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Preparatory Commission for the Organisation for the Prohibition of Chemical Weapons |
PC-VII/B/WP.2 4 May 1994 ENGLISH only |
Seventh Session
(27 June - 1 July 1994)
ISRAEL
WORKING PAPER
EQUIPMENT CONSIDERATIONS IN DEVELOPING CWC INSPECTION PROCEDURES
1. There are many issues to be taken into consideration when developing the standard procedures for inspections taken under the Chemical Weapons Convention (CWC). Among these issues are the approved types, methodology of use, and other considerations relating to the inspection team (IT) instrumentation. Related to the instrumentation issues are the sampling procedures of substances to be analysed on-site by the IT using the analytical instrumentation.
2. The CWC defines several types of inspections, starting with declared Schedule 1 chemicals producing plants, routine inspections of plants capable of making Schedule 2 and 3 chemicals, "other" chemical plants, challenge inspections, and "alleged use" investigations. The aims and circumstances of each type of inspection are different, therefore approved inspection procedures will have to be specified for each type. For instance, the aim of a declared Schedule 1 plant inspection will be to verify the allowed installed production capacity and production records, which will be based on material balance records rather than on chemical analytical detection methods. Routine chemical plant inspection will be devoted to verifying the activity declaration of the plant, by random sampling of feed materials and products. Challenge inspections will be more concerned with finding evidence of CWC prohibited activities.
3. Three basic common features in the instrumentation provided for each type of inspection will be:
(a) health and safety aspects;
(b) suitability for the inspection aim;
(c) information confidentiality aspects.
These aspects should be covered in the proposed inspection procedures.
4. Some of these have already been referred to by the various Expert Groups. For instance, section 5.5 of Appendix 1 to reference 1, dealing with "Health and Safety Principles During Inspections", specifies that "the use of any safety equipment shall be subject to agreement before the inspection begins. The agreement ... shall be subject to the need to meet site-specific safety and confidentiality considerations in accordance with the site safety rules and regulations. ... the inspected State Party will provide the health and safety equipment, ... provided that the equipment meets OPCW standards and Regulations, as applicable, ... at the end of an inspection, if the inspected State Party so requests, any piece of health and safety equipment involved in the inspection activities will be left on the site ... in order to prevent the disclosure of confidential information." Clearly, these are not the only issues of health and safety related to instrumentation that are needed to be included in the inspection procedures. Reference 2 lists the following industry concerns about the safety and legal requirements that have to be fulfilled before the IT may use any inspection equipment in a plant:
(a) demand for approval by an accredited safety organisation, such as Underwriters Laboratories (UL), that the equipment is safe for use in the plant environment, with recertification after use, repair or modification. This approval will enable the plant personnel to approve the use of this equipment during the inspection;
(b) concerns regarding possible interference from x-rays or radio frequency sources with the operation of level, nuclear and density gauges or communication equipment in the plant;
(c) certification of the IT equipment safety by the inspected State Party, to assume liability in case of accidents resulting from the use of the IT equipment in the plant.
If adopted, this means that the point of entry verification of the instruments brought by the inspection team, will have to be repeated at each inspected site.
5. The suitability of the IT instrumentation to the inspection aims is the subject of on-going discussions in the Expert Group on Equipment. A requirement for an agreed function specifications list was adopted, and preliminary inspection equipment specifications were prepared by the PTS (reference 3), but there is no mention of which equipment is to be used in what inspection type, and under what circumstances.
6. Especially important are the procedures for use of the portable analytical equipment, such as the proposed Gas/Chromotograph/Mass Spectrometer (GC/MS) based Intelligent Chemical Analysis Instrument (ICAI), described in reference 4. The operational procedures are related to the sampling procedures, which were also of concern to the chemical industry (reference 5), in particular, the technical and confidentiality issues involved in direct sampling at any point. In reference 4 an agreed upon preliminary screening of the site was suggested, using hand-held "military" type Chemical Agent Monitors or enzymatic biological test paper, to indicate the presence of suspected scheduled chemicals. If a positive response of the monitoring device is seen, a sample will be taken and subsequently analysed on-site by the ICAI. The automatic data-processing and interpretation capability of this instrument will provide the required yes/no assurance. Only if a scheduled chemical is detected by the ICAI will the detailed GC/MS spectra be available to the inspection team, for verification and recording. It should be noted that the hand-held "military" type monitors alone are unsuitable for inspection in chemical plants, because of their high rate of positive false alarms caused by common chemicals and air pollutants.
7. The Non Destructive Equipment IT instrumentation should be used only in ammunition storage sites, to assist in the task of munitions classification to the CW category. Although the storage sites environment is less restrictive than in chemical plants, the inspection procedures have to include all the basic requirements for health and safety and confidentiality.
8. The issues of inspection procedures in chemical industry facilities are complex, and when developing these procedures the experience from the National Trial Inspections should be considered. One comprehensive work summarising this experience is found in reference 6, and the recommendations of this book, especially the conclusions dealing with "Inspection methodology in chemical industry facilities" should be heeded.
References
1. Third Report, Expert Group on Safety Procedures, PC-VI/B/WP.10, 25 February 1994.
2. Implementing the Chemical Weapons Convention: Counsel from Industry. A. E. Smithson, ed., The Henry L. Stimson Center Report No. 10, January 1994, p. 9.
3. Draft Inspection Equipment Specifications. PTS Non-Paper prepared for the informal consultations of the Expert Group on Equipment, 24-25 March 1994.
4. Intelligent Chemical Analysis Instrument to be used by the OPCW. Non-Paper presented by the delegation of Israel to the informal consultations of the Expert Group on Equipment, 24-25 March 1994.
5. Reference 2, pp. 16-18.
6. R. Trapp, Verification under the Chemical Weapons Convention: On-Site Inspection in Chemical Industry Facilities, Oxford University Press, 1993.