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Setting up a National Authority | Initial Declarations Under Article VI | Identification of Declarable Activities | Preparations for Inspections
Preparations undertaken by the National Authority to facilitate the conduct of an OPCW inspection normally consist of the following activities and elements:
The inspected State Party (ISP) shall acknowledge the receipt of a notification by the Secretariat of an intention to conduct an inspection, not latter than one hour after receipt of such notification. The procedures for receiving and replying to such notifications should be established by the ISP.
The National Authority should notify as soon as possible the facility to be inspected. Depending on the type of inspection, the National Authority will activate the appropriate escort team.
The National Authority should establish procedures for receiving an Inspection Team (IT) at the POE. These procedures include administrative/logistical support arrangements and procedures for the ISPs inspection of the approved equipment carried by the team. The National Authority should carry out the following arrangements and activities that will assist the IT:
Establish a meeting point at the POE where the National Authority will meet the IT.
Arrange for the smooth and timely passage of the IT through customs and immigration and collection of all their personal belongings and inspection equipment.
Arrange for a suitable room at the POE where the National Authority will receive the IT and where the Inspection Mandate can be handed over. The ISP shall confirm all relevant information concerning the members of the team (the names and numbers of inspectors, UNLP no, visas, etc) as provided in the notification of inspection and shall sign for receipt of a copy of the inspection mandate.
Conduct the inspection of ITs equipment against the equipment list contained in the Inspection Mandate and the approved list of equipment (CI-DEC.7.). If any equipment is excluded from the inspection, a room should be provided at the POE where such equipment could be safely and securely stored.
Brief the IT with the immediate logistical arrangements and provide communication means for the IT to contact their headquarters. Alternatively and if available as part of the inspection equipment, the IT can establish such contact by using their own communication equipment.
Arrange for suitable transportation means for the inspection team and their equipment from the POE to the facility to be inspected within 12 hours after arrival.
After receipt of the notification, the National Authority informs the site to be inspected and may send an advance team to the Site in order to co-ordinate and assist the local personnel to prepare for the inspection.
The Advance Team should be able to assist the site with advice for the pre-inspection briefing, preparation of a Preliminary Draft Facility Agreement, preparation for records review and personnel interviews, identification of confidential business information, which are not to be disclosed during the inspection, and logistic aspects which can facilitate the smooth and timely conduct of inspection activities.
3.1 Administrative arrangements
Arrangements for administrative and logistic support shall be made prior to the arrival of the IT to facilitate the inspection. Such arrangements shall include:
Provision of amenities normally requested by the IT, i.e. means of communication, interpretation services, workspace and storage facilities at the Site, accommodation, meals, and medical care
Provision for transport of the IT, their belongings and all inspection equipment throughout the inspection period, from arrival at the POE up to return to the POE, noting the number of inspectors, volume of inspection equipment, need for international airline tickets, etc.
3.5 Site preparation
In preparing the site for inspection, the National Authority escort team can advise the inspected facility on the following issues:
Declarations should be thoroughly checked and updated by representatives of the ISP and/or Site prior to the arrival of the IT at the site. A copy of the declaration should be available
Confidential business information at the level of confidentiality established by the site management and/or the National Authority will be treated by the OPCW as such and protected in accordance with its relevant procedures. However, the site management might not be willing to disclose certain information, which are considered sensitive. This concern, however, should not hamper the development of the inspection and alternative ways for fulfilling the aims of the Inspection Mandate should always be provided.
Identification of the records/documents and their location
The inspection team should be provided with a pre-inspection briefing. Representatives of the ISP and site personnel should prepare the information that will be presented to the inspection team during this pre-inspection briefing. The main topics included in this presentation are:
Activities, business and manufacturing operations taking place at the site
Physical layout of the plant and site
Delineation of declared areas
Scheduled chemicals on site
Process description, including Block and process flow diagrams, Brief description of the process, Unit operations
Emergency procedures to be followed (alarms/signals, routes and exits, location of assembly points/emergency shelters, areas at which access is limited or not allowed due to health or safety reasons, location of medical facilities, etc.)
A site tour may also be provided to the IT. The route followed during this site tour and the information related to the plant site presented during this site tour are intended to allow the IT to familiarise itself with the site and finalise the inspection plan.
After completion of the pre-inspection briefing and site tour, the actual inspection activities commence. These are in general governed by a mutually agreed Inspection Plan, proposed by the IT. The inspection plan covers all the activities to be performed in order to fulfil the aims of the inspection mandate. The activities may vary depending on the type of the inspection, but generally include the following:
4.1 Physical inspection
The inspection team, accompanied by representatives of the ISP and the inspected facility to be inspected, physically inspect all areas and buildings within the declared perimeter. Access to some areas or buildings may require using personal protective equipment as well as inspection team equipment.
Adequate logistics for the timely and smooth passage of the inspection team through the areas and buildings at the Site and knowledgeable personnel from the inspected facility to assist in clarification of activities performed and equipment employed at the inspected facility, is of utmost importance.
Depending on the inspection, the inspection team may divide into one or more sub- groups, which will require the availability of more manpower from the ISP and Site to be inspected in order to assist in the physical inspection of the Site.
4.2 Records review
For the purpose of the inspection, certain documents need to be reviewed by the IT. Assistance from the appropriate authorities to obtain and make such documentation available to the IT in a timely manner will enhance the productivity during the inspection period. Such documentation may include the following:
4.3 Sampling and Analyses
If sampling and analysis is to be performed, representatives of the ISP and the Site will render assistance to the inspection team to deploy the necessary inspection team equipment for samples taking, sample preparation and analysis.
4.4 Draft Facility Agreement
For certain types of inspections, data to conclude a Facility Agreement will be collected by the IT with the assistance of representatives of the inspected State Party and the inspected facility. This document, once approved by the Executive Council, will govern the smooth execution of future inspections at the inspected facility.
4.5 Preliminary Factual Findings Report
A Preliminary Findings Report is compiled at the end of the inspection period which is co-signed by a representative of the inspected State Party acknowledging that notice was taken of the content of the report.
The following activities are performed during the post inspection period:
The following activities should be carried out prior to departure from the inspected facility and should be witnessed by representatives of the ISP:
5.2 Transport of the inspection team, personal luggage and equipment to the Point of Entry (POE)
Logistic assistance should be rendered for the IT and their personal luggage and equipment to the POE. In particular note should be taken of the amount of equipment to be transported and the departure timelines.
5.3 Customs and emigration procedures at the POE
A final inventory and checking of the inspection team and personal protective equipment seals can be performed at the POE. Assistance to the IT to facilitate a smooth and timely passage through customs and emigration on departure from the POE is always much appreciated.
Setting up a National Authority | Initial Declarations Under Article VI | Identification of Declarable Activities | Preparations for Inspections