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The
JCIA, as a member of the International Council of Chemical Associations
(ICCA), has been active domestically and has made contributions, internationally,
towards the implementation of the industrial verification regime.
On-site
Inspections in Japan
Plant
Sites and Facilities Subject to Inspection
The number of companies participating in the Committee is 37. The total
number of facilities subject to inspection, including those of non-participants,
is:
Schedule 1 chemicals: none
Schedule 2 chemicals: 19 companies, 21 facilities
Schedule 3 chemicals: 24 companies, 35 facilities
DOC plant sites: 550 (est.)
Receiving
On-Site Inspections
– Initial Inspections of Schedule 2 Plant Sites
From November 1997 to June 2000, initial on-site inspections were carried
out at 21 Schedule 2 plant sites, thus completing the inspection of all
such sites which are subject to inspection.
– First Inspections of Schedule 3 Plant Sites
On-site inspections were conducted at five Schedule 3 plant sites in the
period October 1998 to June 2000.
– Inspections of DOC/PSF Plant Sites So far there have been no
on-site inspections of DOC/PSF plant sites.
Outline
of the JCIA’s Activities
Domestic
Activities
– Publication of the Inspection Receiving Manual
With governmental assistance and cooperation, the JCIA published the ‘Inspection
Receiving Manual’ for Schedule 2, Schedule 3, and DOC plant sites, with
a view to facilitating the smooth and efficient implementation of the
industrial verification regime, including on-site inspections, in compliance
with the CWC.
– CWC Awareness and Compliance
The JCIA disseminates information on the CWC to industry, and offers guidance
to individual companies on compliance with the industrial verification
regime. The JCIA, with governmental assistance, organises presentations
to assist relevant individual companies to comply with the industrial
verification regime, and to facilitate the widest possible dissemination
of information about the CWC.
– Measures for Preventing Abuse of Scheduled Chemicals
During 1995, a religious cult used sarin gas in a terrorist attack in
Japan. To prevent any repetition of such an occurrence, the JCIA produced,
in 1996, the ‘Guidelines on the control of the distribution, and prevention
of abuse of chemicals’, which were presented and distributed to industry.
– Research on Low Concentration Mixtures and Thresholds
The JCIA, with the assistance of the Japanese Ministry for International
Trade and Industry (MITI), investigated the production, processing, consumption
and transfer of low concentration mixtures of Schedule 2 and Schedule
3 chemicals, and proposed to MITI the declaration thresholds for low concentration
mixtures which were desirable for the industry.
– Exchange of Experience about On-Site Inspections
To facilitate the efficient discharge of obligations under the CWC, the
JCIA encourages members of the Committee to exchange their experiences
about on-site inspection of Schedule 2 and Schedule 3 plant sites.
The
industry is providing complete cooperation to inspectors, in their inspection
duties, to ensure the smooth implementation of the CWC.
International
Activities
– Cooperation with OPCW Exercises and Training The JCIA, in cooperation
with the Provisional Technical Secretariat (PTS) and the Government of
Japan during the preparatory phase, performed a desktop exercise for drafting
an actual agreement in accordance with the draft model facility agreement
on Schedule 2 chemicals prepared by the PTS. In March 1996, simulated
on-site inspections were performed at Schedule 2 and 3 plant sites. This
resulted in a multilateral agreement on the protection of secrecy, in-plant
operational security and safety, and the prevention of possible damage
caused by unwanted rumours, between the PTS, the Government of Japan,
and the chemical industry in Japan.
Furthermore, the JCIA in May 1997 received 28 OPCW candidate inspectors
at Schedule 2 and Schedule 3 plant sites, and afforded cooperation in
inspection training in general, including trial on-site inspections and
logistical matters.
–
CWC Industrial Verification Asian Seminar
For the purpose of reviewing and discussing the status of implementation
of the CWC and associated issues, the JCIA conducted the following CWC
industrial verification Asian seminars in cooperation with MITI, and the
Pre-paratory Commission and the OPCW respectively.
The
JCIA cooperated to the fullest possible extent with both the OPCW and
the Government of Japan.
The first seminar, in October 1996 in Makuhari, attracted about 100 participants,
including 29 from 17 Asian countries. The second seminar, in October 1998
in Tokyo, attracted about 80 participants, including 19 from 12 Asian
countries.
Furthermore, six States which had not ratified the CWC participated in
the second seminar, thus contributing significantly to the universality
of the CWC.
Contact
with Chemical Industry Associations of Member States
By maintaining close contact with chemical industry associations of Member
States such as CEFIC and the ACC, for example, the JCIA has, as a member
of the ICCA, submitted
to the OPCW its requests and opinions on various matters, including:
–
compliance with measures to protect the commercial secrets of companies,
a matter of great concern to industries associated with the implementation
of the CWC;
– the draft model facility agreement for Schedule 2 chemicals;
– the range of DOC, and the inspection of the plant sites in question;
– the establishment of low concentration thresholds for the declaration
and reporting of Schedule 2 and Schedule 3 chemicals;
and, – the selection procedure for, and the frequency of inspection of,
Schedule 2 and Schedule 3 plant sites which are subject to inspection.
To
ensure impartiality amongst States Parties it should be considered, for
instance, that no routine inspections should be able to commence before
initial inspections in all States Parties have been completed.
Regarding the declaration thresholds of low concentration mixtures for
the production of Schedule 2 and Schedule 3 chemicals and the method of
conducting on-site inspections for DOC/PSF plant sites—two issues which
are still pending—the JCIA is proceeding with the compilation of requests
and opinions, for submission to the OPCW, and is keeping in touch with
the chemical industry associations of the other Member States.
The
JCIA’s Opinions on the Issues: The Conduct of CWC Industrial Verification
Through meetings with officers of the OPCW and other forms of dialogue,
the JCIA has formulated a list of points which are matters of concern
to Japanese industry.
On-Site
Inspections
The industry is providing complete cooperation to inspectors, in their
inspection duties, to ensure the smooth implementation of the CWC.The
OPCW should, however, consider lightening the burden on the plant sites
in any way feasible—for example, by shortening inspection hours.
In the case of the inspection of a small-sized plant site, the number
of members of the team should be reduced to the minimum possible, bearing
in mind the limited number of personnel involved in the inspection, as
well as the limited availability of space.
Start
of Routine Inspections for Schedule 2 Plant Sites
To ensure impartiality amongst States Parties, and also amongst companies
subject to inspection, it should be considered, for instance, that no
routine inspections (second and subsequent inspections) should be able
to commence before initial inspections in all States Parties have been
completed.
Low
Concentration Thresholds for Schedule 2 and Schedule 3 Chemicals
The low concentration thresholds for the declaration of Schedule 2 and
Schedule 3 chemicals have been set at in excess of ‘30 percent’.This figure
is considered to be reasonable.
It is expected that the thresholds for the declaration of Schedule 2A
chemicals will also be promptly decided on, at a reasonable level, in
order to alleviate the burden on the chemical industry arising from the
implementation of the CWC.
Inspection
of DOC/PSF Production Facilities
Although there are many DOC/PSF production facilities in each State Party,
the risk which they pose for the CWC is considered to be very low. It
is expected that the method of inspection will be decided within a reasonable
time scale, through a careful investigation of the actual situation associated
with the inspections on Schedule 2 and Schedule 3 chemicals which are
currently being conducted, and that it will also reflect the actual situation
and the opinions of industry.
The specific opinions on the method of inspections for DOC/PSF production
facilities are as follows.
–
Inspection of Facilities
Although the type of inspection cannot be predicted, as the chemicals
and the facilities subject to inspection have not yet been specified,
it is expected to be simpler than for Schedule 2 and Schedule 3 plant
sites.
In our view, the inspection of DOC/PSF plant sites will take the form
of a general guided tour with a general explanation.
–
Disclosure of Records
The CWC stipulates that the inspection team may have access to records
in situations in which the inspection team and the inspected State Party
agree that such access will facilitate the fulfilment of the objectives
of the inspection. If records are actually disclosed, this will, as is
appropriate, be limited to the minimum necessary materials.
Conclusion
At the meeting held in September 1989 to discuss the destruction of chemical
weapons, Japanese industry promptly expressed its intention to support
the CWC, and—in cooperation with the Government of Japan—pushed for the
early implementation of the CWC. Furthermore, for the purpose of the smooth
and efficient implementation of the industrial verification regime, which
was a new ex-perience, the JCIA cooperated to the fullest possible extent
with both the OPCW and the Government of Japan, keeping in close contact
with the chemical industry associations of the other Member States.
The first inspections of DOC/PSF plant sites and the routine inspections
of Schedule 2 and Schedule 3 plant sites will commence shortly.
However, there are still some remaining issues such as low concentrations
for declarations and the frequency of inspections, which are of paramount
importance if the smooth and efficient implementation of the industrial
verification regime is to be accomplished. It is expected that a reasonable
solution will very soon be reached which will reflect the situation and
the views of industry.
| Mr
Makoto Sonai is the Executive Director of the Japan Chemical Industry
Association (JCIA), which he joined in July 1999.
Mr Sonai joined the Ministry of International Trade and Industry
in 1974 and has held a number of different positions since then.These
include tenure as Director of the Ceramics Division and of the Material
Research & Development Division, Deputy Director of the Department
of Commerce and Industry,Tokusima Prefecture, and Director of the
Coal Development Division. Mr Sonai has also served as Counselor
at the Embassy of Japan in Argentina.
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