oversight

Export Controls: Opportunities for Improving Compliance With Export Administration Regulations

Published by the Government Accountability Office on 1990-12-06.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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                                         .._____                              Offiw

GAO                                   Itt,port t,o tht Secretary of Commwcc




                                     Opportunities for
                                     Improving Compliance
                                     With Expbrt
                                     Administration
                                     Regulations


                                                                                  IllIllIll
                                                                                        II
                                                                                      142771




G&NSJAJWI          -47
National Security and
International Affairs Division

H-24 1674

December 6,199O

The Honorable Robert A. Mosbacher
The Secretary of Commerce

Dear Mr. Secretary:

This report presents the results of our review of the Department of Commerce’s procedures
for providing oral export administration advice to exporters. It also gives ways to improve
the presentation and readability of the commodity control list. This review was made as part
of our ongoing efforts to assess key parts of the national security export control program
and because of congressional interest in the area.

This report contains recommendations to you in chapters 2 and 3. The head of a federal
agency is required by 31 U.S.C. 720 to submit a written statement on actions taken on these
recommendations to the Senate Committee on Governmental Affairs and the House
Committee on Government Operations no later than 60 days after the date of the report and
to the House and Senate Committees on Appropriations with the agency’s first request for
appropriations made more than 60 days after the date of the report.

We are sending copies of this report to appropriate House and Senate Committees; the
Director, Office of Management and Budget; and other interested parties.

Please contact me at (202) 275-4812 if you or your staff have any questions concerning the
report. Other major contributors to this report are listed in appendix II.

Sincerely yours,




Allan I. Mendelowitz, Director
Trade, Energy, and Finance Issues
Executive Summary


                   The United States controls the export of commercial products that could
Purpose            be of military use to the Soviet Union, Eastern European countries, and
                   the People’s Republic of China. Industry compliance with export con-
                   trols requires that exporters be able to determine whether a product is
                   subject to control and, if so, what type of export license is necessary.
                   Because of the importance of export controls to U.S. national security,
                   GAO examined industry concerns that (1) oral advice provided by the
                   Commerce Department is sometimes inaccurate or inconsistent and
                   (2) the commodity control list, an integral part of the Export Adminis-
                   tration Regulations, is unnecessarily difficult to understand and use.


                   The United States, its North Atlantic Treaty Organization allies (except
Background         Iceland), Australia, and Japan coordinate their export control policies to
                   protect their national security through the Coordinating Committee on
                   Multilateral Export Controls. Each member country implements export
                   control policy agreements in the context of its own regulatory frame-
                   work. In the United States, the Export Administration Regulations con-
                   tain the list of products subject to export controls and the rules
                   governing their export. The Department of Commerce is responsible for
                   administering U.S. export controls, including maintaining the regula-
                   tions and providing guidance to the business community. The regula-
                   tions have become complex as changes have been made reflecting policy
                   and legislative developments, This complexity results in thousands of
                   requests annually for advice and clarification from exporters seeking to
                   identify applicable export controls.


                   Commerce does not always provide accurate or consistent advice in
Results in Brief   response to exporter inquiries. Factors impairing responses include the
                   large number of staff providing advice with limited quality control, and
                   operational problems affecting Commerce’s telephone log system. The
                   telephone log is Commerce’s chief means of maintaining the quality of
                   export guidance provided by the two offices designated as primarily
                   responsible for providing oral advice. Commerce officials acknowledge
                   that staff at times give inconsistent or inaccurate advice. However, suf-
                   ficient data are not available to establish the magnitude of the problem.

                   The US. commodity control list, a key part of the export regulatory pro-
                   cess, is unnecessarily difficult for U.S. exporters to understand and use.
                   The list would be easier to use if explanations were more fully devel-
                   oped and the list’s visual presentation were improved. The United States
                   recently agreed to discontinue using the present control list and to


                   Page 2                                         GAO/NSIAD9147   Export Controls
                         Executive Summary




----
                         develop a new one focusing on a few core technologies. Commerce has a
                         unique opportunity to incorporate visual improvements into the new
                         list.



Principal Findings

Unreliable Oral Advice   Industry representatives say they sometimes receive inaccurate or
                         inconsistent advice from Commerce in response to their export control
                         inquiries. The resulting lack of confidence in Commerce’s advice leads
                         firms to make unnecessary follow-up calls to check the accuracy of gui-
                         dance. It also sometimes leads to “shopping” by exporters,.which occurs
                         when exporters repeatedly call Commerce staff until they receive advice
                         consistent with what they want to do. Inaccurate and inconsistent
                         advice can prove costly for exporting firms and can compromise compli-
                         ance with export control regulations.

. .
Factors Impairing Oral   While several factors contribute to the problem of inaccurate and incon-
Advice                   sistent guidance, a major factor is the large number of Commerce staff
                         authorized to give advice, coupled with the absence of effective quality
                         control mechanisms.

                          In 1989, Commerce implemented a telephone log system that allows
                          supervisory reviews of oral advice given to exporters. The system’s use
                          is limited to the approximately 30 people in the 2 Commerce offices
                          whose chief responsibility is assisting exporters. It is not currently used
                          by about 280 staff in other Commerce offices who may also respond to
                         exporter inquiries. Commerce, therefore, has no way of accurately esti-
                         mating the extent of oral advice provided by these other offices or of
                         judging the quality of advice they provide.

                         Although the log system is a promising first step, it has limitations that
                         reduce its effectiveness. These include the lack of staff time to log infor-
                         mation into the system and its inability to sort logged telephone
                         inquiries by subject matter. The system only allows inquiries to be
                         sorted by caller, a capability that does not allow for checking the consis-
                         tency and accuracy of advice given different callers. Even this feature,
                         however, is not always used when staff respond to calls.




                         Page 3                                          GAO/NSIAD-914   Export Controls
                           Executive Summary




                           In addition, while Commerce’s Office of Technology and Policy Analysis
                           is responsible for maintaining the regulations and providing written
                           interpretations, it does not review the telephone log to check the accu-
                           racy and consistency of responses. This review is performed instead by
                           senior staff in the offices handling the telephone inquiries.

                           Other agencies have taken steps to improve the accuracy of information
                           provided to callers. For example, to improve the accuracy of the oral
                           advice it provides, the Internal Revenue Service has initiated a number
                           of quality control efforts. These efforts include improving the staff’s
                           ability to probe callers for all relevant information and periodic testing
                           of the accuracy of the staff’s oral advice. GAO testified in March 1990
                           that these efforts have contributed to recent increases in the accuracy
                           rate of responses to taxpayer inquiries. Commerce may be able to adopt
                           some of these mechanisms to improve the quality of its export control
                           inquiry responses.


Control List Readability   A key section of the Export Administration Regulations, the commodity
Can Be Improved            control list, also needs improvement. From initial product classification
                           to identifying applicable licensing requirements, this list is central to
                           regulatory compliance. However, numerous firms described the control
                           list as difficult to understand and use. Export control managers at sev-
                           eral high technology firms said that illogical formats and methods of
                           presentation often created confusion. Commerce has made some
                           improvements to the control list; however, its recent attempts to
                           improve the list have been hampered by resource constraints and other
                           agency priorities.

                           Commerce can make the control list easier to understand and more
                           useful by rewriting it in simpler language, providing user-oriented
                           explanations, and using a less complicated typographical design. This is
                           a particularly opportune time to improve the list’s presentation since the
                           United States has recently agreed with its major Western allies to dis-
                           continue the current control list and develop a new one.


                                recommends that the Secretary of Commerce direct the Under Sec-
Recommendations            GAO
                           retary for Export Administration to ensure the accuracy of the oral
                           advice provided on export regulations and has identified a number of
             ”             actions the Secretary may wish to consider in implementing this recom-
                           mendation. GAO also recommends that the Secretary improve the presen-
                           tation of the new control list.


                           Page 4                                         GAO/NSIAD-9147 Export Control8
                  Executive Summary




                  The Department of Commerce concurred with GAO'S recommendations.
Agency Comments   Regarding GAO'S recommendation to ensure the accuracy of oral advice,
                  Commerce identified several programs it has implemented over the past
                  several months and believes that it has met the intent of GAO'S recom-
                  mendation, GAO agrees that Commerce has made significant progress in
                  improving the accuracy of its oral advice but needs to continue focusing
                  on this issue to ensure that planned actions are completed. Regarding
                  GAO'S recommendation to improve the new control list’s presentation,
                  Commerce stated it intends to incorporate as many of GAO'S suggestions
                  as practical and identified several improvements it has made recently.




                  Page5                                         GAO/NSIAD9147ExportChntrols
contents


Executive Summary                                                                                 2

Chapter 1                                                                                         8
Introduction             The Export Control System
                         Implementing US. Export Controls Results in Complex
                                                                                                  8
                                                                                                  9
                             Regulations
                         Export Control Depends on Exporters Determining Which                   10
                             Controls Apply
                         Objectives, Scope, and Methodology                                      10

Chapter 2                                                                                        12
CommerceCould            Commerce Employees Respond to Hundreds of Exporter
                             Inquiries Daily
                                                                                                 12
Improve the Quality of   Firms Voice Complaints About Inconsistent and                           12
Oral Advice Provided         Inaccurate Advice
                         Reasons for Inaccurate or Inconsistent Advice                           13
on Export Regulations    Other Quality Control Mechanisms Are Potentially                        17
                             Available to BXA
                         Conclusions                                                             17
                         Recommendation                                                          18
                         Agency Comments                                                         19

Chapter 3                                                                                        20
Improving the            Industry Finds the Control List Difficult to Read and
                             Understand
                                                                                                 20
Readability of the       Commerce Efforts to Improve the Control List                            21
Commodity Control            Presentation
                         The Commodity Control List Can Be Made Easier to                        22
List                         Understand and Use
                         Commerce and Industry Agree That the Control List Can                   30
                             Be Improved
                         Conclusions                                                             30
                         Recommendation                                                          30
                         Agency Comments                                                         31

Appendixes               Appendix I: Comments From the Department of                             32
                             Commerce
                         Appendix II: Major Contributors to This Report                          42




                         Page 6                                      GAO/NSIAD-9147 Export Controls
          Contents




Figures   Figure 3.1: Introductory Material for Commodity Control                     24
               List Entry 1529A
          Figure 3.2: Revised Introductory Material Consolidating                     26
               General and Special License Eligibility
          Figure 3.3: Comparison of British and U.S. Control Lists                    28




          Abbreviations

          BXA        Bureau of Export Administration
          I-us       exporter assistance staff
          EAR        Export Administration Regulations
          GAO        General Accounting Office
          IRS        Internal Revenue Service
          ITA        International Trade Administration
          WHO        Western Regional Office


          Page 7                                          GAO/NSLAD-9147 Export Controls
Chapter 1

Introduction


                     Since 1949, the United States and its allies have controlled exports of
                     goods and technology with commercial and military uses to the Soviet
                     Union, Eastern European countries, and the People’s Republic of China.
                     To prevent diversions to these countries, exports of militarily sensitive
                     commercial products have also been controlled to most other
                     destinations.


                     The Export Administration Act of 1979, as amended, authorizes controls
The Export Control   over exports of commercial goods and technologies that could signifi-
System               cantly contribute to the military capabilities of a potential adversary. It
                     also authorizes export controk to achieve U.S. foreign policy goals and
                     to ensure the domestic availability of resources in short supply.

                     The Department of Commerce is responsible for administering U.S.
                     export controls, At the act’s direction, Commerce established the Bureau
                     of Export Administration (BXA) in 1987 to provide for high-level direc-
                     tion of the national export control policy. RXA’S responsibilities include
                     processing export license applications, developing and implementing
                     policies for export licensing, and providing oral advice and technical gui-
                     dance to the business community on a wide range of technology and
                     country specific export control issues. While BXA is primarily respon-
                     sible for export controls, the International Trade Administration (ITA),
                     Commerce’s export promotion arm, is also involved in disseminating
                     information to exporters on export controls.

                     The IJnited States controls the export of all goods and technology
                     through two types of export licenses: general and validated. A general
                     license is a broad grant of authority by the government to all exporters
                     for certain categories of products to all or most destinations. Most U.S.
                     exports are shipped abroad under general licenses and no application is
                     required for their use. There are currently 22 different types of general
                     licenses.

                     A validated license is a specific grant of authority from the government
                     to a particular exporter to export a specific product to a certain destina-
                     tion, Special licenses may also be available to cover a range of products
                     to several distributors.




                     Page 8                                          GAO/NSIAD-9147 Export Controls
                     Chapter 1
                     Introduction




                     The Export Administration Regulations (EAR) establishes the rules and
Implementing U.S.    procedures needed to carry out the provisions of the Export Administra-
Export Controls      tion Act. They contain the list of controlled products and specific provi-
Results in Complex   sions governing their export, such as how to obtain an export license,
                     documentation requirements, and special commodity and country
Regulations          policies.

                     The EAR has become increasingly complex. To some degree, we believe
                     this complexity is a function of the sophistication of the controlled tech-
                     nologies, the varying licensing requirements for different countries, and
                     the constant change in regulations made to reflect policy and legislative
                     developments. Changes are adopted through publication in the Federal
                     Register, and later, through incorporation in the EAR itself.

                     Regulatory complexity is also related to the degree of flexibility found
                     in the regulations. According to a Commerce official, the most straight-
                     forward form of export controls would be an inflexible system that
                     required a license for all exports. However, a series of exceptions to this
                     requirement have been implemented to avoid burdening U.S. exporters.
                     While these exceptions increase flexibility for US. exporters, they also
                     add to regulatory complexity, which can create problems, particularly
                     for inexperienced exporters.

                     In the early 198Os, as a result of a congressional mandate for regulatory
                     simplification, a major effort was made to rewrite the export control
                     regulations. At the time, Commerce undertook a comprehensive plan-
                     ning exercise to prepare for a major rewrite of both the body of the reg-
                     ulations and the control list. Since the necessary resources were never
                     committed, however, only limited success was achieved.

                     Beginning in 1988, a major effort was made to revise the export regula-
                     tions for technical data and software, which industry users and govern-
                     ment officials described as being among the most complex and difficult
                     to understand. At the time of our review, BXA was circulating final
                     drafts of the revised regulations internally for approval. Agency offi-
                     cials said because of its work load, BXA has not had the opportunity to
                     begin revising the remainder of the EAR.




                     Page 9                                          GAO/NSLAD-9147 Export Controls
                        Chapter 1
                        Introduction




                        An essential part of the export control process involves exporters deter-
Export Control          mining whether a product requires a general or a validated license. To
Dependson Exporters     accurately determine which license is required, exporters must not only
Determining Which       be familiar with the BAR, but also with recent pertinent changes pub-
                        lished in the Federal Register as well as unpublished interpretations and
Controls Apply          policy guidance. It is therefore critical that the EAR be both understand-
                        able and current.

                        For the exporter, the first step in the export licensing process is to deter-
                        mine a product’s control status. This depends on what is being exported,
                        where it is going, the end use, and the end user. Because the regulations
                        are complex, exporters find that they must often rely on oral advice pro-
                        vided by Commerce specialists.

                        According to a 1987 report.1 on the national security control’s affect on
                        international technology transfer, the export control system’s com-
                        plexity imposes considerable costs on, and often undermines compliance
                        by, exporting firms. The burden is heaviest on small- and medium-sized
                        companies that cannot spread the costs of complying with constantly
                        changing export control requirements over a large volume of export bus-
                        iness. The study concludes that the EAR needs to be rewritten, simplified,
                        and condensed.


                        The objective of our review was to assess the accuracy and consistency
Objectives, Scope,and   of advice given exporters and to identify needed improvements to the
Methodology             EAR. Specifically, we (1) evaluated industry concerns regarding the
                        quality of oral advice provided by Commerce and identified ways to
                        improve its accuracy and consistency and (2) examined possible ways to
                        improve the U.S. commodity control list’s clarity.

                        To identify concerns regarding the quality of oral advice and guidance,
                        we spoke with licensing specialists, exporting officials, senior manage-
                        ment at exporting firms of various sizes, various trade association
                        officers, private consultants, and the chairmen of seven BXA technical
                        advisory committees.2 We spoke with officials at the Departments of
                        Commerce and State, to obtain agency views.

                        ‘Bakncing the National Interest-US. National Security Export Controls and Global Economic Com-
                        petition, National Academy Press, Washington, DC., 1987.

                        2The 1979 Export Administration Act establishes Technical Advisory Committees consisting of both
                        U.S. government and industry representatives to advise Commerce on the evaluation of technical
                        issues, worldwide availability, use, and production of technology and licensing procedures relating to
                        specific industries.



                        Page 10                                                          GAO/NSIAD-9147 Export Controls
Chapter 1
Introdu”fc.on




We held extensive discussions with BXA staff to determine the proce-
dures and policies involved in providing oral advice to the business com-
munity. We also reviewed BXA telephone logs used to record information
on exporter queries, and then discussed procedures for creating, using,
and monitoring the logs with BXA staff. We also reviewed BXA’S budget
report for fiscal year 199 1.

To assess ITA'S provision of export control information, we reviewed a
June 1989 report, District Office Delivery of Export Administration Ser-
vices, prepared by the accounting firm, Price Waterhouse,3 under con-
tract to ITA. We also interviewed ITA officials in Washington, D.C., and in
the San Francisco District Office regarding ITA’S provision of oral advice
on export controls,

To assess how quality control over the provision of export control infor-
mation could be improved, we reviewed BXA’S quality control procedures
and identified weaknesses. We also compared BXA’S procedures with
information we previously developed on quality control mechanisms
used by the Internal Revenue Service (IRS) to improve the quality of
advice it provides to the public.

To identify possible shortcomings in the commodity control list, we first
determined past changes to the list by reviewing Commerce files and
BXA annual reports. We then identified possible ways of improving the
control list by interviewing industry representatives, consultants, and
government officials and by searching literature on “plain English” doc-
ument design. Using a commodity identified as a good candidate for
revision by both Commerce and industry, we assessed how well it incor-
porated commonly accepted graphic design principles, and compared it
with the widely used British version of the list. We also obtained both
Commerce and industry views on whether the potential improvements
identified enhanced the control list’s ease of use and clarity.

We conducted our review between May 1989 and March 1990 in accor-
dance with generally accepted government auditing standards.




SThis study was commissioned by Commerce to assessthe quality of export administration services
provided at 10 Commerce locations in the field. Other study objectives were to analyze future demand
and recommend organizational structure and resources needed for the future delivery of export
administration services.



Page 11                                                        GAO/NSIAD-91-47 Export Controls
Chapter 2

CommerceCould Improve the Quality of Oral
Advice Provided on Export Regulations

                        Exporters make tens of thousands of calls a year to Commerce for clari-
                        fication and interpretation of the EAR. Commerce does not, however,
                        always provide accurate or consistent advice. As a result, export control
                        compliance may be adversely affected. Factors contributing to this
                        problem include the large number of staff, with varying levels of experi-
                        ence, authorized to provide advice and limited quality control. Although
                        Commerce has implemented a telephone log system to improve the
                        quality of its oral advice, additional measures can be taken to make
                        Commerce’s oral advice more reliable.


                             is the principal source of advice within Commerce on export control
CommerceEmployees       BXA
                        matters. Within BXA, the Office of Export Licensing’s exporter assis-
Respondto Hundreds      tance staff (EAS) and Western Regional Office (WRO) staff are responsible
of Exporter Inquiries   for responding to telephone questions posed by the exporting commu-
                        nity regarding export regulations.
Daily
                        ITA, the Commerce agency primarily responsible for promoting U.S.
                        exports, also provides advice on export control matters. ITA'S 67 district
                        offices in the United States are listed at the beginning of the regulations
                        as information sources on export controls, which makes ITA readily
                        accessible to most firms nationwide.

                        Commerce representatives respond daily to a constant stream of tele-
                        phone inquiries, BXA data show that EM and WRO offices alone received a
                        total of 160,000 export control-related inquiries during fiscal year 1989.
                        Reliable data on the number of inquiries ITA district offices receive are
                        not available, since only 72 percent of the district offices regularly
                        reported their export control activity to BXA in fiscal year 1989, Avail-
                        able data, although limited, indicate that ITA district offices handled a
                        much smaller number of inquiries- about 6,000 telephone inquiries and
                        about 700 walk-in inquiries-in    fiscal year 1989.


                        Industry representatives told us that Commerce staff sometimes give
Firms Voice             inaccurate or inconsistent advice in response to export control ques-
Complaints About        tions. Similarly, Price Waterhouse’s study of Commerce’s district offices
Inconsistent and        found that inconsistent responses from Commerce staff cause problems
                        for companies seeking definitive policy advice on which to base business
Inaccurate Advice       decisions. Commerce officials also recognize the problem of inconsistent
            Y           and inaccurate oral advice.




                        Page 12                                         GAO/NSIAD-91-47 Export Controls
                              Chapter 2
                              Commerce Could Improve the Quality of Oral
                              Advice Provided on Export Regulations




                              The export community’s lack of confidence in Commerce’s advice results
                              in exporters making unnecessary follow-up calls to determine the accu-
                              racy of advice. We learned of many cases demonstrating this lack of con-
                              fidence. For example, in one instance, an exporter telephoned Commerce
                              to ask whether a letter of assurance’ was necessary for the export of
                              certain software under a general license. A Commerce employee told the
                              exporter it was not needed. Concerned that this answer might be inaccu-
                              rate, the exporter called a second time and was told by another Com-
                              merce employee that one was required. Because of the inconsistency, he
                              called Commerce’s Office of the Chief Counsel and was told that one was
                              needed.

                              Inaccurate or inconsistent advice may also lead exporters to “shop” for
                              desired responses, or in other words, make repeated calls to different
                              Commerce staff until they receive advice consistent with what they
                              want to do. In one such apparent instance, an exporter made repeated
                              calls to ask Commerce employees whether, under an individual vali-
                              dated license, it was possible to export a product directly to a third
                              party in a foreign country rather than to the consignee designated on
                              the license for later shipment to the third party. Two Commerce offices
                              told the exporter that the product should go to the designated consignee
                              first. Apparently dissatisfied with these answers, the exporter called a
                              policy level Commerce official, who provided a response that was more
                              favorable. The advice was that the product could be shipped directly to
                              the ultimate customer, provided that certain conditions were met.

                              Commerce officials acknowledge that oral advice provided to exporters
                              is sometimes inaccurate and inconsistent and that it may result in
                              exporters shopping for desired responses. Although Commerce officials
                              do not consider this to be a major problem, they subsequently agreed
                              with our observation that sufficient data are not available to establish
                              its magnitude.


Reasonsfor Inaccurate Several
                       advice factors contribute
                              These  include                        to the problem of inaccurate or inconsistent

or Inconsistent Advice      ’
                          l   Commerce’s limited control over the large number of staff providing
                              oral advice,


                              ‘A U.S. letter of assurance is often required from importers in other countries stating that the tech-
                              nical data will not be reexported to certain countries without prior U.S. authorization.



                              Page 13                                                           GAO/NSIAD-9147 Export Controls
                              Chapter 2
                              Commerce Could Improve the Quality of Oral
                              Advice Provided on Export Regulations




                            . the failure of Commerce staff to elicit all relevant information from
                              callers before providing advice, and
                            . the high turnover of BXA staff primarily responsible for responding to
                              exporters’ telephone inquiries.


Limited Control Over          Recognizing the problem of inconsistent and inaccurate oral advice, BXA
Large Number of Staff         recently established a computerized telephone log system that allows
                              ongoing reviews of oral guidance. The system is intended to monitor the
Providing Advice              inquiry work load as well as to improve the accuracy and consistency of
                              advice. The system was first implemented in WRO during early 1989. EAS
                              began implementing a similar system in Washington during October
                              1989. The telephone log system, however, is limited to the 16 EAS and 14
                              WRO staff within RXA who have direct responsibility for responding to
                              telephone inquiries. The system does not cover the more than 130 other
                              BXA professional staff who are authorized to, and who in fact do,
                              respond to questions. These include engineers, export administration
                              specialists, licensing and export compliance specialists, and senior level
                              managers. In fact, with the exception of the telephone log system used
                              by EA!3 and WRO staff, there are no procedures to ensure the accuracy
                              and consistency of oral advice given by most BXA staff.

                              The system is not used to monitor the approximately 150 trade special-
                              ists located in the ITA district offices who also provide advice on export
                              control matters. Although a memorandum of understanding with BXA
                              stipulates that these offices are authorized to provide counseling and
                              assistance on export control matters, they are not included in the tele-
                              phone log system.

                              The ITA district offices do have a ma,nual form that can be completed
                              when advice is provided, but according to the Price Waterhouse study,
                              forms are not completed regularly. In addition, BXA, the agency respon-
                              sible for administering the export control system, does not review the
                              completed forms for accuracy and consistency. However, as BXA adds
                              regional offices recently mandated by the Congress, it expects to absorb
                              much of the export administration services’ work load now being han-
                              dled by ITA.


Operational Problems With     Both WRO and EAS staff are limiting their detailed log entries to only the
                              most “significant inquiries.” The staff must rely on their own judgment
the Telephone Log System      for determining which inquiries are significant and for determining how
                              much documentation is required in the log entry. Therefore, Commerce


                              Page 14                                        GAO/NSLAD-9147 Export Controls
Chapter 2
Commerce Could Improve the Quality of Oral
Advlce Provided on Export Regulations




has no assurance that all significant calls are properly included in the
log.

According to BXA officials, if a conflict develops between establishing an
extensive tracking system or being responsive to exporters and fielding
more calls, the latter tends to take precedence. In WRO, about 40 percent
of the incoming calls are recorded in detail in the computer log.
According to a WRO staff member, this does not represent all significant
inquiries since there is not always enough time to log in and document
all such calls. To the extent the telephone log system is incomplete, BXA
cannot fully monitor the quality of advice or check past queries to
ensure consistency.

Due to the high volume of incoming calls, BXA staff are also not per-
forming an immediate check of the calls logged into the system for shop-
ping or for consistency of responses. In addition, the system, as it is
currently programmed, only allows the sorting of inquiries according to
caller and by the general nature of the calls, such as requests for regula-
tory information, classifications, or export control forms. While this
sorting capability allows BXA staff to check on all advice provided to the
same caller, it does not allow checking for consistency and accuracy
between different callers. Sorting according to inquiry topic would allow
BXA staff to quickly see if accurate and consistent advice is being pro-
vided to all exporters on a particular topic. According to the industry
consultant who designed BXA'S current system, this capability could be
incorporated into the system at a relatively minor cost.

Finally, telephone log responses are not reviewed by BXA'S Office of
Technology and Policy Analysis, which as the office responsible for
maintaining the EAR and providing written interpretations is the unit
best suited to judge the accuracy of advice. Instead, senior staff in EAS
and WRO review log entries to verify the accuracy and consistency of
responses. Incorrect responses are brought to the attention of the
responsible staff and the inquiring firm is contacted to correct any mis-
information. A senior BXA official told us that while experienced EAS and
WRO staff check telephone log responses, it is conceivable that they may
also be mistaken, particularly in those cases where advice requires some
interpretation.




Page 16                                        GAO/NSIAD-9147 Export Controls
                        Chapter 2
                        Commerce Could Improve the Quality of Oral
                        Advice Provided on Export Regulations




CommerceDoes Not        To provide accurate advice, Commerce must elicit all pertinent informa-
Always Obtain All       tion from callers. A variety of factors affect export control require-
                        ments, including the technological sophistication of the commodity, the
Pertinent Information   country of destination, and the use to which the commodity will be put.
When Responding to      Commerce recognizes the importance of seeking all relevant information
Queries                 and assigns new employees to experienced staff for a period of time, in
                        part, to observe probing techniques. In some cases, however, Commerce
                        staff do not always receive or seek all pertinent information. In other
                        instances, callers can provide inaccurate information despite Com-
                        merce’s attempts to elicit all pertinent information.

                        An experience we had shows the importance of probing for information.
                        We had occasion to call Commerce about whether a license was required
                        to take a computer overseas. We described the computer and explained
                        that we would be using it for business purposes. In responding to our
                        inquiry, the Commerce employee gave a reply based on the information
                        offered, but did not seek further information, such as whether our
                        employer owned the computer. In retrospect, we were told by a senior
                        Commerce licensing official that had we stated it was a government-
                        owned computer, to be used for government business, it would have
                        affected the response we received.


High Turnover Lowers    The high level of turnover among BXA staff primarily responsible for
Experience Level        responding to exporters’ telephone inquiries also contributes to the
                        problem of inaccurate and inconsistent advice. For example, in 1988 and
                        1989, 12 of 16 EAS staff left the unit. As a result, in late 1989, almost 40
                        percent of the current staff of 16 providing regulatory advice had been
                        in the area for 6 months or less. According to Commerce, one factor
                        accounting for this high turnover is the low grade structure and pay of
                        staff, as compared to the private sector. Commerce officials acknowl-
                        edge the problem of high staff turnover and are attempting to raise the
                        grade structure of EAS positions to make them more competitive with
                        other government and private sector positions. In commenting on a draft
                        of this report, Commerce stated that the grade structure has been
                        changed and identified other efforts to reduce turnover.




                        Page 16                                         GAO/NSIAD-91-47 Export Controls
              -
                        Chapter 2
                        Commerce Could Improve the Quality of Oral
                        Advice Provided on Export Regulations




                        To ensure the quality of advice they provide to the public, organiza-
Other Quality Control   tions, such as IRS, have developed a variety of quality control mecha-
Mechanisms Are          nisms that Commerce could potentially adopt. Although the IRSresponds
Potentially Available   to a far greater number of telephone inquiries, it is similar to BXA in that
                        both provide oral advice on numerous questions related to a complex
to BXA                  body of regulations. Both also represent areas of government regulation
                        with major implications for the United States,

                        The IRS has implemented a number of quality control efforts to improve
                        the responsiveness, accuracy, and overall quality of taxpayer service.
                        Specifically, these include (1) ongoing monitoring of calls, (2) sample
                        testing of IRS service centers using hypothetical tax questions, and
                        (3) the development of a probe and response guide and formal training
                        in effective probing techniques. The guide directs IRS staff to elicit all
                        necessary information before responding to tax inquiries.

                        The IRS has been successful in its recent efforts to improve its accuracy.
                        For example, a survey of the IRS toll-free tax information number found
                        that the accuracy rate of IRS responses to our test questions rose from 66
                        percent in tax year 1988 to 78 percent as of March 16, 1990. In testi-
                        mony before the House Ways and Means Committee,2 we reported that
                        several factors contributed to the improved IRS accuracy this year.
                        These factors include an increased emphasis on probing to obtain all the
                        facts needed about a taxpayer’s situation, greater managerial emphasis
                        and involvement, and a more stable and experienced work force.


                        Both Commerce and industry agree that the oral advice Commerce pro-
Conclusions             vides the exporting community is not always accurate and consistent.
                        Quality controls recently instituted in the form of a telephone log system
                        only cover the two Commerce offices whose principal responsibility is
                        providing exporter assistance. Commerce consequently has no mecha-
                        nism to monitor the quality of oral advice provided by most of its other
                        professional staff, who also provide advice to exporters.

                        One way to reduce the likelihood of staff providing inconsistent and
                        inaccurate oral advice would be to limit the number of staff authorized
                        to provide such advice. Attempting to limit the number of staff that can


                        %atement of GAO Director for Tax Policy and Administration Issues before the Subcommittee on
                        Oversight, Committee on Ways and Means, House of Representatives (GAO/T-GGD-90-26, Mar. 22,
                        1990).



                        Page 17                                                    GAO/NSIAD9147      Export Controls
                                               Chapter 2
                                               Cmnmerce Could Improve the Quality of Oral
                                               Advice Provided on Export Regulatione




- .._.._....
       ---_- .. .._...__...
                       ^..__.._.--.-l”--
                                               respond to public inquiries would, however, reduce Commerce’s respon-
                                               siveness to the public. If Commerce considers it essential that all profes-
                                               sional staff continue to be available to provide oral advice, it could
                                               expand the telephone log system to include all staff providing advice.

                                               The telephone log system, however, has operational problems that limit
                                               its effectiveness, These problems include the

                                           . inability to properly log all significant calls because of the high volume
                                             of calls and the lack of time available to make log entries;
                                           l failure to use the system to immediately check responses previously
                                             given the caller and an inability to check responses given to other callers
                                             with similar questions; and
                                           l failure to assign responsibility for reviewing the telephone log responses
                                             to the Office of Technology and Policy Analysis, the Commerce office
                                             directly responsible for the EAR.

                                               Because of weaknesses in the log system and because it is not used by all
                                               Commerce staff, only limited quantitative data are available on the
                                               amount of inaccurate or inconsistent advice that is given, the types of
                                               questions that most often result in such advice, and the Commerce units
                                               that most often provide such advice.

                                               Commerce may be able to adopt quality control mechanisms effectively
                                               used by the IRS to improve the quality of its advice. The IRS efforts in
                                               this area have shown some success as demonstrated by recent increases
                                               in the accuracy rate of its responses to taxpayer inquiries.


                                               We recommend that the Secretary of Commerce direct the Under Secre-
Recommendation                                 tary for Export Administration to ensure the accuracy of the oral advice
                                               provided on export regulations. To accomplish this, the Secretary may
                                               wish to

                                           l undertake a pilot project to quantify the nature and extent of the provi-
                                             sion of inaccurate and inconsistent advice and based on these results,
                                             take steps to increase accountability over staff currently providing oral
                                             advice, and if necessary, limit the number of staff authorized to provide
                                             advice or include them in the telephone log system;
                                           l direct the Office of Technology and Policy Analysis to periodically
                                             review the accuracy of responses noted in the telephone log; and
                                           . consider developing additional quality control mechanisms such as those
                                             used by the IRS that are potentially transferable to BXA’S operations.


                                               Page 18                                         GAO/NSlAD-9147 Export Controls
                  Chapter 2
                  Commerce Could Improve the Quality of Oral
                  Advice Provided on Export Regulations




                  The Department of Commerce concurred with our recommendation and
Agency Comments   elaborated on some of the difficulties we identified in this report. Com-
                  merce believes that it has met the recommendation’s intent and has
                  identified several programs implemented over the past several months
                  to aid in giving accurate and consistent oral advice. It also stated its
                  intention of soliciting advice from IRS. We agree that Commerce has
                  made significant progress in improving the quality of the oral advice it
                  provides, but it needs to continue focusing on this issue to ensure that
                  planned actions are completed.




                  Paye 19                                        GAO/NSIAD-9147 Export Controls
Improving the Readability of ihe commodity
Control List

                         An effective export control system requires that exporters be able to
                         correctly interpret the commodity control list. However, U.S. industry
                         representatives say the list is difficult to understand and use. Commerce
                         has taken some steps to improve the list, but has been hampered by
                         budgetary constraints and the press of day-to-day business. The list
                         would be easier to understand and use if it were restructured, explana-
                         tions were added, and it were typeset in a way that made entries less
                         confusing. Industry user groups indicated that such improvements
                         would promote their understanding of, and compliance with, export con-
                         trol regulations.

                         The United States, its North Atlantic Treaty Organization allies (except
                         Iceland), Australia, and Japan, coordinate their export control policies
                         to protect their national security through the Coordinating Committee
                         on Multilateral Export Controls. Each member country implements
                         export control policy agreements in the context of its own regulatory
                         framework. Because the United States, in concert with its Coordinating
                         Committee allies, has recently agreed to discontinue the existing control
                         list and develop a new one, Commerce has a unique opportunity to
                         improve the presentation of the new list.


                         Compliance with export control regulations depends on exporters being
Industry Finds the       able to determine whether a commodity is subject to controls and, if so,
Control List Difficult   what type of export license is needed. The control list is central to regu-
to Read and              latory compliance, from the initial product classification to the identifi-
                         cation of applicable licensing procedures. For this reason, the list needs
Understand               to be understood by the exporting community.

                         However, industry specialists most familiar with its contents, including
                         some members of Commerce’s technical advisory committees, expressed
                         varying levels of frustration in using the control list. One technical advi-
                         sory committee chairman, for example, told us that technical experts
                         who use the control list on a regular basis generally understand the
                         entries, but acknowledged that periodic or infrequent users tend to have
                         more problems understanding the entries and resolving ambiguities in
                         its policies.

                         Other committee chairmen expressed frustration with the control list
                         and advocated numerous improvements. For example, one of the
                         chairmen would like to see the entire control list reformatted to improve
                         its presentation and readability. The Chairman also favored eliminating
                         what he termed convoluted language, double negatives, and extraneous


                         Page 20                                         GAO/NSIAD-9147 Export Controls
                      Improving the Readnbility of the Commodity
                      C4mxol Li6t




                      wording, described as having accumulated over the past 40 years with
                      the constant addition of list amendments. Another chairman could not
                      recall how the commodity control list entries were currently formatted
                      because it had been so long since the U.S. list was last seen. Typical of
                      many other industry and U.S. government officials we interviewed, the
                      committee chairman regularly uses the British list, which is widely
                      acknowledged to be much easier to understand and use. The United
                      Kingdom, as with other members of the Coordinating Committee, pro-
                      duces its own list.

                      Export control managers at several high technology firms said that illog-
                      ical formats and methods of presentation and ambiguous expressions
                      frequently create confusion. Shortcomings they cited included too much
                      “legalese”; an illogical numbering system; confusing subparagraphs,
                      notes, technical notes, and advisory notes; and ambiguous regulations
                      that leave too much room for interpretation. As noted earlier, both the
                       1987 report on the impact of national security controls on international
                      technology transfer and the Price Waterhouse study identified regula-
                      tory complexity as a major problem needing attention.

                      The Price Waterhouse study, for example, indicated that the increasing
                      complexity of export regulations is a major factor adversely affecting
                      exporters’ compliance. It went on to suggest that Commerce rewrite the
                      regulations and the control list in easy-to-understand language, using
                      everyday industry terms. The study also suggested that typographic
                      aids, such as shading to highlight particular topics, be adopted to make
                      the list easier to use.


                      As discussed earlier, the last major effort to rewrite the export control
CommerceEfforts to    regulations occurred in the early 1980s. As part of that effort, Com-
Improve the Control   merce made a number of changes to the control list that improved its
List Presentation     ease of access, comprehensibility, and readability. These included
                      (1) removing column headings, (2) creating a new paragraph format,
                      (3) moving advisory notes to the control list from the supplement where
                      they were previously located, (4) incorporating the contents of footnotes
                      into regular text, and (5) consolidating export control-related informa-
                      tion from other parts of the regulations.

                      More recent attempts at improving the control list presentation have
                      been hampered by resource constraints and other Commerce priorities.
                      For example, Commerce has recently had as few as two of the six regu-
                      lation writer positions filled. According to a Commerce official, this staff


                      Page 21                                         GAO/NSIAD-91-47 Export Controls
                      Chapter 3
                      Improving the Readnbillty of the Commodity
                      Control List.




                      is generally kept busy with day-to-day responsibilities, such as writing
                      implementing regulations resulting from new legislation and Coordi-
                      nating Committee list reviews. This work has left little time for them to
                      undertake major new improvements to the control list.

                      Even though a formal improvement program is not currently underway,
                      Commerce does recognize the need to improve the control list and makes
                      changes to it on an ad hoc basis, generally in response to industry pres-
                      sure. For example, in response to industry complaints that various com-
                      modity control entries were difficult to follow, the agency reformatted
                      the page typography1 of the list for some key entries.

                      Commerce officials also believe that shaded coding, as found in the
                      British list, is useful for highlighting specialized types of information.
                      Therefore, Commerce has introduced the use of shaded advisory notes
                      in the most recent edition of the U.S. control list.


                      In addition to the improvements already made, Commerce can make the
The Commodity         control list more understandable and useful by rewriting and reordering
Control List Can Be   entries and by incorporating typographical formats that better show the
Made Easier to        subordinate relationships between subsections. Commerce will shortly
                      have a unique opportunity to improve the control list. This opportunity
Understand and Use    resulted from a June 1990 agreement among members of the Coordi-
                      nating Committee, including the United States, to “scrap” the present
                       116-item list of dual-use goods and replace it by mid-December with a
                      new list. As Commerce develops the new list to comply with this agree-
                      ment, it can maximize its efforts by also incorporating commonly
                      accepted principles of typography and visual presentation to effectively
                      improve the list’s readability.

                      The term “plain English” describes a number of document design princi-
                      ples that government agencies and major banking and insurance firms
                      have applied to forms and documents in recent years to simplify use and
                      improve comprehension. Based on our review of the control list, we
                      believe that control list entries can be made easier to use by rewriting
                      and reformatting them according to the plain English principles. For
                      example, guidance can be expanded for inexperienced users, and sec-
                      tions can be restructured to present related material in a single location.
                      Similarly, entries can be reformatted in keeping with plain English typo-
                      graphical principles to make them more readable and readily understood
                                                                                                                      -
                      ‘The term typography refers to the style, arrangement, or appearance of typeset matter.



                      Page 22                                                        GAO/N&ID-9147       Export Controls




                                                                                                .
                       Chaptm 3
                       Improving the Readability of the Commodity
                       Chdol Llat




                       by using larger type face, standard indentation, and expanded use of
                       shaded notes.

.“-_-----
Clearer Guidance and   Control list entries would be easier to understand and use if they incor-
Reorganization         porated user-oriented directions and headings that require little or no
                       experience in using the list. Figure 3.1 contains a sample of the introduc-
                       tory material found in each control entry. It contains a series of sections
                       providing information on requirements for obtaining a license to export
                       a particular controlled commodity.




                       Page 23                                         GAO/NSIAD-W-47 Export Controls
                                                chapter 8
                                                zyrort&ihe   Readability of the Commodity




Figure 3.1: Introductory Material for Commodity Control List Entry 152949



                                    1629A Electronic equipment            for testing, measuring or
                                    for microprocermodmicrocomputer            development,   aa fol-
                                    lOW8.

                                   Controlr      for ECCN 1529A

                                   Unit: Report in “number,”      parta and accessories in “$ value.”
                                    Validated     Licenee Required: Country Groups QSTVWYZ.
                                   GLV 6 Value Limit: $6,000 for all items in paragraph 6x6)           to
                                   Country Groups T & V, except $0 to the People’s Republic            of
                                   China; $3,060 for all other items to Country Groups T and          V,
                                   except $0 to the People’s Republic of China; $0 for all items to   all
                                   other destinations.
                                   Processing Co&: MT for items in paragraph 61x6); EE for all
                                   other items.
                                   Reason for Control: National       security; nuclear non-prolif-
                                   eration; foreign policy. Foreign policy controls apply for nuclear
                                   weapons delivery purposes to commodities described in para-
                                   graph (c) and (d) under the List below for launch and ground
                                   support equipment usable for complete rocket systems and
                                   unmanned air vehicle systems described in B 776.16(a).

                                   Special Licenees Available: No special licenses are available for
                                   commodities under foreign policy controls for nuclear weapons
                                   delivery purpoees (0 776.16(c)). See Part 773 for special licenses
                                   available for other commodities defined in ECCN 1629A.
                                   Technical Data: Exports of certain related technical data require
                                   a validated license to all destinations except Canada (see
                                   $779.4(dKZO)).
                                   GFW Eligibility: Commodities that meet technical specifications
                                   described in Advisory Note 2 under this entry regardless of end-
                                   use, subject to the prohibitions contained in $771.2(c).




                                                Page 24                                                     GAO/NSLAD91-47 Export Controls
chaptm 3
Improving the Readability of the Commodity
Control List




 For example, each control list entry has a section entitled “Unit,” speci-
 fying the unit of measurement exporters need to report on the export
 license application. Under our suggested approach, the heading “Unit”
 would be changed to read “Quantity to be Exported” so that even inex-
 perienced exporters could understand the intended meaning. The list’s
usability can also be increased by reordering the commodity control
entry contents with users’ needs in mind. As also shown in figure 3.1,
material relating to general and special licenses is scattered throughout
the introductory material. Figure 3.2 shows that reordering the prelimi-
 nary material consolidates guidance on general and special license eligi-
bility into three consecutive sections. This revision also incorporates
rewritten headings that show the relationship between the sections’ sub-
ject matter.




Page 25                                        GAO/NSIAD-9147 Export Controls
                                             Chapter 3
                                             Improving the Rendabiuty of the Commodity
                                             Control List




Figure 3.2: Revised Introductory Material Consolidating General and Special License Eligibility




                                      GLV liamme eligibilityz A gerasaal Iti
                                      iiar hitad due amnmoditiw (GLV licenne)
                                      is available few tshipmnrtn vahred at up to:
                                      $6ooO for all itema in
                                      aimtry pupa T & V, s                        :‘g
                                      Pecple’s E&public of china; $8,000 far all
                                      other itema to anmtry groups T .and V,
                                      except $0 to the People’e Repub!ic d china;
                                      ~$Oforallitematoallotherdeatmstions.
                                      GFW lioense         eligibilitr.  A gemmIld
                                      known aa a GFVV licesum may be available
                                      far1owlevelexport6fo~countie6ftr
                                      ammoditiw           that      meet the t4xhhal
                                       epetdficati~ deemibed in A&&way Note 3
                                      of tlh.e&y         mgtdeaa of =d-use, subject
                                       to the prahibirtiana described in 0 77l2(c).
                                       8peohd l&taes&fdlity:                 ‘No qecitd
                                       li-                             axxmKditie8 under
                                       fateigIlpolicya6ltrplsfarmlclearw8apon8
                                       delivery pm-paws (9 776.18(c)). Part 778
                                       deechbee epecial lieing           prowdyythat
                                       may be available in lieu of an mdndual
                                       validated lioenfw far ofdain other axn-
                                       mod&a covered by ECCN 1629A. (ase Part
                                        773-m 1)




                                             Page 26                                              GAO/NSL%D-91-47 Export Controls
---
                           Chapter 3
                           Improving the ReadabIlity of the Commodity
                           Control List




Improvements to            Although in recent years Commerce has improved the control list’s
Typographic Presentation   usability and typographic presentation by adopting such features as
                           shaded notes, further improvements can increase its ease of use. This is
                           demonstrated in figure 3.3, which compares a British and U.S. control
                           list entry. As can be seen from the figure, one potential way to improve
                           the list’s ease of use involves reformatting the list to distinguish
                           between outline levels. At present, it is difficult to distinguish sections
                           that are subsets of other sections because of the lack of uniform inden-
                           tation in the US. list. As shown in the figure, using uniform indentation
                           for all text in the outline entry, as is the case in the British list, more
                           readily identifies sections that are subsets of other sections. Commerce,
                           in commenting on a draft of this report, said that they have already
                           adopted more consistent indenting.




                           Page 27                                         GAO/NSIAD-9147 Export Controls
                                                            Chapter 3
                                                            ImprovIng the Readability   of the Commodity
                                                            Control List




Figure 3.3: Comparison of British and US, Control Lists

                                   U.S. List                                                                       British List

      1529A Electronl c equipment for testing, mefwwIng or                              IL 1529
      for mioroproceo~dmio~mpubr       developmeat, u fol-
      LOW&                                                                              Eltctronlc equipment for terrting, measuring or
                                                                                        for microprocessor/microcomputer       develop.
      Controlr for ECCN 152SA                                                           meat, as follows, and specially designed
      Lht of Equipment Controlled by ECCN 1WSA                                          “software” the&or:
        (8) Any teeting or meaauriag equipment:
                                                                                          (~1 Any testing or measuring equipment:
           (I) Not deucrihed in any other ECCN in the Commodity
      Control List; and
                                                                                                (1) Not de5crlbed In any other Item in this U5t; and
            (2) Designed for w)o at t+aqusncisr exuhsding 18 GHz;                               (2) &signed for use at frqusncicc cxcasding 18 GHz;
           Note: Thin paragraph (a)(2) does not control the following
                                                                                                    NB:
      equipment having a meximum specified operating &e-
      quency of 26.6 Gliz or Ieee:                                                                 This sub-item does not embargo the following equipment
                                                                                                   having II maximum rpocifird operating frequency of 26.5
              (8) Power metere;                                                                    CHz or tu):
                                                                                                   (1) Power meterr:
              (b) Broadband noise eourcee; or                                                      (2) Broadband noise sources: or
                                                                                                   (3) Nobo figure meters:
              Cc) Noiee figure metem;                                                    @) Lo@ ~alyrsn having any of the following characteristics,
         (b) Logic analyeere having any of the following characterie-                        and speclrlly dcslgned acceuori~ and rpeclally dcrlgnrd
      th. and epecially designed awesacrles and specially deeigned                           components       therefor:
      mmpcnents therefor:                                                                    (1) More than a total of 64 channels:
                                                                                             (2) A vnchronoru (atate) channel sampling rate of mom
            (1) Mom than a total of 64 channels;                                                   than 50 MHz;
                                                                                             (3) An a5 nchronour (tlmlng) channel mmpttng rate of more
           (2) A eynchronoue (et&a)        chennel   sampling rate of mom                          than I 00 MHz; or
      than 60 MHZ;                                                                           14) Probe lntcrfacw and Inverse ksremblsra, ucepr those
                                                                                                   dsalgncd       Ior ure with a microprocessor            or
           (9) An ~ynchronoue       (timing) channel enmpling rate of                              microcomputrr mlcroclrcuit “family” which contain5 at
      more them 200 MHZ;                                                                           tcut one mlcroproce55or or microcomputer mlcrocircuit
                                                                                                   that ir not embargoed by Item IL 1564:
             (4) Probe interfaces and inverse sasemblere, ezcept those                   (c) Frequency standard5 having both of the following
      derigned for tue with a micropmcerror or microcomputer micm                            characteristics:
      circuit “family” that contain ot bout one micmproorrsor D                              (1) Designed a5 relerence 5tandrrda for laboratory u5e: and
      micmcomputer microcircuit not conhwlkd by ECCN 1564A;                                  (2) Either of the followlng:
         W Frequency etander& having both of the following chnrac-                                 (A) A long-term drift (agelng) over 24 hour5 or more of
                                                                                                          1 part Or Iem in 101” 0r
      tarietice:                                                                                   (6) A #ho+term drift (instabillty) over 5 period from 1
            (1) Designed aa reference standarda for l&oratory         uee;                               to 100 seconds of 1 ptl or leas In IOJZ
      and                                                                                (d) Equipment contatning frequency dandards. having any of the
                                                                                             following characteristics:
            (2) Either of the following:                                                     (I) Designed for mobile we and having a long-term drift
                                                                                                   (ageing) over 24 hour5 or more of 1 part or lea5 In l(P
              (1) A long-term drift (aging) over 24 hours or more of 1                       (2) Drrigned for fixed ground uu and having 5 long-term
      pelt in lOL0 or less; or                                                                     drift (agelng) over 24 hour5 or more of !i parts or Icu in
                                                                                                   IO” or
              (ii) A short-term drift kaetebility)    over a period ham 1
      to 100 ssmnds of 1 part in 1Olz or leee;
         (d) Equipment containing frequency standards. having any
      of the following Charactwistice:
            (1) Ibrigned for moth IJIBand having a long.term drift
      (eglng) over 24 houm or more of 1 pert in 10’ or less:
            (2) Dwigwd for fixed ground ~110and having B long-term
      drift (Aging) over ‘& houra or more of 6 parte in 10” or less: or




                                                            Page 29                                                            GAO/NSLAD-9147 Export Controls
Chapter 3
Improving the Readability of the Commodity
Control List




Using a larger typeface than is currently used in both the headings and
body of the U.S. list is another way to improve the list’s ease of use.
According to research into the factors that affect legibility, text type
that is too small makes reading difficult. Small type basically reduces
visibility, which in turn, hampers word recognition. Research further
proposes that the most legible sizes of text type range from 9 to 12
point.2 The British list, which uses 9 point type appears easier to read
than the U.S. list, which uses 8 point type.

Improved typography, such as greater use of highlighted shading, can
also help eliminate the confusion coming from the large number of notes,
technical notes, and advisory notes that appear throughout the list. In
1989, Commerce attempted to adopt the British list’s use of shading to
distinguish advisory notes for Soviet Bloc countries and the People’s
Republic of China. Initial attempts to print this shading were less than
successful due to publication problems, but a Commerce official stated
that the problems have since been solved. Once it is clear that these
technical problems have been fully eliminated, Commerce can expand
the use of shading or other methods of highlighting to further distin-
guish between the commodity control list text and the text associated
with the many notes that users describe as confusing. In commenting on
a draft of this report, Commerce said that in revisions to the control list
published in late summer 1990 it had placed explanatory and technical
notes within box outlines to separate them both from the main text and
from the already shaded advisory notes.

Also, since legibility research shows that the overuse of italics impairs
readability and comprehension, a revised version could also restrict the
use of italics to cross references in explanatory items and to exceptions
in the list. Commerce’s current format uses italics for subject headings in
addition to these functional highlighting purposes, which results in a
large amount of italics type. Consistently limiting the use of italics to
only a few typographic highlighting functions can help some readers
better understand and use the list.




2Rob Carter Ben Day, and Philip Meggs, Typographic Design: Form and Communication (New York:
Vos Nostra& Reinhold and Company, 1985, p. 86).



Page 29                                                    GAO/NSLU-91-47 Export Controls
                          Chapter 3
                          Improving the Readability of the Commodity
                          Control List




                          The Commerce official responsible for the control list’s publication and
Commerceand               an industry representative agreed that the control list could be
Industry Agree That       improved by incorporating some of our suggested formats and presenta-
the Control List Cl5I-l   tional revisions. This Commerce official further indicated that there are
                          no operational constraints against making these improvements. The offi-
Be Improved               cial responsible for managing the formatting and presentation of the list
                          said that our suggestions for typographical and format changes
                          represent a substantial visual improvement. However, the official
                          expressed some reservations about the effect the changes had on the
                          size of the regulations, adding that the list is already criticized as exces-
                          sively large. However, with the recent agreement to substantially reduce
                          the list, length should not be an inhibiting factor.

                          Both the Commerce official and the industry representative said that
                          they favored our suggestion that the information be reorganized to
                          reflect the sequence of a user’s need for information and guidance. They
                          said they liked setting off notes with various types of shading, although
                          the Commerce official expressed reservations about users being able to
                          distinguish between various types of shading.


                          The U.S. control list is unnecessarily difficult for US. exporters to use
Conclusions               and understand. Over the years, Commerce has made improvements to
                          the list, but exporters continue to experience problems in using the list.
                          Commerce now has a unique opportunity to improve the list as it
                          develops a new list pursuant to a recent agreement between the United
                          States and its allies. In developing the new list, Commerce should seek to
                          make its presentation clearer and more readable. This can be done by
                          incorporating plain English features, such as user-oriented rewording
                          and typographical redesign. Knowledgeable Commerce and industry
                          officials confirmed that such changes would promote the control list’s
                          usability. Subsequently, senior Commerce export control policy officials
                          told us that they intend to improve the control list’s clarity while devel-
                          oping the new list.


                          We recommend that the Secretary of Commerce direct the Under Secre-
Recommendation            tary for Export Administration to incorporate into the development of
                          the new commodity control list design principles such as the ones
                          described above that will improve the list’s presentation.




                          Page 30                                          GAO/NSIAD-9147 Export Controls
-
                  Chapter 3
                  ImprovLng the Readability of the Commodity
                  Control List




                  Commerce concurs with our recommendation. In developing the new
Agency Comments   control list, Commerce has stated that it will incorporate as many of our
                  suggestions as practical. It has also identified a number of improve-
                  ments it has recently made to the control list’s readability.




                  Page 31                                       GAO/NSIAD-9147 Export Controls
Appendix I

CommentsFrom the Department of Comerce




                                                              UNITED     STATES     DEPARTMENT      OF COMMERCE
                                                              The Assistant     Secretary  for Administration
                                                              Washmgton,   D.C.   20230




                                                                  24 SEP 1990




             Mr. Frank C. Conahan
             Assistant    Comptroller    General
             National    Security    and International
               Affairs    Division
             U.S. General Accounting        Office
             Washington,     D.C.    20548
             Dear Mr. Conahan:
             Thank you for your letter   requesting      comments on the draft                   report
             entitled  "Export Controls:    Opportunities      for Improving
             Compliance with Export Administration        Regulations."
             We have reviewed the enolosed comments of the Under Secretary                           for
             Export Administration      and believe they are responsive to the
             matters discussed     in the report.
                                                     Sincerely,




                                                     Assista&   Secretary
                                                       for Administration

             Enclosure




                    Page32                                                         GAO/NSIAD-9147ExportControla
             Appendix I
             Comments  From the Department
             of Commerce




                                              UNITED    aTATE        DEPARTMENT            OF COMMRRCE
                                              The Undrr    Oocrrtrry      for Export       Adminirttwtion
                                              Weshmgton.       D.C.   20230

                                                                          September    7, 1990


Mr. Frank C. Conahan
Assistant      Comptroller     General
U.S. General Accounting          Office
National      Security    and
   International       Affairs   Division
Washington,      D.C.     20548
Dear Mr.      Conahanr
Thank you for your letter      to the Secretary       affording     the
Department  of Commerce an opportunity       to review and comment on
your draft  report   entitled,   Export Controls:        Oooortunitiee     for
Jmorovina  Comoliance with ExDort      Administration         Reaulations.
In the report,   GAO recommends that the Secretary      of Commerce
direct  the Under Secretary   for Export Administration     to ensure
the accuracy   of the oral advice provided  on export regulations.
We concur with this recommendation.
To aid in giving     accurate   and consistent   advice, we have
implemented   several    programs over the past several    months.    For
our assessment of the findings       relating  to this recommendation
and details   on these programs,     please see Enclosure   A. We
believe   the intent   of this recommendation     has been met.
GAO also recommends that the Secretary                of Commerce direct          the
Under Secretary         for Export Administration         to incorporate        into the
development        of the new commodity control         list   design principles
such as the ones described              in the report   that will    improve the
list's    readability.         We concur with this recommendation             and we
appreciate        GAO's suggestions.         Upon the development      of the new
control     list,    we will     incorporate    as many of these suggestions
as practical.          A detailed      assessment of the findings        relating     to
this recommendation          are included      a8 Enclosure    B.
We appreciate         this   opportunity     to comment on the draft                  report.
                                            Sincerely,



                                            Dennis         Kloske
Enclosures




             Page33                                                           GAO/NSIAD-9147 Export Controls
                                  Appendix I
                                  Comments From the Department
                                  of Commerce




                                                                  ENCLOSURE A


                      I.   -ion                          that the Secretary                   erce Direct   the Under
                                             or Export      Admi&i.stration toee                the Act uracv of the
                                               rovi&&$      On &&port Reaulafions
Nowonpp   12and 13.   +-   Paa-        I7 - 19..      Firms    Voice    Comolaints       About      Inconsistent        and

                           Through day-to-day         hands on experience,              and discussions        with their
                           colleagues,       BXA's Exporter        Counselling         Division     (ECD) and regional
                           offices      are able       to provide          the most accurate               responses       to
                           exporters'      inquiries.         In addition,          our Computer Phone Log helps
                           ensure that ECD and the regional                  offices       provide    the same correct
                           answer each time.           The counselor           simply checks the phone log for
                           a record     of when that exporter             called      last,     what the question       was
                           and what the counselor's             response was.           This not only ensures that
                           we provide       the same response,            but it provides           a quality      control
                           function     by allowing      the staff      to discuss the questions              and answers
                           given to exporters.             The ltOne-Voice Program" also helps to ensure
                           that we are providing             consistent        information        to the public.         The
                           office     of Export Licensing           (OEL) meets once a month to interpret
                           and discuss new regulations              to assure that consistent                and accurate
                           guidance     is provided       to the exporting           community.        This information
                           is communicated to the regional                 offices      after each meeting so they
                           too speak with one voice.
                           The report       talks    about     exporters      llshoppingll     for     the desired
                           response.        Exporters      sometimes      do shop around            for    the most
                           favorable      answer,     but shopping        around      is not the result               of
                           inconsistent      advice.      Rather,   it is a result         of exporters        hearing
                           what they do not want to hear.              In addition,        exporters      will   often
                           change their      export scenarios      when they call more than once.                  Even
                           a slight      change in the facts            can change our answer to their
                           questions.       We are concerned       that GAO did not question               exporters
                           to determine       whether they described           the exact same transactions
                           every time they called           and the methods GAO used to measure the
                           quality     of responses     from exporters       interviewed.
Now on p. 14          B.   paaes 20 21..           Timited    Control   Over Larae Number of St aff             Providinq
                           --
                            The report       discusses      the limited       control      over the large number of
                           .etaff    providing      advice to the public,            and how the phone log system
                            is only used by a minority             of Commerce staff.            ECD and the regional
                            offices       are     the    primary      offices         responsible       for     answering
                            exporters'        questions.          Exporters         are aware that           information
                            regarding        export     regulations        is obtained          through     ECD or our
                            regional     offices.       This message is conveyed through our brochures,
                            BXA's newsletter          the QEL Insider             and at our nationwide            seminar
                            programs.       Even the ITA District           oifices      refer exporters       to BXA for




                                  Page 34                                                     GAO/NSIAD-91-47 Export Controls
                                   Appendix I
                                   Comments From the Department
                                   of Commerce




                                                                     -2-

                           complex      liceneing     questione.      ECD and the regional        offices     may
                           refer    the exporter       to the appropriate       OEL strategic  trade officer
                           for    information        on a specific        case,    or to BXA's Office           of
                           Technology          and    Policy     Analyeie       (OTPA)     for  a     technical
                           interpretation,         such as a commodity classification.
                           The report also states that the phone log system is not used by the
                           more than       130 other    BXA professional   staff    who respond     to
                           questions,     or by the 150 ITA Trade Specialists          located in the
                           District   Offices.     For the reasons stated above, it would not be
                           beneficial    for them to be connected to the phone log system.        They
                           do not routinely     provide  advice on export regulations.
Now on pp, 14 and 15       Paces    21-23:      Ooerational       Problems     With    the Telephone        Loa Svstem
                           The report         state0      that the ECD and the Western Regional                     Office
                           limit      their      phone log entriea                to only     the most "significant
                           inquiries,"         and that the staff             uses its own judgment to determine
                           what is considered              significant.            Our offices      seek to record all
                           calls     into      the phone log with the exception                      of routine     status
                           questions.          However, because we handle hundreds of calls                       per day,
                           we do not always have time to record each call into the phone log.
                           To help ua achieve the goal of logging                        &JJ. calls,      we continue     to
                           encourage        exporters         to use our electronic                services     to handle
                           matters that do not require                   regulatory    interpretation.         Staff will
                           then be able to concentrate                  on the more complex questions,            and have
                           the time to use the phone system to record these calls.                                 We have
                           recently        developed        a brochure           that   explains       how to use our
                           electronic         eervicea.          We hope that exporter              awareness of these
                           service8      will     lighten      the load on our counselors               80 they have the
                           time they need to utilize                 fully     the phone log.
                           The report   further   states that we can only sort calls       recorded in
                           the phone log according      to caller.     This is not true.   The reports
                           which are generated      from the phone log can be sorted by type of
                           caller  and nature of the call.         In addition,  we can print   out the
                           comment field     which will    give the question    asked and the answer
                           given.   In this way, we monitor the accuracy and consistency          of our
                           advice to the exporting       community.
                           The report       also implies       that OTPA ehould have the responsibility
                           for     eneuring     accurate      and consistent           advice      to the exporting
                           hommunity        because      they      maintain        the     Export       Administration
                           Regulations       and provide written          interpretations,          such as commodity
                           classifications        and advieory         opinions.        The ECD and the regional
                           offices       are the primary         offices      responsible        for providing         oral
                           advice to the exporting           community.         Moreover,      although    OTPA writes
                           the regulationa,        they do so with the consultation                  and clearance        of
                           other offices        in BRA. The ECD regularly                 advises     the Regulations
                           Branch of OTPA regarding                  changes that         should     be made to the
                           regulations       based on contacts          with the exporting           community.

                       Y




                                   Page35                                                        GAO/NSLAD-91-47ExportControls
                           Appendii I
                           Comments FromtheDepartment
                           ofCommerce




                                                              - 3 .-


Now on p 16.        Paa-      23 24,
                                -      l
                                           Commerce Does Not Alwava             Obtain    All     Pertinent
                     nforc&@tion       When Resoondina to Oueries
                    We recognize        the importance       of asking      the exporter       the right
                    queetione,      and do so to the extent         possible.      To ensure that new
                    employees      get the proper training          needed to work in ECD or the
                    regional    offices,      they are assigned       to an experienced       counselor.
                    The new employees spend several            days just listening      in on calls      to
                    ensure that they become familiar             with our "probing       techniques."
                    However,     consulting       over the phone does have its             limitations.
                    Without    written     documentation     in front    of UB as we speak, we must
                    rely on what the exporter            chooses to tell       us in response to our
                    questions.
Nowonp   16         paae 24:        Hiah Turnover      Lowers    Experience   Level
                    ECD does have a history           of high turnover.          One of the reasons was
                    the low grade structure.             This was changed early           this year,      and
                    will   most certainly      aid in retaining          good employees.       However, ECD
                    employees     are often        young, well-educated          and in a position          to
                    enhance their      careers after mastering            the regulations     in ECD. They
                    move on to jobs which build on the expertise                 they developed working
                    for ECD: Another reason for high turnover                      is job burnout.        ECD
                    staff    answer dozens of calls            a day.        We have made some changes
                    which ehould help prevent job burnout.                  Counselors no longer answer
                    the phone eight hours a day.                Rather,     they are on the phones for
                    part of the day, and then they are given time to work on other
                    projects    including     writing    articles      for the OEL Insider,       preparing
                    for seminars where they will             participate       as speakers,     and working
                    on a wide variety        of other assignments.
Nowonp   17    C.   Paces 24-25:   Other            Oualitv     Control   Mechanisms     Are    Potentiallv
                    Available to BXA
                    GAO's references     to IRS efforts      to improve its           accuracy  in advice
                    to the public    are interesting.       We will  solicit          advice from IRS on
                    the costs and benefits       experienced    to date.
                    Moreover,    we agree that probing     to obtain   all  the facts      needed
                    about    a situation     and a stable   and experienced     workforce     are
                    important   factors    in assuring the accuracy of information      given to
                    the public.      We are aware of this and, as stated above, have taken
                    'steps to address problema that have arisen in the past.




                           Page36                                                GAO/NSIAD-91-47ExportControls
              Appendix I
              CommentsFromtheDepartment
              of Commerce




               ADDITIONAL PROGRAMSTO ACHIEVE ACCURATE ORAL ADVICE

    Through the opening of our regional      offices,     expanding    the Exporter
    Counselling   Division     (ECD), and adding      automation     aide,   we are
    increasing  our responsiveness     to exporters.       In addition,     we have
    implemented  several   programs over the paat several       months, including:
      Qne-voice       PrQQr~:       OEL meets once a month to diecuss               new
      regulations        and their   implications     for licensing     activ%ties.
      Thie allows         OEL to speak with       "One-Voice"     to the exporting
      community.         A summary of the meeting is transmitted               to the
      regional      offices    through OEL's network,         so that the offices
      provide     the same information         as provided     in Washington.
      m-Line    Reaulationsr ECD staff    with access to the Local Area
      Network can review the export      regulations         on their     computer
      in the course of their    counselling       activities.          Electronic
      acceae to the Export Adminietration         Regulations         (BAR) keeps
      the staff   up-to-date on the latest       changes and developments
      in the regulationa.
            ne Feder 1 Reaieter:         Network uaera also can review new
      eal.        &cisater    notices   to ensure that   they are informed
      about regulations        as soon a8 they are published.     BXA also
      sends advance notice          of regulations   to BXA and ITA staff
      domestically       and abroad.

      elsctronic:                Users of the network            may transmit      all
      significant    information     to BXAoffices       (including     the regional
      offices)    the flame day in hard copy format.                E-Mail     is also
      uBed to inform        users    of unique      licensing       questions,     and
      enables the ECD etaff        to discuss    the question        and provide     an
      answer.
             wina Servicer     ECD is a part of a Commerce newspaper
      clipping    service  that keeps the staff   up-to-date    on current
      event8 which may affect     export controls  and licensing.
    We are      always seeking   waya to increase      the public's   awareness and
    understanding       of the EAR.     In addition   to our exporter   counselling
    services,      we have an ambitious    seminar program including    24 seminars
    per year --a one-day and three-day         program each month.     US&FCS Trade
    SpeCialiBts      participate in these seminars.
    BXA hae made great stridea      in improving    its services             to the public.
    Reaction   from the Congress       and business      community           has been very
    favorable.    Complaint   calls  are virtually     non-existent.             However, we
    are always willing    to look at ways to achieve additional                improvements.




Y




              Page37                                                  GAO/NSIAD-9147Export   Controls
                                  bpendix 1
                                  CommentaFrom theDepartment
                                  of Commerce




                                                                   BBCLOSUBBB

                      II.   s '
                            of the Comglpditv         Control        List
Now on p 20           A.    r                    V             e
                            Australia   should        be added to the                 list      of COCOMmembers given             in
                            the report.                                                                    \

Now on pp 20 and 21   B.    -es       30 -rIu
                                           32            trv       Finds     the      Control       List   Difficult        to Read

                            The comment from the TAC Chairman that he uses the British                          list
                            instead     of the Control        List     is not surprising.        Some exporters
                            claim that the British             list     is easier  to follow      than the more
                            bulky     COCOM International             List,    and it     is not classified.
                            However, the TAC Chairman could not rely on the British                        list      to
                            determine     properly     U.S. legal requirements.           In addition,     most of
                            the industry         complaints      would not be completely          eliminated        by
                            formatting      improvements.         Most of the confusion      is caused by COCOM
                            agreed     technical     wording,       which is negotiated         by a 17 member
                            organization.
Now on pp 21 and 22   C.    paaes      32 33         Commerce Efforts                  to      Improve     the    Control      List
                            d
                            The changes to the regulations         published    in August 1990 will place
                            the various   technical      and explanatory     notes in boxes, so they can
                            be more clearly     distinguished      from the main text.

Now on pp 22 to 29    D.    pace 33 - 42 8    he Commodity                  Control          List   Can Be Made Easier            To
                            Understand    and Use

Now on p. 22.               The reference     at the top of page 34 to "eight      simple categories"
                            is misleading.      The current    list is in ten simple categories;      the
                            complexity     comes within    each of the ten categories.       It is too
                            soon to know if the goal of simplicity         in the core list    exercise
                            will  be fully    realized.
Now on p. 28.               Figure    3.3 on page 40 is intended              to display       the benefits         of
                            larger   type, it inetead       shows a difference         in overall      formatting.
                            What is striking       is not the negligible          difference        in type sire,
                            but rather      the differences       in indenting       and use of open space.
                            BXA has already       adopted the more consistent              indenting       and will
                            review    spacing    and suggested       formatting      in formulating         the new
                            list.    Along with uniform        indentation,      BXA has also responded to
                            the need for distinguishing             various     explanatory        and technical
                            notes from the main text.            Substantial      revisions       to the Control
                            List published      in late Summer 1990 place these notes within                       box
                            outlines    to separate      them both from the main text and from the
                            already    shaded Advisory      Notes.




                                  Page38
                         Appendix I
                         Comments From the Department
                         of Commerce




                                                          -2-


Nowon p.30       E.   paae 42-43:    Commerce and Industrv             mree    That   the   Control    w9s,
                      San Be &wroved
                      Until    we have an agreed core list               for COCOM controlled          items
                      (i.e.,     items     controlled     multilaterally       for national        security
                      reasons),     we will     not know how complex the core list            will    be or
                      how it might influence           the size of the complete            Control     List,
                      which     contains     foreign    policy      and nuclear     controls     as well.
                      However, BXA is committed to working with industry                 to develop ways
                      of improving       the organization        and structure    of the Control       List.




             Y




                         Page 39                                                 GAO/NSIAB9147    Export Controls
               Apptdix I
               Comments From the Department
               of Commerce




               The following are GAO'S comments on the Department of Commerce’s
               letter dated September 24, 1990.


                1. We agree that to provide consistent advice involving a specific export
GAO Comments   Commerce officials must be provided with the same set of facts. Chapter
               2 of our report discusses the importance of obtaining all pertinent infor-
               mation when providing oral advice. Regarding Commerce’s concern that
               we did not ascertain whether exporters were describing the same exact
               transaction, we had no indication from our discussions with exporters,
               as well as from our own experience with Commerce, that there was any
               alteration of the basic facts of a situation. Regarding Commerce’s con-
               cern about our method of measuring the quality of responses, we
               obtained Commerce’s position as to the appropriate response to a given
               question. This was based on our belief that Commerce, as the agency
               responsible for administering export controls over dual-use goods and
               technology, is the appropriate party to assess the accuracy of its
               responses. In the course of our work, Commerce officials acknowledged
               that oral advice is sometimes inaccurate and inconsistent and that it
               may result in exporters shopping for advice,

               2. As discussed in chapter 2 of our report, ITA'S district offices handle
               several thousand calls each year, albeit far fewer than BXA. No data are
               available on how much oral advice is provided by BXA professional staff
               outside WRO and EAS. We concluded that BXA may wish to include these
               staff in the telephone log system to improve accountability after
               assessing the nature and extent of the provision of inaccurate and incon-
               sistent advice.

               3. We are aware that Commerce is capable of generating reports from its
               telephone log system that can be sorted by the general nature of the
               calls, such as requests for regulatory information, classifications, or
               export control forms, and have revised the report to include this infor-
               mation However, a Commerce manager involved in providing oral
               advice, as well as the industry consultant who designed the log system,
               told us that it is not possible to sort responses according to subject
               matter.

               4. We have revised the report to include Australia.

               5. We agree that the U.S. control list must be used to determine U.S. legal
               requirements. However, the British list is regularly used by both U.S.
               government and industry officials for quick and easy reference.


               Page 40                                        GAO/NSIAD91-47 Export Controls
Appendix 1
$zhtvrn      the Department




6. We have revised the report to state that the Coordinating Committee
has agreed to develop a new list, which offers the opportunity to
improve the list’s readability. We agree that it is too soon to know if the
goal of simplicity in this list will be fully realized.

7. We have revised the report to emphasize the benefit of indenting and
using open space. We have also recognized BXA’S improvements.




Page 41                                         GAO/NSIAD-9147 Export Controls
Appendix II

Major Contributors to This Report


                        Steven H. Sternlieb, Project Director
National Security and
International Affairs
Division, Washington,
DC.
                                                                -
                        Kane Wong, Issue Area Manager
San Francisco           Evelyn E. Aquino, Project Manager
Regional Office         Robert R. Tomcho, Evaluator
                        Gerhard C. Brostrom, Report Analyst



Office of Publishing    Kim Wheeler, Publishing Consultant
and Communication




(443663)                Page 42                                     GAO/NSIALb91-47 Export Controls
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