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NOTE BY THE SECRETARIATPROVISION
OF UNIQUE CODES FOR SCHEDULE 2 AND 3 PLANT SITES
1. Introduction 1.1
As indicated by the Director-General in his opening statements to
the Executive Council at its Twenty-First and Twenty-Second Sessions
(respectively EC-XXI/DG.8*, dated 3 October 2000, and EC-XXII/DG.12,
dated 5 December 2000), the provision and appropriate
application of codes for Schedule 2 and 3 plant sites has been a
major concern for the OPCW Secretariat (hereinafter the "Secretariat"):
"the efficiency of declaration processing,
and inspection
planning in the Secretariat, depend heavily on the consistent use
of such unique plant site codes".1.2
While more than 70% of States Parties have assigned a unique code
to each of their declared plant sites, approximately 25% have not
yet done so. However, of those States Parties which did provide
the Secretariat with a unique code for each Schedule 2 or 3
plant site, 14% were subsequently inconsistent in their use of such
codes. To compound this problem, a further 18% of codes assigned
by some States Parties were identical with plant site codes assigned
by other States Parties (for example, 1- or 2-digit codes which
lacked any reference to a specific State Party).
2. Identifiers in current use 2.1
On the basis of paragraphs 6(a) and 6(b) of Part VII, paragraphs
6(a) and 6(b) of Part VIII, and paragraphs 4(a) and 4(b) of
Part IX of the Verification Annex, the following information is
available to assist the Secretariat in identifying a plant site:(a)
the name of the plant site; (b) the name
of the owner, company or enterprise operating it; and (c)
the precise location of the plant site, including its address.2.2
As the task of identifying a plant site by comparing all of the
above identifiers has proven to be both extremely time-consuming
and prone to error, the Secretariat has almost never been able to
arrive at a definite conclusion in such cases. Some examples
of scenarios with which the Secretariat has until now had to contend
are set out below: Example 1:
A plant site is sold. The new owner
changes the name of the plant site, and moves the main entrance
to a different side of the complex, which is consequently listed
under a different street address. When the plant site is declared,
with these new identifiers, in the State Partys subsequent
declaration, it is simply not possible for the Secretariat to
determine whether or not this plant site is identical to the one
which was previously declared.
Example 2:
Two plant sites are declared in subsequent
declarations: the plant sites bear the same name, have the same
owner, and are both located in the same street, but simply have
a different number in each case. Without further information the
Secretariat is not in a position to determine whether the location
of the main entrance has simply changed, or whether the two sites
are completely different.
Example 3:
Two plant sites are declared in subsequent
declarations with the same name, the same owner, and the same
street address, but the name of the city is different in each
case. It is impossible to determine with certainty whether this
is attributable to coincidence, to clerical error, or to the provision
of imprecise address details - a reference to the city as a whole
in one case, and to a specific suburb of the same city in the
other case.
2.3 In the majority of situations the identifiers
vary just slightly from one year to the next, but, as example 2 shows,
even minor differences can denote different plant sites. For this
reason alone, 32% of all declared plant sites have been susceptible
to identification discrepancies.2.4 Given the
critical importance assigned by the Convention to the correct identification
of declared Schedule 2 and 3 plant sites, the Secretariat is of the
view that any uncertainty in this regard is simply unacceptable. Where
the correct and appropriate implementation of the verification provisions
of the Convention is concerned, only hard facts, and not supposition,
can be allowed to count.
3. Recommendations
In order to resolve this situation, the
Secretariat recommends that the plant site coding system should in
future be uniformly implemented by all States Parties in accordance
with the following principles:
(a) a unique plant site code shall
be assigned to each plant site declared by each State Party;(b)
the plant site code shall be truly unique, i.e. the same plant
site shall always be referred to with the same unique code;(c)
the Secretariat shall identify a plant site solely on the basis
of its unique code. It follows from this that two declared plant
sites shall be considered as identical if they both have the same
unique code, even if all other identifiers (i.e. their names,
the names of their owners, the name of the company or enterprise
operating them, or their precise location, including the address)
are different;(d) once assigned, a unique
plant site code may not under any circumstances be transferred
to any other plant site, even if the original plant site has ceased
operations; and(e) plant site codes shall
be used consistently across all the Schedules of the Convention,
i.e. if the same plant site is declared in accordance with more
than one Schedule (for example pursuant to both Part VII and Part
VIII of the Verification Annex) the same plant site code shall
be used in all such declarations.
- Examples of plant site codes
For reasons of consistency the Secretariat
recommends the application of the following simple and transparent
method, which incorporates both a standard acronym for the name of
the State Party in question (in accordance with appendix 1 of
the Declaration Handbook 2000) and a four-digit numeral, with the
two being separated by a forward slash:
Example 1: HUN/0001
HUN/0002
HUN/0003
Example 2: IRL/0001
IRL0/002
IRL/0003
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