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CUI Considerations For The Heat Treating Industry Published in Heat Treating Today Magazine, March 2024
In this article, you will learn what is and what is not considered Controlled Unclassified Information (CUI). If you are a prime contractor for the Department of Defense (DoD) or a subcontractor, then you have CUI in one form or another whether it be paper or digital format.
What Exactly Is Considered CUI?
The DoD handles CUI in many forms across its operations. CUI includes sensitive information that requires safeguarding but does not meet the criteria for classification as classified information. Examples of DoD CUI may include:
Export-Controlled Information: Information that is subject to export control laws and regulations, such as technical data related to defense goods and services.
For Official Use Only (FOUO): Information that is not classified but still requires protection from unauthorized disclosure for official government use.
Critical Infrastructure Information (CII): Details about critical infrastructure elements like facilities, systems, networks, and assets that are essential for national security, economy, or public health.
Privacy Information: Personal information of individuals (e.g., Social Security numbers, medical records) that needs protection under privacy laws and regulations.
Sensitive but Unclassified (SBU) Information: Information that, although unclassified, is sensitive and requires protection due to its potential impact if disclosed.
Contract-related Information: Non-public details within contracts, such as proprietary information, financial data, or technical specifications.
Proprietary Information: Data owned by an entity and protected by intellectual property rights or confidentiality agreements.
In the heat-treating industry, DoD CUI might include various sensitive details related to heat treatment processes, materials, or specifications used in defense-related applications. Here are some potential examples of DoD CUI within the heat-treating industry:
Material Specifications: Specifications for heat-treated materials used in defense equipment, weapons systems, or components. This could include details about specific alloys, heat treatment methods, tempering, or hardening processes required for certain applications.
Process Documentation: Detailed procedures and technical information regarding heat treatment processes employed in the production of defense-related materials or components. This might involve specific temperature ranges, cooling rates, or other proprietary methods used in heat treatment.
Quality Control Data: Information related to quality control measures specific to heat treating in defense-related manufacturing. This could involve data on testing methodologies, inspection techniques, or standards compliance for heat-treated materials used in critical defense systems.
Research and Development (R&D) Information: Research findings, experimental data, or proprietary knowledge related to advancements in heat treatment technologies tailored for defense applications. This may include innovative heat treatment methods for enhancing material properties, durability, or performance in defense systems.
Supplier Information: Details about suppliers providing heat treatment services or materials to the defense industry, including contractual agreements, proprietary processes, or specifications specific to DoD projects.
Cybersecurity Measures: Information about cybersecurity measures employed within heat treatment facilities that handle DoD contracts or projects to safeguard sensitive data from cyber threats.
Facility Security Protocols: Details regarding security protocols, access controls, and clearance requirements within heat-treating facilities handling defense-related projects to prevent unauthorized access to sensitive information.
Other items that may be identified as CUI provided by the DoD or generated in support of fulfilling a DoD contract or order include, but are not limited to (in both paper and digital formats):
Research and engineering data
Engineering drawings & lists
Technical reports
Technical data packages
Design analysis
Specifications
Test reports
Technical orders
Cybersecurity plans/Controls
IP addresses, nodes, links
Standards
Process sheets
Manuals
Data sets
Studies & analyses and related information
Computer software executable code and source code
Contract deliverable requirements lists (CDRL)
Financial records
Contract information
Conformance reports
What Is Not Normally Considered CUI?
Here are several examples of items that may not typically fall under DoD CUI for the heat-treating industry:
General Industry Standards: Information related to commonly accepted industry standards, processes, or procedures that are widely available and not specific to defense-related applications.
Non-Proprietary Heat Treatment Techniques: Basic information about standard heat treatment methods or techniques that are publicly known and not proprietary to a particular organization or application within the defense sector.
Publicly Available Research: Scientific or technical research findings, publications, or data that are publicly accessible, not subject to proprietary rights, and not specifically tied to defense-related advancements.
Commonly Shared Best Practices: Information regarding widely accepted best practices in heat treating that do not involve proprietary or classified techniques applicable solely to defense-related materials or components.
Non-Sensitive Business Operations: Routine business operations, administrative documents, or general non-sensitive communications within the heat treating industry that do not pertain to defense contracts or projects.
Information Approved for Public Release: Data that has been officially approved for public release by the DoD or other relevant authorities, ensuring it does not contain sensitive or classified details.
Basic Material Specifications: Information about materials, alloys, or heat treatment processes widely used in commercial applications and not specifically tailored or modified for defense-related purposes.
About the Author
Joe Coleman is the Cyber Security Officer for Bluestreak Consulting™, which is a division of Throughput | Bluestreak | Bright AM™. Joe is a Certified CMMC-RPA (Registered Practitioner Advanced).
Joe has over 35 years of diverse manufacturing and engineering experience. His background includes extensive training in cybersecurity, DFARS, NIST SP 800-171, and CMMC, a career as a machinist, machining manager, early additive manufacturing (AM) pioneer, and production control/quality management software implementer/instructor.
Contact Joe Coleman at joe.coleman@go-throughput.com or at 513-900-7934 for any questions and a free consultation with a complimentary detailed compliance eBook.
About Bluestreak™:
Bluestreak™ is a powerful Manufacturing Execution System (MES) and a fully integrated Quality Management System (QMS), designed for the manufacturing environment and service-based manufacturing companies ( metal-treating/powder-coating, plating, heat-treating, forging, and metal-finishing), businesses that receive customers’ parts, perform a process (service) on them, and send those parts back to the customer). Companies need MES software tailored to specific functionality and workflow needs such as industry-specific specifications management, intuitive scheduling control for staff and machinery maintenance, and the ability to manage work orders and track real-time data. If different work centers on the production floor aren’t “speaking” to each other via the MES, the data loses value and becomes disjointed or lost in disparate silos.
Bluestreak | Bright AM™ is an MES + QMS software solution specifically designed to manage and optimize the unique requirements of Additive Manufacturing’s production of parts and powder inventory usage.
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