Please be advised that the declaration regulations (Chemical Weapons Convention) came into force March 11, 2010.
Two new proposals to enhance the information provided in declarations of other chemical production facilities (OCPF) in order to improve site selection methodology.
The “Other Chemical Production Facilities” (OCPF) regime was agreed in Geneva in the last phase of the negotiations for the Chemical Weapons Convention to fill the so-called “verification gap”. The objective of the OCPF regime is to deter the use of OCPFs for CW-related activities and to provide confidence to States Parties that OCPFs located in other States Parties are not being misused for covert CW production. OCPFs produce by synthesis Discrete Organic Chemicals (any chemical belonging to the class of chemical compounds consisting of all compounds of carbon except for its oxides, sulfides and metal carbonates).
There are currently more than 4,600 declared OCPFs in 79 countries and as of 30 October 2008 only 12% have been inspected since inspections began in 2000; too little to offer the necessary non-proliferation comfort that we all need. What can be done? As there are limits to the increase in the number of OCPF inspections, changes to the selection methodology are required to ensure that facilities that are most relevant to the Convention are inspected.
Until recently, a two-step selection algorithm was used. In the first step an equal probability of selection was allocated to all States Parties and then in the second step an OCPF within the selected State Party was chosen. In the first two years of implementation, this led to selection of low relevance sites producing high-volume chemicals such as urea, formaldehyde, methyl-tertiary-butyl ether and methanol. Canada was no exception. Three of the four inspections took place at urea plants. In a first attempt to improve the selection methodology, the Technical Secretariat of the OPCW introduced an improved second-step selection algorithm (the so-called A14 algorithm) starting from 2002 which resulted in better targeting of more relevant sites. But the equal probability for selection of States Parties in the first step continued to produce less than equitable inspections distribution: by the end of 2006, 17 States Parties with small chemical industries had 100% of their OCPFs inspected, while the 5 top States Parties possessing 67% of the total worldwide number of inspectable OCPFs have had only 1% of their plant sites inspected. Something was clearly wrong and corrective action was needed.
Starting from 1 January 2008, at the OPCW Director General’s initiative, a new selection methodology was put in place. This new one-step methodology that uses two weighting factors (the geographical distribution factor and the information weighting factor based on the A14 algorithm) has already produced a more equitable geographical distribution. But progress towards a better selection mechanism of the more relevant sites with advanced engineering features and process capabilities remains an elusive desiderate. More needs to be done.
At the root cause of the problem is the scarcity of information that has to be provided in OCPF declarations. Indeed, Part IX of the Verification Annex requires States Parties to provide only minimal data about their OCPF plant sites: a) the name of the plant site and the name of the owner, company, or enterprise operating it; b) the precise location of the plant site including its address; c) its main activities; and d) the approximate number of plants producing the unscheduled discrete organic chemicals (DOC). In addition information on the approximate aggregate amount of production of DOC in the previous calendar year expressed in ranges has to be provided. That’s hardly enough to enable the Technical Secretariat to make an informed decision when selecting a site for inspection.
Two new proposals by the Director General of the OPCW will go a long way in addressing this problem. States Parties have been describing plant site “main activities” through the use of "product group codes" derived from the "Standard International Trade Classification (SITC) since 2000. Under the first new proposal, new SITC subcategories codes will be introduced to better identify sites producing bulk chemicals of low relevance to the Convention. These new product group codes are: 512A for methanol; 512B for other alcohols, phenols, phenol-alcohols, and their halogenated, sulphonated, nitrated or nitrosated derivatives; 514A for urea; 514B for other nitrogen-function compounds; 516A for formaldehyde; 516B for methyl tert-butyl ether (MTBE); 516C for other organic chemicals; 554A for detergents produced by neutralisation of sulphonic acids; 554B for soaps produced by saponification of a fatty acid; and 554C for other soap, cleansing and polishing preparations. Use of these sub-codes will result in a better identification of low-relevance OCPFs and reduction of the probability of inspection of these sites.
The second proposal, subject to agreement by States Parties, will require the provision of additional information on the type of process and equipment configuration of the plants producing Discrete Organic Chemicals at a plant site (batch versus continuous and dedicated versus multipurpose). More specifically, companies will be asked to answer the following two questions: 1) Please indicate if your plant site consists of plants that are dedicated, multipurpose or both. (Answers: all dedicated; all multipurpose; both); 2) Please indicate if your plant site consists of plants that are operated continuously, in batch mode or both. (Answers: all continuous; all batch; or both).
Canada will start to implement voluntarily both these proposals ec53s05 (PDF version, 94.2 KB) * and ec53dg11 (PDF version, 142 KB) * at the end of this year with the request for information for the Annual Declarations of Past Activities for 2008. We count on Canadian companies to support the implementation of these important changes that will benefit all of us through a more efficient use of scarce resources.