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28 The PCB Design Magazine • July 2017 TRILOGY CIRCUITS: MIL/AERO DEMANDS TECHNOLOGICAL, REGULATORY EXPERTISE mandate will be required by the end of 2017, which includes DFARS 252.204-7012 and NIST SP 800-171. These impose heightened security safeguards and mandatory reporting require- ments and subcontractor flow-downs on DoD contractors handling Covered Defense Informa- tion (CDI). AS9100 Rev D is here, and any au- dits conducted after June 15, 2017 will have to be to the revision D standard. Revision D takes this registration to a whole new complexity level. Transition audits must be completed by September 15, 2018. Revision C certificates will become invalid after that date. Shaughnessy: A few survey respondents said their mil/aero customers were worried that their boards would wind up being manufactured overseas because of the lack of transparency. Is that a widespread problem? We thought ITAR would curtail a lot of that. Capers: Great question. Fact of the matter is, they should be worried. Just about anyone can obtain an ITAR registration. Understanding ITAR and actually complying is where things get fuzzy for most people. Even though several board houses and brokers claim to have ITAR facilities over - seas, we really don't know how the product data is handled after you click the "send" button. We are very cautious when handling sensitive data and use only U.S.-based manufacturers for our military bare boards. The penalties and fines for sending data beyond our physical borders is enough to put most small companies out of business and the owners in federal prison. Shaughnessy: And yet it seems like everyone in the PCB world wants to be in mil/aero now. What are some of the biggest obstacles for com- panies who are considering moving into mil/ aero? Capers: As I mentioned before, compliance with all the regulations is the big one. Coun- terfeit mitigation is big as well. Ensuring that all your materials come from franchised distri- bution is critical. We are not allowed to pur- chase anything from non-franchised sources. This can be very difficult when dealing with EOL or obsolete components. The sales cycle is a long and drawn out process also. Time and patience are what it takes to get in as a supplier. To expect results in weeks or months is a fan- tasy. You can also expect a lot of facility visits and extensive audits of all your processes. Re- member, the government loves paperwork. The