Chemical Weapons Convention Implementation Paper 11

Declarable activities under Schedules 2 and 3
from the point of view of a facility operator

I. Introduction

National implementation of the Chemical Weapons Convention (CWC) requiresthe setting-up of a National Authority in each country which is a partyto the Convention. In addition, each State Party has an obligation to reporton the industrial activities addressed in Article VI of the CWC, and eachState Party is required to submit declarations on all relevant militaryand civilian chemical facilities in the first 30 days after entry into force(EIF) of the Convention.

The military facilities in question will normally be under the control orsupervision of the respective governmental authorities and thus should presentfew problems as regards meeting the reporting requirement. The chemicalindustry will be affected mainly by the need to declare activities underArticle VI (i.e., those activities which are related to the production ofSchedule 2 and 3 chemicals and unscheduled discrete organic chemicals -including those containing the elements phosphorus, sulphur or fluorine(PSF) - above declaration thresholds). The detailed declaration requirementsare contained in the Verification Annex to the CWC in parts VII, VIII andIX. There is common understanding that these declarations are 'industrialdeclarations'. (This paper does not deal with the declaration requirementsfor Schedule 1 chemicals and the facilities producing such chemicals.)

This paper focuses on implementing declaration requirements on the nationallevel, taking into account the fact that the individual facility operatoris the legal entity which must submit the requested data to the NationalAuthority, so that the State Party can make the declarations required underthe CWC.

The Provisional Technical Secretariat is in the process of developing aDeclaration Handbook to serve as a basis for the States Parties to prepareand submit their complete declarations. However, it is already clear thatthe requirements of the Handbook will need to be `translated' into workableforms which focus on the needs and requirements of the individual facilityoperator. This will be the task of the National Authority, and it is onewhich must be accomplished with the actual situation of the chemical industrykept in mind. Understanding the basic declaration obligations and the timetablefor submitting the required declarations to the OPCW (Organisation for theProhibition of Chemical Weapons) is essential in order to make the workof the Technical Secretariat (TS) efficient and to ease compliance amongStates Parties to the CWC. However, it is entirely up to the National Authority,as outlined under Article VII, to organize the data acquisition from industryin the way it assumes to be the most effective. The only precondition isthat, the National Authority must ensure that declaration data is providedin sufficient time so that the State Party is able to submit aggregate nationaldata and to validate potentially questionable data. This will perhaps notalways be an easy task.

Table 1. Declaration requirements and deadlines of declarations

Schedule 2 Schedule 3 DOC and PSF

Initial declaration Aggregate national data Aggregate nationaldata EIF(SP) + 30 days EIF(SP) + 30 days Declarations for plant sites Declarations for plant sites Declarations forplant sites EIF(SP) + 30 days EIF(SP) + 30 days EIF(SP) + 30 daysAnnual declarations Aggregate national data Aggregate national data (pastactivities) Year end + 90 days Year end + 90 daysDeclarations for plant sites Declarations for plant sites Annual updateYear end + 90 days Year end + 90 days Year end + 90 daysAnnual declarations Declarations for plant sites Declarations for plantsites (anticipatory activities) Beginning of year - 60 days Beginning ofyear - 60 daysAdditionally planned Change after annual Change after annual activitiesanticipatory declarations anticipatory declarations Change - 5 days Change- 5 days Declarations on past production of scheduled chemicals for CW Declarationsfor plant sites Declarations for plant sites purposes EIF(SP) + 30 daysEIF(SP) + 30 days

II. Declaration requirements

Parts VII, VIII and IX of the Verification Annex provide guidance forthe preparation of 'industrial declarations'. The complexity of the declarationrequirements is illustrated by the fact that under Schedule 2 informationhas to be given on production, possessing, consumption,import and export while under Schedule 3 data are requiredonly on production, import and export. For the discreteorganic chemicals (DOC), only data on productionneed be submitted. The declarations are 'triggered' by the relevant thresholds,which differ in respect to the annual declaration and possible routine verificationactivities. Table 1 shows the declarations required with respect to initial,annual and planned activities.

As mentioned above, the thresholds trigger the declaration of activitiesto the OPCW. They are also the 'triggers' for subsequent routine verificationactivities by the Organisation. Table 2 summarizes the various thresholdsfor the schedules.

Examination of the timetable for the declarations makes it clear that theNational Authority must ensure that declarations from industry will needto be obtained far in advance of the CWC deadline so that aggregate nationaldata can be developed and possible errors checked and corrected.

Table 2. Thresholds for declaration and verification for plant sites

Declaration VerificationSchedule 2A* 1 kilogram 10 kilogramSchedule 2A 100 kilograms 1 tonneSchedule 2B 1 tonne 10 tonnesSchedule 3 30 tonnes 200 tonnesUnscheduled DOCs 200 tonnes 200 tonnesDOCs containing PSF 30 tonnes 200 tonnes

The following declarations must be submitted by a State Party to the OPCW(they are based on the Declaration Handbook):

Schedule 2 declarations

Aggregate national data on Schedule 2 chemicals:

Primary declaration identification

Declaration per chemical

Specifications of import of the Schedule 2 chemical by country


Specifications of export of the Schedule 2 chemical by country

Information on declared Schedule 2 plant sites

Primary declaration identification

Schedule 2 plant site information

Schedule 2 plants at plant site

Production capacity per chemical

Schedule 2 chemicals at plant site

Schedule 2 chemicals sold or transferred off the plant site

Anticipated time periods for the production, processing or consumption of Schedule 2 chemicals

Initial declaration of Schedule 2 chemicals produced at the plant sites since 1 January 1946 for CW purposes

Production periods for Schedule 2 chemicals produced for CW purposes since 1 January 1946


Locations to which each Schedule 2 chemical produced for CW purposes has been delivered

Schedule 3 declarations

Aggregate national data on Schedule 3 chemicals:

Primary declaration identification

Declaration per chemical

Specifications of import of the Schedule 3 chemical by country


Specifications of export of the Schedule 3 chemical by country

Information on declared Schedule 3 plant sites

Primary declaration identification

Schedule 3 plant site information

Schedule 3 plants at plant site

Schedule 3 chemicals at plant site

Initial declaration of Schedule 3 chemicals produced at the plant sites since 1 January 1946 for CW purposes

Production periods for Schedule 3 chemicals produced for CW purposes since 1 January 1946


Locations to which each Schedule 3 chemical produced for CW purposes has been delivered

Other chemical declarations concerning DOC

Primary declaration identification

Plant sites producing unscheduled discrete organic chemicals


Plant sites producing unscheduled discrete organic chemicals containing the elements phosphorus, sulphur or fluorine

In reviewing the above declaration requirements it is obvious that thereare two groups: (a) annual declarations (on past and anticipatedactivities) and declarations regarding changes in anticipated activities;and (b) initial declarations 30 days after EIF and declarations onpast activities also 30 days after EIF. Table 3 presents a timetable forsubmission of declarable data to the OPCW by a State Party.

III. Obligations for a facility operator

The declaration forms developed by the PTS present the basic formatsfor transmission of the declarable activities from the National Authorityto the Technical Secretariat (TS). The National Authority is tasked withdeveloping a system to obtain the necessary information from industry inorder to fulfil its declaration requirement to the TS. It will be necessaryto start well before anticipated entry into force to collect the requireddata from industry. In order to do so, the affected companies need to receiveinformation about what is expected of them. A facility operator will needinformation which is as precise as possible about the data which must besubmitted to the National Authority and the deadlines which must be met.The National Authority should perhaps use a twofold strategy in its dealingwith individual companies.

If a company is identified as being involved in declarable activities, regularreporting (after submission of the initial declaration) on annual (pastand anticipated) activities needs to be developed. This could be seen asa 'regular' declaration activity.

Any planned changes in activities or planned additional activities whichmust be declared, need to be declared to the National Authority. When newactivities which have to be declared are planned, declaration of this mustbe made to the National Authority. From an administrative point of view,this is likely to be one of the most complicated matters with which to cope.Both cases could be categorized as 'unusual' declaration activities. Thereare two possible ways to cope with such 'unusual' declaration activities:(a) the previously submitted declaration could be amended or a totallynew declaration could be submitted, or (b) the facility operatorcould request a licence for new production of a certain chemical. UnderSwiss legislation, for example, companies are required to submit a licencerequest for new production of chemicals on Schedule 1, and Schedule 2A andB. However, it is up to the National Authority to ensure that companiesare well informed about their duties with respect to all declaration obligations.

Table 3. Timetable for submitting the declarations

Subject to declaration Declaration form Declaration deadlineSchedule 2 chemicals and facilitiesAggregate national data Initial declaration EIF + 30 daysAnnual declaration on past year's Year end + 90 days activities Declarations on plant sites Initial declarations EIF + 30 daysAnnual declarations on past year's Year end + 90 days activities Annual declarations on anticipated Beginning of the year activities less60 daysAdditionally planned activities Change less 5 days and changesDeclarations on past production of EIF + 30 days Schedule 2 chemicals forCW purposes Schedule 3 chemicals and facilities Aggregate national data Initial declaration EIF + 30 daysAnnual declaration on past activities Year end + 90 daysDeclarations on plant sites Initial declarations EIF + 30 daysAnnual declarations on past year's Year end + 90 days activities Annual declarations on anticipated Beginning of the year activities less60 daysAdditionally planned activities and Change less 5 days changes Declarations on past production of EIF + 30 days Schedule 3 chemicals forCW purposesOther chemical production facilities Initial declarations EIF + 30 daysAnnual updates with respect to past Year end + 90 days (last years) activities

The question now is: How will industry cope with its declaration requirements?It might be rather naive to assume that on being obliged to submit declarationsa company would cease to conduct activities (production, consumption, processing,importing or exporting) with controlled chemicals under the schedules. Themarket is the only decisive factor which will affect a decision on suchactivities. If business can be successfully conducted, reporting obligationswill not serve as an obstacle.

What impact will these reporting requirements have on industry? The casesin which reporting on chemicals to the National Authority is essential canbe categorized as follows (in the following evaluation the declaration obligationfor plant sites and plants is not discussed because such declaration activitieswill occur automatically if a certain scheduled chemical is produced, consumed,possessed, etc.):

1. The company is currently producing, processing, consuming, importing or exporting any of the Schedule 2 chemicals.

2. The company is currently producing, importing or exporting any of the Schedule 3 chemicals.

3.The company is currently producing any chemical covered under the definition of DOC.

4. The company is planning to start new activities covered under points 1, 2, and 3.


5. The company is planning to change a previously submitted declaration with respect to activities under points 1 and 2.

The reporting requirements must always be seen in connection with thresholdlevels (see table 2). However, as noted above, the national implementationexperience of some countries is that it might be advisable not to restrictreporting to the National Authority to CWC threshold levels only. In Sweden,for example, companies are required to declare to the National AuthorityDOC, including PSF, chemicals at threshold levels which are 10 times lowerthen those specified in the CWC. There are no thresholds for Schedule 2and 3 chemicals regarding to the declaration obligations.

Countries are required to submit national aggregate data on chemicals. Ifseveral companies have activities which are under the threshold levels,when these values are added the national aggregate number might be abovethe threshold. In addition, companies might alter their quantitative declarationsduring the year, so that the aggregate number would then exceed the threshold.

The National Authority ought to work continuously with companies for whichreporting is required. Close co-operation is needed with industry duringimplementation preparation and also on the national level to introduce lowerthreshold reporting limits than those outlined in the CWC.

Information required from a facility operator

What is the minimum amount of information that must be supplied by the facilityoperator to the National Authority? Here, it must be noted that the Nationalauthority is required to submit data using the declaration forms in theDeclaration Handbook. This information is to form the basis for the developmentof the questionnaire to be submitted by the National Authority to the individualfacility operators.

For Schedule 2 chemicals the following information might constitutea basic set of data sufficient for the National Authority to prepare thenational aggregate data:

(a) general information: item number on Schedule 2, chemical name,CAS registry number, common/trade name and structural formula;

(b) quantitative data: quantity produced (including information onpercentage concentration regarding raw material and product), quantity processed(including information on percentage concentration regarding raw materialand product) and quantity consumed, imported, exported, retained stored,sold or transferred;

(c) information on import/export: supplier and recipient countries;

(d) information on quantities sold or transferred (including informationon destination and final product for which the chemical has been used);and

(e) information on instances where the chemical produced is usedfor other purposes than processing, consumption and shipment to anotherdestination.

For Schedule 2 plant sites the following information might constitutea basic set of data:

(a) logistics information: name and address of the facility (includingbuilding number or address, structure and postal code) and name of boththe owner and operator of the facility; and

(b) activity information: main activities of the facility, whichscheduled chemicals are produced there and their production capacity, andinformation on the type of plant (dedicated or multipurpose).

For Schedule 2 chemical declarations it must be kept in mind that a StateParty has to submit to the OPCW national aggregate number on every chemicaltaking the thresholds under Schedule 2 into account (Schedule 2A* - 1 kilogram,Schedule 2A - 100 kilograms and Schedule 2B - 1 tonne). It is up to theNational Authority to decide on the thresholds for declarations from individualfacilities.

For Schedule 3 chemicals or plant sites the information requiredwill be essentially the same but adjusted to the particularities of Schedule3 declaration requirements. For chemicals the following data will be essential:

(a) general information: item number on Schedule 3, chemical name,CAS registry number, common/trade name and structural formula;

(b) quantitative data: quantity produced (including information onpercentage concentration regarding raw material and product), imported andexported;

(c) information on import/export: supplier and recipient countries;

(d) information on purpose of production; and

(e) information on production range for the certain chemical: lessthan 30 tonnes, 30-200 tonnes, 200-1000 tonnes, 1000-10 000 tonnes, 10 000-100000 tonnes and above 100 000 tonnes.

For Schedule 3 plant sites the following information might constitutea basic set of data:

(a) logistics information: name and address of the facility (includingbuilding number or address, structure and postal code) and name of boththe owner and operator of the facility; and

(b) activity information: main activities of the facility, whichscheduled chemicals are produced there and their production capacity, andinformation on the type of plant (dedicated or multipurpose).

For DOC, including PSF chemicals, the following informationmight constitute the basic set:

(a) general information: chemical group, chemical name, CAS registrynumber and common/trade name; and

(b) information on the production range for the plant site: lessthan 30 tonnes, 30-200 tonnes, 200-1000 tonnes, and above 1000 tonnes.

For a facility producing DOCs, including PSFs, the following informationwill be required:

(a) logistics information: name and address of the facility wherethe chemical is handled or stored (including building and structure specification)and name of both the owner and operator of the facility; and

(b) activity information: main activities of the facility and identificationof each unit or plant at each plant site that has produced a DOC, includingPSF plants.

The above basic sets of information required from an individual facilityoperator should be sufficient for the National Authority to fulfil the declarationobligations to the OPCW. A system must also be in place which will takecare of any changes at the company level regarding previously submittedinformation on Schedules 2 and 3.

In addition, there is a need to identify the dates by which the informationfrom the facility operator should be submitted to the National Authorityso that the annual and initial declaration can be submitted at the propertime to the OPCW.

IV. Facility operators and inspection activities

This paper does not address in detail the anticipated routine and possiblechallenge inspection activities after declarations have been submitted.However, the following discussion provides a brief review of the main aspectsof routine inspections under Schedule 2 and 3.

Schedule 2 requirements

The initial declarations of a State Party will provide information on allSchedule 2 chemicals produced above the threshold and data on the numberof plant sites and plants that should undergo an initial inspection withinthe first three years after entry into force.

For Schedule 2 declarations verification will involve on-site inspectionof all plant sites and its plant(s) that have produced, processed or consumedany such chemicals during the three calendar years before entry into forceor which anticipate any of these activities in the following calendar year.The Technical Secretariat will give priority to Schedule 2 facilities overthe first three years after entry into force of the Convention. The aimof these on-site inspections is to verify that Schedule 2 activities arein accordance with a States Party's obligations under the CWC which interalia include the absence of Schedule 1 chemicals, consistency with declarationsand non-diversion. Each plant site will receive an initial inspection atwhich time a Facility Agreement for the plant site will be negotiated bythe OPCW and the National Authority. This should be agreed upon not laterthan 90 days after the inspection. In general, access by the OPCW inspectionteam to other parts of the plant site will be granted in accordance withthe negotiated Facility Agreement. The National Authority will have a minimumof 48-hours notice of any given inspections and the inspection cannot lastmore than 96 hours.

Schedule 3 requirements

Initial and annual declarations are required for all plant sites where morethan 30 tonnes of a Schedule 3 chemical were produced in the past calendaryear or are anticipated to be produced in the following calendar year. Verificationwill involve on-site inspection at plants where production is in excessof 200 tonnes aggregate above the declaration threshold. The inspectionaim is to verify that activities are consistent with the information providedand that no Schedule 1 chemical is present. There will be no Facility Agreementunless requested by the State Party. The OPCW team will focus on the declaredSchedule 3 plant(s) but may request access to other parts of the plant siteon the basis of negotiation with the national inspector present. Accessto records, sampling and on-site analysis will also be the subject of negotiation.The State Party will receive a minimum notice of five days before the inspectiontakes place and the inspection cannot last more than 24 hours without furtheragreement of the national inspector. Inspection of Schedule 3 facilitieswill have a lower priority than inspection of Schedule 2 facilities especiallyduring the first three years. The maximum number of inspections (including'other chemical production facilities') is 3 + 5 per cent of the total plantsites declared to an overall limit of 20 inspections. No individual plantwill receive more than two inspections per annum.

From this short review it is obvious that a facility operator has to beprepared to receive, in accordance with the thresholds for verification):

(a) an initial inspection if there are Schedule 2 chemicals or aplant site producing Schedule 2 chemicals - the major aim of such an inspectionis to prepare the facility agreement;

(b) a routine inspection if there are Schedule 2 or 3 chemicals ora plant site producing one of these chemicals; and

(c) four years after EIF a routine inspection if DOC chemicals, includingPSFs, are handled.

For any Schedule 2 plant site the facility operator has to be prepared toreceive an initial inspection in the first three years after EIF. Duringthis inspection the draft Facility Agreement has to be prepared, which impliesthat the facility operator must prepare it in advance in close cooperationwith the National Authority to ensure that after implementation of it, futureeventual inspections will run smoothly and inspection activities will nothave a major negative impact on the facility.

V. Public outreach strategy to affected industry

As outlined under Article VII, it will be the responsibility of eachState Party to design its own public outreach programme to industry andto identify the important target groups specific to its own situation. Thereare various target groups which will be affected by the Convention's declarationrequirements and verification (inspection) obligations. From a pragmaticpoint of view it is possible to differentiate between different target groups:

(a) groups which will be affected by the declaration requirements,including the requirements under Article VI (scheduled chemicals and facilitiesdealing with these chemicals, plus facilities under the PSF and DOC approach);

(b) groups which will be affected by 'normal' inspection activities(systematic on-site inspections, monitoring and routine inspectionsof chemical facilities), and

(c) groups which will be affected by 'not normal' inspection activities(challenge inspections, investigation in cases of alleged use of CW).

These groups will be affected differently under the CWC, but must be identifiedby each country during the process of preparing for national implementation.

The implementation strategy used by some countries suggests that in orderto identify the entities which will be affected by 'declaration requirements'and 'normal' inspection activities, the following approach can beused:

(a) a survey of the industrial base for the production, processingor consumption of selected product types;

(b) matching these product types with commercial and trade organizations,manufacturers associations, and the like; and

(c) targeting the relevant facilities, plants and plant sites byusing the data obtained from the survey of the industrial base and the informationsupplied by the commercial and trade organizations.

If this approach is used, it is obvious that not only the 'pure' chemicalindustry will have to be surveyed. Depending on the level of industrialdevelopment, other branches (e.g., micro-electronics, pharmaceuticals, dyeand photographic industry, textiles) will also need to be covered in sucha survey, keeping in mind the requirement to declare consumption of designatedchemicals (especially under Schedules 2 and 3). For this undertaking theillustrative list of Categories of Products developed by the PTS will serveas a point of departure. However, it must be remembered that the correlationbetween a product and the schedules is only an indicator and does not automaticallyidentify the facility. The scheduled chemicals are another point of departure.In addition to the three schedules of chemicals, there is another groupof facilities which may also be affected by the declaration requirement:the group of facilities with DOC, including PSF, chemical production. Itis obvious that the whole survey will be broader and more complex than wasfirst expected. Many states already have experience related to the firstphase - targeting and survey.

In general, the following groups have to be considered for the first survey:(a) chemical industry (facility operators at various levels and variousdegrees of involvement in activities related mostly to Schedules 2 and 3and, to a lesser extent, to Schedule 1; (b) facility operators runninga facility covered under the DOC or PSF approach; (c) military defenceestablishments concerned with Schedule 1 activities (defence research),and old and abandoned CW; (c) research institutes, laboratories anduniversities (using Schedule 1 chemicals in small amounts for R&D);and (e) other branches of industry (e.g., those involved with agriculture,medicine, biotechnology, micro-electronics, dye and ink industry, etc.)which are concerned with the consumption of primarily Schedule 2 chemicalsand some Schedule 1 chemicals.

In conducting the survey to estimate the target entities, the CWC verificationregime should also be considered, which will be established only for: (a)Schedule 1 chemical production facilities; (b) Schedule 2 chemicalproduction, processing and consumption plants; (c) Schedule 3 chemicalproduction facilities; and (d) production facilities manufacturingunscheduled DOCs including PSF chemicals.

The question of how to identify these facilities is probably the most challengingone. The PTS has prepared background material which is quite helpful andpoints to the possible 'tools' which can be used.

After the internal survey and the identification of possible affected facilities(with respect to declaration and normal inspection requirements and activities),the National Authority should start a dialogue to inform about all of thedetails of declaration activities and the receiving of expected inspections.It should be remembered that there are different levels of possible involvementin declaration submission by an individual facility operator: (a)a facility, which has to declare annually (Schedule 2 and 3), (b)a facility, which has to declare past activities (Schedule 2 and 3), and(c) a facility, which declares only once (PSF and DOC).

In the national implementation process there is a need not only to identifythe entities which will be affected by the CWC's declaration and inspectionrequirements and activities on the national level, but also to set up a'programme' to inform them of the requirements they are supposed to meet.The National Authority ought probably to conduct some type of outreach programmeto update facility operators on a continuing basis about new developmentsin regard to not only their obligations but also their rights in normalinspections. A good opportunity to start such a dialogue with facility operatorswould be the preparation for the setting up of facility agreements for thoseinvolved in Schedule 2 activities. However, compared to the overall numberof facilities affected, this is only a small group.

Another crucial question is: Who could assist in the outreach strategy forthose facilities affected by declaration duties and possible inspectionactivities? Obviously, the National Authority will not be able to effectivelyaddress this question alone. There is a need to use a country's existingorganizational set up for industry (e.g., CMAs, Industrial ManufacturersAssociations, Chambers of Commerce, etc.) However, there will always bea group of facilities which are not represented in such organizations. TheNational Authority must involve these facilities in its outreach strategy,including preparing them for possible inspections.

VI. Problems remaining to be solved regarding the declaration formats

The declarations submitted by an individual facility operator will formthe basis for the declarations from the National Authority to the OPCW.The National Authority will decide the format to be used by each individualfacility operator to submit its declaration. However, there are still ambiguitiesregarding the declaration forms in the Declaration Handbook, which may createdifficulties in setting-up questionnaires for industry.

The declarations will include 'aggregate national data' for each Schedule2 and 3 chemical and declaration of plant sites where chemicals of interestare employed. There is an ongoing debate as to what 'aggregate' means asthere will be many sites where scheduled chemicals are produced below reportingthresholds for plant sites. Normally, these plant sites need not be declaredby the National Authority. The question which arises here is, will the NationalAuthority require information on all production in order to develop a nationaldeclaration or will 'aggregate data' include only declared plants? If thelatter is the case, then much of the production of scheduled chemicals willnot be accounted for.

In connection with 'aggregate national data' there is also the questionof how to cope with changes in the declared data of individual facilitiesduring the year. Such changes could cause changes in the aggregate numberswhich might then exceed the thresholds.

There seems to be a general problem with respect to the 'rounding rules',as outlined in the Declaration Handbook. For example, if there is a batchproduction of 500 kilograms of a particular Schedule 2 chemical, shouldthis be reported as 1 tonne under the proposed rounding rules for Schedule2 declarations? For practical reasons it might be advisable that in therequired declaration from a facility operator the rounding rules be adjustedso that the aggregate number could be estimated more precisely. This willapply mostly to Schedule 2 declarations, and especially chemicals on Schedules2A* and 2B.

There is another definition problem related to DOCs. They are subject tolimited reporting: only production at chemical facilities above the giventhreshold based on past production need be reported. The CWC generally definesproduction as 'its formation through chemical reaction', while Part IX ofthe Verification Annex discusses the production of DOCs 'by synthesis'.The former is a broader category than the latter.

VII. Conclusions

The chemical industry will be affected mostly by declaration requirementsrelated to Schedules 2 and 3 and other chemical production facilities. Theburden of reporting will fall on the individual companies. However, it willbe up to the National Authority to develop a system which will make it possiblenot only to inform companies about reporting obligations, but also to workon a continuous basis with companies which have to report annually on regularactivities as well as companies which start activities that must be declared.Companies need to be informed and provided with updated information abouttheir obligations and rights. The National Authority should help companiesto fulfil their reporting obligations. Individual companies need assistanceto provide the data which will form the basis for the National Authority'sdeclarations to the OPCW. The declarations of a State Party will be onlyas precise as those of the individual companies to the National Authority.


(June 1995)