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July 2017 • The PCB Magazine 33 MIL/AERO ELECTRONICS SUPPLY CHAIN FACING NEW CHALLENGES are the drawings with existing requirements. "You're trying to comply with the drawing and you'll have situations, like you were men- tioning. You have to get a waiver, to do some- thing differently, or something's very cost-pro- hibitive due to an impact to yields. Getting changes through is always one of the supreme challenges. Even in cases where you provide a good service and your customer agrees to what you're requesting, often there's no fund- ing in the program to pay for your engineer- ing change. We've come across that recently where we all agree with this, it makes a lot of sense, and it's going to help you reduce costs, but nobody's going to pay you any money to fix that. Or cases where it does go through, but the length of time it takes to go through automati- cally puts the entire program on schedule jeop- ardy and puts immense pressure on the entire supply chain to perform to levels that maybe are unreasonable or difficult to come out look- ing good, when really you were just trying to do the right thing and build to print or reduce costs," he said. "Those are some challenges as well. I've seen many cases where jobs go on hold for three months, and then of course everyone needs it tomorrow. And I certainly understand that, no matter who that customer is. Everyone is making a product, and we're all feeding up- wards towards some goal, and you can't recov- er that lost time. I'd say to Dave's point, there are certainly business challenges with that. I think change management, where it changes, and their impact on the overall schedule is also a challenge that's worth noting." From an EMS standpoint, Zentech's Turpin also mentioned the need to comply with the new cybersecurity rules. "The NIST 800-171 [2] guidelines are complex. It's night and day. ITAR is really nothing compared to the cyber rules. Complying with ITAR would be maybe a three, and to comply with the NIST 800-171 is more like an 83. It's orders of magnitude more com- plex and we've been working on it, and we al- ready had a head start. We started about three years ago down this path, but the NIST 800-171 is formidable and it's being driven at us as flow- downs from all the military primes. Fortunate- ly, it doesn't have to kick in now, but soon ev- erybody is going to have to do it," he said. "To the earlier point about the military being more commercial in terms of pricing, this NIST 800- 171 is going to be an unbelievable barrier to en- try. I don't know how a lot of people are going to have the infrastructure and the capability to comply with it. They're either going to have to close their eyes when they self-certify, or they're just going to be completely non-compliant and hope it will go away. NIST 800-171 is huge, and I'm surprised a lot of people aren't talking about it yet. That will be a big challenge. We're doing pretty good. We should be compliant before the end of this year." Regarding how long it takes to go through that compliance process, Turpin said it depends on how mature the organization is. "For us, we currently have only two sites, and we're getting ready to add a third. If you are a multi-site orga- nization, or you've got the challenge that Scott does in terms of kind of a virtual organization, it's unbelievably difficult because very specific hardware issues must be dealt with. I can't even begin to talk about it. I mean, I've got a whole team that's dealing just with this compliance." But isn't this industry overregulated al- ready? Absolutely not, according to Turpin. He said that there is such a disparity in terms of the due diligence the companies in the mil/aero- space undertake, and it's absolutely needed. John Rolle, Lenthor Engineering.