized the significance of adhering to export control regulations in nurturing NASA’s expanding international partnerships. “We want to be open and facilitate sharing with our international partners," he said. "Additionally, we strive to cultivate a collaborative workplace environment that enables our employees to interact with commercial partners.”

Vansadia and others know that export control’s multiple layers and nuances can make compliance complicated. “There are a lot of gray areas in export control,” said Jennifer Mason, a Gateway program specialist and former center export administrator who helped establish Johnson's Export Services Team. “No two exports are the same, so there’s a lot of problem solving that goes into following the regulations while enabling NASA to reach its goals and complete its missions.”

The importance of export control and its complexities are why it was identified as a top priority for the Dare|Unite|Explore (DUE) Products and Processes Working Group. The group aims to make export control processes simpler and more effective for internal and external stakeholders. Vansadia works closely with the group to map and review export control processes and develop recommended efficiencies. To date, the team has made progress in streamlining aspects of export control for Orion and Artemis and will continue implementing process improvements this year. Vansadia mentioned that the tasks encompass areas such as customer service, bridging information gaps among employees, and implementing IT solutions and tools to streamline export control processes.

Export control stakeholders at the program level are also finding ways to simplify processes for team members. Mason noted that in a previous role with the International Space Station Program, she helped create a program-wide technology transfer control plan that alleviated the need to conduct time-consuming annual reviews for each of the thousands of foreign nationals working with the program. Now she is part of an Artemis Export Process Improvement Team that spans Moon to Mars and Artemis programs. “We have weekly meetings with export control stakeholders from all of these programs to identify opportunities to set up common processes, and we share information about how our different programs are handling export control and what our requirements are,” she said. The team is currently working on a record-keeping tool to help the programs document exports appropriately without duplicating efforts.

Importantly, these and other process improvements must still ensure necessary safeguards for exported items and information because the consequences of noncompliance are serious. For employees, these consequences can include fines and imprisonment, as well as a damaged professional reputation and lost career opportunities. At the center and agency level, consequences include legal penalties, financial losses, lost technological leadership, and weakened international relationships, explained Tonya Barker, senior export control analyst. “It could also erode trust with partners, stakeholders, and the public, significantly impacting our mission and collaborative projects,” she said. Vansadia explained that regulators might intensify their monitoring of NASA, leading to the need for more reviews and approvals of exports that would slow the agency’s operations.

To avoid these consequences, Johnson employees are encouraged to take export control trainings and use the many tools and resources provided by the Export Services Team. “I highly recommend that everyone take the introductory export control training in SATERN,” Vansadia said, and headquarters provides a list of additional export control training programs.

Another top resource for employees who are actively involved in export activities is Johnson’s network of Export Control Representatives (ECRs). Each ECR is assigned to provide export control guidance and compliance support to team members within assigned programs or organizations. Barker, the lead ECR for four Johnson organizations, explained that ECRs assess and identify potential export control issues, advise on the export classification of technologies and information, secure necessary export licenses, and conduct training sessions for staff. “My goal is to facilitate compliance without hindering the center’s innovative and collaborative spirit,” she said.

Vansadia stressed the importance of ECRs serving as the primary contact for all export-related activities. He highlighted the exceptional expertise and proactive engagement of ECRs throughout the agency in enhancing our procedures. Barker also recommends that employees review the NASA Export Control Operating Manual, checklists for assessing export control requirements, and a series of FAQs available on the Export Services Team’s website for additional information.

Looking ahead, Mason expressed hope that employee’s understanding and awareness of export control will rise to the level of safety, which has become such a strong part of Johnson’s and the agency’s culture. “Export control is kind of like safety, in that we have to always be aware of it and we have to do it right,” she said.

Vansadia mentioned that a key objective for him, Alternate Center Export Administrator Judith Elam, and the Export Services Team in 2024 is to enhance the readability and comprehension of export control manuals. Additionally, they are actively increasing awareness of export control among employees. "Our goal is to disseminate export control knowledge and procedures across the center," he elaborated, "and we will collaborate with program and directorate leadership to ensure we are fulfilling our responsibilities."