Your company and inspections
under the Chemical Weapons
Convention
2011
This guide is intended for use by industrial facilities in the UK that are subject to initial and/or
routine verification activities under the Chemical Weapons Convention (CWC). The information
provided should assist schedule 2, 3 and unscheduled Discrete Organic Chemical facilities in
planning and preparing for an inspection of their declared facilities. It includes references to all
the phases of the inspection process, including planning, preparation, inspection, and postinspection procedures. A glossary of key terms is provided on pages 15/16.
The Department of Energy and Climate Change (DECC) is the Government Department with the
lead responsibility for all CWC inspections conducted in the UK. DECC’s objective is to
demonstrate the UK’s compliance with the CWC, by ensuring that all the requirements of an
inspection are met in an efficient and timely manner, whilst minimising the disruption to the
company’s day-to-day operations.
Further information and guidance can be provided by DECC on request. Contact details are
included at the back of this guide.
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Introduction
The Chemical Weapons Convention (CWC) is an international arms control treaty, administered
by the Organisation for the Prohibition of Chemical Weapons (OPCW) based in The Hague,
Netherlands. It introduced a verifiable ban on an entire class of weapons of mass destruction by
prohibiting the development, production, acquisition, stockpiling, transfer, and use of chemical
weapons. It also requires the destruction of existing chemical weapons stockpiles, and the
destruction or conversion of chemical weapons production plants and storage facilities.
One of the ways in which the CWC aims to achieve its objectives is by monitoring the peaceful
and legitimate use of dual-use industrial chemicals covered by the CWC, in order to prevent the
possibility of their diversion into weapons that can be designed to kill and maim. The CWC’s
provisions apply to most activities that involve toxic and non-toxic chemicals.
Each State Party has the right, subject to the provisions of the CWC, to develop, produce,
otherwise acquire, retain, transfer and use toxic chemicals and their precursors for purposes not
prohibited under the Convention (e.g. for industrial, agricultural, research, medical and
pharmaceutical uses).
The CWC entered into force in the UK on 29 April 1997, following intensive consultations with UK
industry. The UK CWC National Authority (UKNA), which is part of DECC, is responsible for the
implementation of the CWC throughout the UK, and in the UK’s Crown Dependencies and
Overseas Territories. DECC’s powers to do this are contained in the Chemical Weapons Act
1996, and translated the provisions of the CWC into UK law.
Who is inspected and why?
The UK, like all other CWC States Parties, is obliged to submit detailed declarations on particular
activities that involve certain chemicals, and these declarations are subject to verification by
OPCW inspectors. The OPCW undertakes a number of initial and routine inspections globally
every calendar year, and each industrial site making a declaration under the CWC is potentially
subject to such inspections.
The purpose of an OPCW inspection is to verify the accuracy of the information provided in the
declaration and to confirm that the activities carried out at the plant site are consistent with the
CWC. The toxic chemicals and their precursors that are monitored under the CWC are divided
into three schedules, roughly based on the degree of commercial use and also CW relevance, as
shown in the table overleaf.
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Schedule of Chemical
Risk to the CWC
Verification Threshold
Schedule 1
Chemicals that have been
developed, produced,
stockpiled and / or used as
chemical weapons and
have little or no use for
purposes not prohibited by
the CWC
Any declared production
facility is subject to regular
inspection.
Schedule 2 - divided into
subcategories of 2A, 2A* &
2B
Toxic chemicals and their
precursors that have limited
commercial use and are
capable of being used as
chemical weapons.
A declared plant site is
subject to inspection if one
or more plants produced,
processed or consumed in
any of the three previous
calendar years, or
anticipates producing,
processing, or consuming
in the next calendar year, in
excess of: 10 kilograms of
a 2A* chemical, 1 metric
ton of a 2A chemical or 10
metric tons of any 2B
chemical.
Schedule 3
Chemicals and their
precursors that have been
used as chemical weapons
but which are used in large
quantities for nonprohibited commercial
purposes.
A declared plant site is
subject to inspection if one
or more plants produced
during the previous
calendar year, or
anticipates producing in the
next calendar year, in
excess of 200 metric tons
aggregate of any Schedule
3 chemical.
Discrete Organic
Chemicals (DOC)
Unscheduled chemicals at
facilities that are subject to
inspection on the basis of
their production plant’s
capability to produce toxic
chemicals and precursors.
A declared plant site is
subject to inspection if it
produced by synthesis
during the previous
calendar year more than;
200 metric tons aggregate
of any DOC or 200 metric
tons of a DOC containing
the elements phosphorus,
sulfur or fluorine (PSF).
Note: Information on Schedule
1 chemicals is included for
sake of completeness.
However no UK industrial
facility produces such
chemicals in quantities which
require declaration or
inspection under the CWC.
4
When will companies be notified that they are being inspected?
Companies will be notified in advance by the UKNA that they have been selected for inspection
by the OPCW, with a minimum notice period of between one and five days. The UKNA will notify
companies by telephone as soon as it receives notification from the OPCW, and will then follow
up in writing immediately thereafter. The length of notice of an OPCW inspection varies and is
dependent on whether the inspection relates to a declaration of a Schedule 1, Schedule 2,
Schedule 3 or a DOC plant site, whether the site will be subject to OPCW Sampling and Analysis,
and also on the timing of notifications by the OPCW. Timeframes for OPCW inspection
notifications to the UKNA, as set out in the CWC, are below. However, in reality, the OPCW
provides the equivalent amount of working days notice:
5
Schedule of Chemical
Notification by the OPCW
Schedule 1
Not less than 24 hrs prior to arrival at the UK’s
point of entry (POE)
Schedule 2
Not less than 48 hrs prior to arrival at the plant
site to be inspected
Schedule 3
Not less than 120 hrs prior to arrival at the
plant site to be inspected
Discrete Organic Chemicals
(DOC)
Not less than 120 hrs prior to arrival at the
plant site to be inspected
How long does an inspection last?
There is no time limit on the duration of an inspection of a Schedule 1 facility. An inspection of a
Schedule 2 plant site may last for up to 96 hours, and inspections of Schedule 3 or DOC plant
sites may last up to 24 hours. In all cases, up to a further 24 hours is allowed at the end of the
inspection activities for report writing.
Once an inspection starts, activities can continue around the clock, although inspectors tend not
to work this way for routine inspections and usually adhere to the site’s normal working hours. An
inspection period may be extended by agreement.
How often will a site be inspected?
The frequency of inspections is determined by the OPCW using algorithmic selection systems.
These take into account the perceived risk that a particular plant site presents to the object and
purpose of the CWC by analysing its declaration data, and whether and when it was last
inspected. From the UK inspections received so far, it can be deduced that, on average,
Schedule 1 sites are inspected every 1-2 years and Schedule 2 sites every 2-3 years. Schedule
3 and DOC sites are subject to re-inspection but so many factors affect their selection by the
OPCW, mainly due to the vast numbers, globally, of declared sites still awaiting inspection, that it
is impossible to give an indication of frequency.
What is a challenge inspection?
In addition to initial and routine inspections, the CWC provides for the possibility of a challenge
inspection of any plant site in the UK, whether or not it has been declared. A challenge inspection
may be initiated by any State Party to the CWC in order to clarify any concerns it may have about
another’s compliance with the Convention. Only 12 hours’ notice will be given, and an inspection
may last up to 84 hours and involve up to 50 inspectors working around the clock at the site.
No State Party has yet received a challenge inspection. The UK, along with some other States
Parties, has arranged practice challenge inspections to ensure the OPCW’s preparedness for
such an event. However a challenge inspection will be an unusual event and it is not expected
that a UK facility will be subject to such an inspection.
Who are the inspectors?
The inspectors are full-time, qualified and trained members of the OPCW Technical Secretariat
who are nationals of countries that have ratified the CWC. Any inspector participating in an
OPCW inspection in the UK has been accepted by the UK Government for this purpose and are
bound by strict OPCW confidentiality rules relating to any information they have access to in the
course of the inspection.
The size of an inspection team (IT) may vary, and is determined by the OPCW, based upon its
assessment of the requirements of a particular inspection. For initial or routine inspections, an IT
6
will usually comprise of two to four inspectors or up to six for inspections which include Sampling
and Analysis.
What assistance is available from the UKNA?
The UKNA facilitates all inspections of plant sites in the UK. Its main objective is to ensure that,
when an inspection takes place, all the legitimate requirements of the IT are fully satisfied in an
efficient and timely manner. At the same time, the UKNA is also there to advise the company
about the requirements of the CWC and to assist it, as necessary, in answering the IT’s queries.
It also ensures that minimum disruption is caused to the normal activities of the company, that
confidential information is safeguarded, and that the IT actions are within the boundaries of the
Convention.
The UKNA makes preliminary visits to all declared Schedule 2 and 3 plant sites that can expect to
receive an inspection or have exceeded the declarable threshold. It guides the site management
and other company personnel through the declaration process, and inspection processes and
procedures, as well as their legal obligations. If necessary and on request, particularly for
Schedule 3 and DOC plants sites, this preliminary visit can be carried out after notification of, and
prior to, an inspection by the OPCW.
The UKNA will send a National Authority Escort Team (NAET) to escort and assist the IT
throughout the duration of the inspection. Usually, this will consist of two officials from DECC and
one technical advisor from the Defence Science and Technology Laboratory (Dstl) Porton Down.
The NAET will seek clarification on any matter, at any time, during the inspection, on behalf of the
plant site and help protect commercial confidentiality through the implementation, as necessary,
of managed-access procedures. It will also help to address any problems that may arise in the
course of an inspection.
As well as liaising with the company being inspected, the NAET works closely with a range of
agencies, including personnel at the UK’s designated points of entry (POE), the UK Border
Agency, the Police and the National Authority’s designated travel provider, to ensure that the
inspection runs as smoothly as possible.
What happens during an inspection?
Inspection activities include procedures at the POE, a pre-inspection briefing (PIB) at the plant
site, an initial site tour, the physical inspection of the declared plant(s) / plant site, verification of
the company’s declaration(s), which includes review of documentation on which the declaration is
based, and post-inspection procedures.
The NAET meets the IT at the designated POE and receives the inspection mandate which sets
out the key objectives of the inspection. The NAET subsequently conducts a number of
preliminary checks to confirm that the inspectors and their equipment are in accordance with the
inspection mandate. Although the mandate will vary for each Schedule/DOC, in most cases the
IT’s objectives are to verify:
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1. the consistency of the declaration data;
2. the absence of undeclared Schedule 1 chemicals, especially their production (except at
Schedule 1 facilities);
3. that scheduled chemicals are not being diverted.
The IT will also assess the risk the declared facility poses to the object and purpose of the CWC
(Schedule 1 and 2 plant sites only) and, for Schedule 2 plant sites, will begin the process of
negotiating a Facility Arrangement if one is required. Facility Arrangements for Schedule 1 plant
sites are mandatory and should be in place before site operations commence.
On arrival at the plant site, a company representative will need to provide the PIB, including any
necessary health and safety briefing. The IT will then set up their equipment and undertake an
initial tour of the site which, along with the PIB, will enable it to provide a written initial inspection
plan. The plan will indicate the areas that the IT wish to inspect and provisional timings for the
inspection. If Sampling and Analysis is to take place the plan will also indicate where samples
might be taken and the equipment that the IT proposes to use. On some inspections the IT may
decide to divide into two subgroups to undertake its work. An updated or revised inspection plan
may be provided as the inspection proceeds, but this is very rarely the case. During the
inspection, the IT will comply with all the site’s rules and regulations on health and safety. It will
have rights of access to areas of the site sufficient to enable it to undertake its activities and will
need to question site personnel about their duties as necessary. It will also have the right to
inspect relevant documents and records, and to have photographs and samples taken as
necessary. Unless agreed by the company, the IT will not operate any of the site’s equipment, but
can require particular operations to be performed by site personnel, such as sample taking and
stock taking.
After the physical inspection of the site, the IT will undertake a desk-based exercise to verify the
accuracy of the company’s declaration(s). This will involve a visual inspection of the data and
records used to complete the declaration(s). For Schedule 1 and 2 sites, the IT will verify the
declarations for the three previous calendar years, but can go back further with agreement. For
Schedule 3 and DOC sites the IT will verify the declaration for the previous calendar year only.
The IT will arrive with a copy of all the relevant declarations for their use during the inspection.
The NAET will also bring copies of the site’s relevant declarations that have been submitted to
the NAET and the OPCW.
Within 24 hours of completing the inspection activities, the IT will prepare a Preliminary Findings
Report (PFR). The PFR summarises the findings of the IT and the cooperation of the NAET and
the inspected site, it will only contain facts that are relevant to compliance with the CWC. The
report will be presented to the site personnel and the NAET to review and is usually agreed
before the IT leaves the site, though it is still a draft at this stage. If inaccuracies are found, the
NAET will discuss them with the IT, in cooperation with site personnel, and suggest modifications
to the report as appropriate. The IT will then complete the report and produce two copies, both of
which will be signed by the lead representatives of the IT and NAET. A copy of the signed report
will be provided to the site. The classification of the report will need to be agreed by the site in
order to assist the OPCW in ensuring that it is handled and stored at the OPCW headquarters in
accordance with the regulations governing confidential information.
8
Once the reporting activities have been concluded, the NAET will undertake a series of
procedural checks with the IT to ensure that it does not take any information or documentation
off-site, unless this has been agreed with the company. The IT will then be escorted off-site by
the NAET to return to The Hague.
What does a company need to do during an inspection?
To help facilitate and minimise the impact of a CWC inspection, the UKNA encourages all
declared facilities to prepare well in advance. It is advisable that the company appoints a liaison
officer to act as a focal point both during the preparations for, and during the inspection itself.
Although inspections take place relatively infrequently, sites should have a contingency plan so
that personnel involved are aware of what to expect and are prepared to help the IT fulfil its remit.
Good preparation can help to potentially reduce the length of the inspection since delays in
providing information to the IT is avoided. The most important steps to be taken in preparation for
an inspection are:
•
understand and verify the site’s declaration(s);
•
develop a comprehensive PIB;
•
ensure knowledgeable personnel are available for the site tour, inspection of the declared
plant(s), and records check;
•
identify any confidential business information and other critical information that is not
relevant to the inspection;
•
have available any electronic records used to complete the declaration(s) (SAP etc);
•
have available all the records used to complete the data declaration(s) (import and export
records, sales invoices etc);
•
have documentation available that shows the ownership of the site;
•
set aside separate office space for the IT and the NAET.
As soon as the IT arrives on site, a representative is required to provide the PIB. This is the first
official activity during an inspection and it is important in creating a positive and cooperative
atmosphere. A thorough and accurate PIB will help to ensure that company, plant site, and
plant(s) information is accurately reflected in the inspection report. It will also proactively
demonstrate the plant site’s compliance with the CWC, and help the IT to complete its tasks more
quickly.
A PIB should last no more than three hours, but one hour is usually sufficient. It should enable the
company to focus on the necessary site-specific issues including:
•
•
•
•
•
9
company and site history;
general site activities;
physical layout of the site, including a site plan;
declared areas;
basis of the site’s declaration;
•
•
•
•
•
•
inspection related declared/DOC chemicals, production location and annual quantities;
any other non-inspection related scheduled chemicals on site;
health and safety regulations;
administrative and logistic arrangements for the inspection;
availability of staff and documents;
any particular concerns about confidentiality
It is helpful at this stage to supply a copy of the briefing, a detailed map of the site, copies of any
health and safety regulations and any other relevant information that may be of help, such as
organisation charts and company brochures.
The OPCW inspection team will wish to set up their equipment (laptops, printers etc) shortly after
the PIB and before the site tour. The company should provide lockable office space equipped
with a telephone and, if possible, a fax machine and paper shredder for the inspectors for the
duration of the inspection. When the room is not in use (i.e. during physical inspection activities
and overnight) the IT will need to lock the door and apply a temporary security seal. If this room
needs to be accessed, for any reason (e.g. a fire or security issue), whilst the IT is not present, it
is important that a site representative (or security personnel) contacts the NAET as soon as
possible. The IT can then return to the site immediately to ensure its equipment and the site’s
information has not been compromised. It is also helpful if the NAET can be provided with a
separate work room.
Experienced site personnel should provide a guided tour of the site after the PIB and answer the
IT’s questions which will help it formulate the inspection plan. The site will also need to ensure
that its own staff accompany the IT during the actual inspection. Ideally, these should be people
who are knowledgeable about the areas to be visited. The company should also be prepared to
provide timely access - subject to confidentiality concerns - to any areas (and to the staff working
in these areas) which the IT asks to visit in order to fulfil its remit.
As the duration of an inspection can last between 24 and 96 hours, depending on the type of
Schedule/DOC inspected, the more time the IT are on site the quicker the process can be
completed and the burden reduced. The site is requested, therefore, to provide, if possible,
lunches for the IT and NAET for the duration of the inspection. If this is not possible then the
NAET will make alternative arrangements.
More specific preparatory guidance for Schedule 2, Schedule 3 and DOC sites can be found in
Annexes A–C at the back of this guide.
What is Sampling and Analysis?
Sampling and Analysis is an OPCW verification tool that permits an IT to verify the absence of
undeclared scheduled chemicals. To date, it has only taken place at Schedule 2 sites; although it
will not occur during an initial inspection, it may be used during a subsequent routine inspection.
If Sampling and Analysis is to take place then the UKNA will liaise with the OPCW once it has
been notified of the inspection to ensure that the equipment to be used is shipped directly to and
from the inspected site. After the equipment has been checked by the NAET, the IT will explain
how equipment will be used and, in agreement with the site and the NAET, indicate where
10
samples may be taken. Any samples required by the IT will be taken by site personnel, advised
as necessary by the NAET.
Analysis will be performed on site if facilities exist or off-site if they do not. In extremis, if a UK offsite alternative cannot be found, samples may be removed from the site for analysis at
laboratories designated by the OPCW as agreed by the NAET.
In order for an IT to use its approved equipment to conduct on-site analysis, it requires sufficient
bench space of approximately 3 metres in length that is equipped with an electrical power supply
and running water.
How will confidential information be protected?
The CWC, and internal OPCW policy, stipulates that only information that is strictly necessary for
the conduct of the inspection should be sought by the IT, and that access within the OPCW to
commercially sensitive information is allowed solely on a need-to-know basis.
The Chemical Weapons Act 1996 makes the unauthorised disclosure in the UK of information
obtained under the Act – with exceptions in certain clearly-defined circumstances – a criminal
offence. Companies have the right to take measures to protect commercially confidential
information and data of no relevance to the CWC. They may do so by means of managed access.
The NAET will work with the inspected site to ensure any confidentiality requirements/concerns
are met, whilst still enabling the IT to fulfil its objectives.
How can access to confidential information be managed?
Access may be managed in a number of ways, including:
•
removing sensitive and unrelated papers from offices;
•
shrouding unrelated displays, stores and equipment;
•
shrouding sensitive pieces of equipment, such as computer or electronic systems;
•
limiting the number of inspectors given access to particularly sensitive areas of the site;
•
logging off computer systems and turning off data indicating devices;
•
using the “Random Selective Access” technique. (Under this, the IT may, for example, be
allowed to choose a particular building for inspection, or identify for review a certain filing
cabinet or a selection of documents that may be edited to safeguard confidential information
unrelated to the inspection).
It is however important that these mechanisms are used sparingly and only where they are strictly
necessary to protect commercially confidential information. Their use on a routine basis will cause
suspicions that the site may not be in compliance with the CWC. Moreover, the use of managed
access procedures does not absolve the company from the requirement to demonstrate that the
activities carried out on its site are fully compliant with the CWC
11
What is a Facility Arrangement?
A Facility Arrangement contains information that is specific to the inspected site. Its aim is to
establish the conduct of future routine inspections by setting out the various responsibilities of the
IT, as well as the company and the site being inspected.
Facility Arrangements are required for Schedule 1 sites and according to the Convention, must be
concluded before operations commence. They are recommended for Schedule 2 sites and the IT
will discuss with the NAET and the site during the initial inspection whether one is deemed
necessary. A Schedule 3 or a DOC/PSF site may request a Facility Arrangement, but they are
not required for these sites.
The contents of the Arrangement will include, but is not limited to;
•
•
•
•
•
•
the timing, frequency and duration of inspections;
health and safety requirements;
arrangements related to the protection of confidential information;
sampling and analysis;
limitations on the use of inspection equipment;
administrative arrangements.
In the case of Schedule 2 (and potentially Schedule 3) sites, the IT will collect the relevant
information during the initial inspection and the NAET will work with company personnel and the
IT to develop a draft Facility Arrangement, if one is required. The UKNA will then negotiate the
final Facility Arrangement with the OPCW and these discussions will take place in The Hague.
The company has the right to participate in the negotiations to the maximum extent practicable,
will be notified of any substantial changes and will be able to comment prior to the Facility
Arrangement being approved. A copy of the final Facility Arrangement will be given to the site on
its completion.
What happens at the end of an inspection?
Once the IT has completed its inspection and reporting activities and returned to The Hague, the
IT leader will debrief his or her supervisors on the findings. At this time, the IT leader may then
modify the report to reflect these discussions. The report will then be finalised and forwarded to
the UKNA for comments within two weeks, at which stage a copy will be provided to the site for
comment.
There is no “pass or fail” marking for an inspection. The final report, incorporating any
observations, will be passed to the Director-General of the OPCW within 30 days of the end of
the inspection. The report will draw attention to any ambiguities that could not be resolved during
the inspection and the degree of cooperation received by the IT from the inspected site.
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Further information
For further information about any aspect of the Chemical Weapons Convention please contact:
UK CWC National Authority
Department of Energy & Climate Change
Room G.01
3 Whitehall Place
London
SW1A 2AW
Tel: 0300 068 5939 / 5925 / 5941 / 5927
Fax: 0300 068 6772
Website:
http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/nuclear/nonprolif/che
mical_bio/chemical_bio.aspx
A list of CWC scheduled chemicals can be found on the OPCW website:
www.opcw.org/chemical-weapons-convention/annex-on-chemicals/b-schedules-of-chemicals/
The OPCW’s homepage can be found at:
www.opcw.org
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Glossary of Terms
Chemical Weapons Convention (CWC) — The convention on the prohibition of the
development, production, stockpiling and use of chemical weapons and their destruction.
CWC UK National Authority (UKNA) – Located within DECC and responsible for
implementation of the CWC and the CW Act in the UK, Crown Dependencies and the Overseas
Territories.
Chemical Weapons Act 1996 — The UK’s national legislation which translates the provisions of
the CWC into UK law.
Facility — Any plant, plant site or unit.
Facility Arrangement — A written arrangement between a State Party to the CWC and the
OPCW relating to a specific facility that is subject to on-site verification pursuant to the
Convention. This arrangement defines the terms and procedures to be used during future routine
inspections of the facility. A Facility Arrangement is required for Schedule 1 sites before
operations commence and are generally required to be negotiated during initial Schedule 2
inspections.
Initial Inspection — The first inspection of a Schedule 1 or Schedule 2 declared facility or plant
site.
Inspector — An individual designated by the OPCW to carry out an inspection in accordance
with the CWC.
Inspection Mandate — The instructions issued by the Director General of the OPCW to the
inspection team for the conduct of a particular inspection.
Inspection Team (IT) — The group of international inspectors from the OPCW sent to conduct
an inspection.
National Authority Escort Team (NAET) — Officials from the UK CWC National Authority and
Dstl who accompany and assist the inspectors throughout the duration of an inspection.
Organisation for the Prohibition of Chemical Weapons (OPCW) — The international
organisation, located in The Hague, Netherlands, that administers the CWC.
Plant — (a production facility or workshop) A relatively self-contained area, structure or building
containing one or more units with auxiliary and associated infrastructure, such as:
•
•
•
•
•
14
small administrative area;
storage/handling areas for feedstock and products;
effluent/waste handling/treatment area;
control/analytical laboratory;
first aid service/related medical section;
•
records associated with the movement into, around, and from the site, of declared
chemicals and their feedstock or product chemicals formed from them, as appropriate.
Plant site — (a works or factory) The integration of one or more plants, with any intermediate
administrative levels, which are under one operational control, and includes common
infrastructure, such as:
•
•
•
•
•
•
•
•
administration and other offices;
repair and maintenance area;
medical room;
utilities;
analytical laboratory;
research and development laboratories;
effluent and waste treatment area;
warehouse storage.
Pre-Inspection Briefing (PIB) — A presentation given by a company representative to the IT,
providing an overview of the company, declared activities and the declared plant(s) / plant site
prior to the start of the inspection.
Point of Entry / Exit (POE) — The airport or port which has been officially designated for the incountry arrival and departure of OPCW inspection teams.
Routine Inspection — At Schedule 1 and Schedule 2 facilities, this term refers to all inspections
conducted after the initial inspection. For declared Schedule 3 and DOC plant sites, this term
refers to all inspections conducted.
State Party — A country that has signed and ratified or acceded to the CWC.
Unit — A unit (production or process) is the combination of items and equipment, including
vessels, necessary for the production, processing or consumption of a chemical.
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Inspection Preparation Advice for Schedule 2 Declarers
This brief document outlines the most commonly requested information pertaining to inspections
by OPCW inspectors. Therefore, it is advised that access arrangements are made for the relevant
areas and the following documentation and information is readily available.
Documents – Pre Inspection Briefing
•
Copies of presentations given during the briefing;
•
Site maps/diagrams showing the site perimeter and declared facilities;
•
Organisation charts, showing the role of the key individuals introduced to the team and with
whom the team is likely to come into contact;
•
List of plants, including those declared, with the approximate annual production range of
each plant;
•
Readily available PR material such as site brochures, catalogues, advertising material and
website information;
•
List of products produced on site;
•
List of any undeclared Schedule 1, 3 or DOC/PSF chemicals held on site;
•
Site health and safety policy;
•
A list of COSHH assessments relating to the handling of toxic chemicals, especially highly
toxic chemicals, if numbers make this practical.
Documents – Inspection
•
Records, with supporting documentation, explaining the basis of the declaration;
•
Schedule 2 production, processing and/or consumption records for the last three calendar
years, to date, from which the declarations were derived for each plant, possibly broken
down by monthly, weekly or batch figures;
•
Relevant Schedule 2 sales records, sales invoices, credit notes.
•
Schedule 2 import and/or export records for the last three calendar years, to date, from
which the declarations were derived;
16
•
Basic process flow information, including block flow diagrams and P and I diagrams;
•
Standard operating procedures;
•
Raw material (particularly any Schedule 2 chemicals) purchase/utilisation records for the
last calendar year;
•
Product dispatch records for the last calendar year;
•
Downtime/maintenance records for the last calendar year;
•
Material safety data sheets;
•
COSHH assessments;
•
Product Group Codes will be assessed from product literature - site brochures, catalogues,
advertising material and website information;
•
List of products produced off-site using the declared Schedule 2 chemicals;
•
List of chemicals held on site;
•
Waste effluent records - in particular disposal of Schedule 2 effluent (Environmental
Licences etc);
•
Official documentation proving site address (council tax bill, telephone bill etc).
Access – Inspection
•
Declared production plants;
•
Product filling areas;
•
QC lab - any special safety features, detectors, filtration etc. Consistency of instrumentation
with stated requirements;
•
R&D facility - any special safety features, detectors, filtration etc;
•
Warehouses & workshops – any special safety features, detectors, filtration etc;
•
Waste water treatment facilities;
•
Emergency facilities and any on-site first aiders - qualifications of staff, equipment and
medicines available.
17
Information – Inspection
•
Declared production plants:
-
Materials of construction;
Temperature and pressure ranges of operation;
Single or multi-purpose configuration;
Batch or continuous process;
Control rooms, manual or computer control;
Vapour filtration systems;
Safety equipment available;
Any vapour detectors;
High security fencing etc;
Waste treatment.
•
Number of stainless steel, glass lined reactors/vessels (plant specific);
•
Processing methods e.g. crystallisation/distillation;
•
Extraction/ventilation filters in laboratories and plants;
•
Name and address of nearest hospital to site.
18
Inspection Preparation Advice for Schedule 3 Declarers
This brief document outlines the most commonly requested information pertaining to inspections
by OPCW inspectors. Therefore, it is advised that access arrangements are made for the relevant
areas and the following documentation and information is readily available.
Documents – Briefing
•
Copies of presentations given during the briefing;
•
Site maps/diagrams showing the site perimeter and declared facilities;
•
Organisation charts, showing the role of the key individuals introduced to the team and with
whom the team is likely to come into contact;
•
List of plants, including those declared, with the approximate annual production range of
each plant;
•
Readily available PR material such as site brochures, catalogues, advertising material and
website information;
•
List of products produced on site;
•
List of any undeclared Schedule 1, 2 or DOC/PSF chemicals held on site;
•
Site health and safety policy;
•
A list of COSHH assessments relating to the handling of toxic chemicals, especially highly
toxic chemicals, if numbers make this practical.
Documents – Inspection
•
Records, with supporting documentation, explaining the basis of the declaration;
•
Schedule 3 production records for the last calendar year from which the declaration was
derived for each plant, possibly broken down by monthly, weekly or batch figures;
•
Relevant Schedule 3 sales records, sales invoices, credit notes;
•
Schedule 3 import and/or export records for the previous calendar year, to date, from which
the declaration was derived;
•
Basic process flow information, including block flow diagrams and P and I diagrams;
•
Standard operating procedures;
19
•
Raw material (particularly any Schedule 3 chemicals) purchase/utilisation records for the
last calendar year;
•
Product dispatch records for the last calendar year;
•
Downtime/maintenance records for the last calendar year;
•
Material safety data sheets;
•
COSHH assessments;
•
Product Group Codes will be assessed from product literature - site brochures, catalogues,
advertising material and website information;
•
List of products produced off-site using the declared Schedule 3 chemicals;
•
List of chemicals held on site;
•
Waste effluent records - in particular, disposal of Schedule 3 effluent (Environmental
Licences etc);
•
Official documentation proving site address (council tax bill, telephone bill etc).
Access – Inspection
•
Declared production plants;
•
Product filling areas;
•
QC lab - any special safety features, detectors, filtration etc. Consistency of instrumentation
with stated requirements;
•
R&D facility - any special safety features, detectors, filtration etc;
•
Warehouses & workshops – any special safety features, detectors, filtration etc;
•
Waste water treatment facilities;
•
Emergency facilities and any on-site first aiders - qualifications of staff, equipment and
medicines available.
20
Information – Inspection
•
Declared production plants:
-
Materials of construction;
Temperature and pressure ranges of operation;
Single or multi-purpose configuration;
Batch or continuous process;
Control rooms, manual or computer control;
Vapour filtration systems;
Safety equipment available;
Any vapour detectors;
High security fencing etc;
Waste treatment.
•
Number of stainless steel, glass lined reactors/vessels (plant specific);
•
Processing methods e.g. crystallisation/distillation;
•
Extraction/ventilation filters in laboratories and plants;
•
Name and address of nearest hospital to site.
21
Inspection Preparation Advice for DOC/PSF Declarers
This brief document outlines the most commonly requested information pertaining to inspections
by OPCW inspectors. Therefore, it is advised that access arrangements are made for the relevant
areas and the following documentation and information is readily available.
Documents – Briefing
•
Copies of presentations given during the briefing;
•
Site maps/diagrams showing the site perimeter and declared facilities;
•
Organisation charts, showing the role of the key individuals introduced to the team and with
whom the team is likely to come into contact;
•
List of plants, including those DOC/PSFs declared, with the approximate annual production
range of each plant;
•
Readily available PR material such as site brochures, catalogues, advertising material and
website information;
•
List of products produced on site;
•
List of any undeclared Schedule 1, 2 or 3 chemicals held on site;
•
Site health and safety policy;
•
A list of COSHH assessments relating to the handling of toxic chemicals, especially highly
toxic chemicals, if numbers make this practical.
Documents – Inspection
•
DOC/PSF production records for the last calendar year from which the declaration was
derived for each plant, possibly broken down by monthly, weekly or batch figures;
•
Basic process flow information, including block flow diagrams and P and I diagrams);
•
Standard operating procedures;
•
Raw material (particularly any PSF chemicals) purchase/utilisation records for the last
calendar year;
22
•
Product dispatch records for the last calendar year;
•
Downtime/maintenance records for the last calendar year;
•
Material safety data sheets;
•
COSHH assessments;
•
Product Group Codes will be assessed from product literature - site brochures, catalogues,
advertising material and website information;
•
List of products produced off-site using the declared DOC/PSFs;
•
List of chemicals held on site;
•
Waste effluent records - in particular, disposal method of effluent (Environmental Licences
etc);;
•
Official documentation proving site address (council tax bill, telephone bill etc).
Access – Inspection
•
Declared production plants;
•
QC lab - any special safety features, detectors, filtration etc. Consistency of instrumentation
with stated requirements;
•
R&D facility - any special safety features, detectors, filtration etc;
•
Warehouses & workshops – any special safety features, detectors, filtration etc;
•
Waste water treatment facilities;
•
Emergency facilities and any on-site first aiders - qualifications of staff, equipment and
medicines available.
Information – Inspection
•
Declared production plants:
23
Materials of construction;
Temperature and pressure ranges of operation;
Single or multi-purpose configuration;
Batch or continuous process;
Control rooms, manual or computer control;
Vapour filtration systems;
-
Safety equipment available;
Any vapour detectors;
High security fencing etc;
Waste treatment.
•
Number of stainless steel, glass lined reactors/vessels (plant specific);
•
Processing methods e.g. crystallisation/distillation;
•
Extraction/ventilation filters in laboratories and plants;
•
Name and address of nearest hospital to site.
24
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Department of Energy & Climate Change
3 Whitehall Place
London SW1A 2HD
www.decc.gov.uk
URN 11D/0014