Comments on: No Relief In Pressure Relief Valve Export Settlement http://www.exportlawblog.com/archives/1865 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Mark Williams http://www.exportlawblog.com/archives/1865/comment-page-1#comment-98601 Mark Williams Fri, 28 May 2010 05:57:29 +0000 http://www.exportlawblog.com/?p=1865#comment-98601 What probably happened is that the BIS only had info on the specifications for the EAR99 classified pressure relief valve but did not have all of the information required to make a proper judgment. Just like you say, a pressure relief valve would not be ideal for a chemical weapons system but, since it is interchangeable with the back pressure valve, they should have both been classified as 2B350, especially if the valves are using the anti corrosive materials for the whetted parts described in the regulation. What probably happened is that the BIS only had info on the specifications for the EAR99 classified pressure relief valve but did not have all of the information required to make a proper judgment.

Just like you say, a pressure relief valve would not be ideal for a chemical weapons system but, since it is interchangeable with the back pressure valve, they should have both been classified as 2B350, especially if the valves are using the anti corrosive materials for the whetted parts described in the regulation.

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