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CWC Industry Compliance Program: Problems and Resolutions in Preparing Industry Declarations. Kevin J. Kurland Director Treaty Compliance Division U.S. Department of Commerce. Topics of Discussion. Components of a successful industry compliance program Declaration problems and resolutions

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CWC Industry Compliance Program:

Problems and Resolutions in Preparing Industry Declarations

Kevin J. Kurland

Director

Treaty Compliance Division

U.S. Department of Commerce


Topics of discussion
Topics of Discussion

  • Components of a successful industry compliance program

  • Declaration problems and resolutions

  • Advantages of a robust declaration compliance program


Components of a successful industry compliance program
Components of a Successful Industry Compliance Program

  • Ensure industry compliance

    • Establish an administrative regime to compel:

      • declarations; Schedule 1 notifications; end-use certificates (EUCs) for Schedule 3 transfers to States not Party; and on-site inspections

    • Establish an enforcement regime to ensure:

      • submission of declarations, notifications, and EUCs

      • entry on-site is granted to inspectors

      • prohibit imports and exports to States not Party

      • outlaw use of toxic chemicals/precursors for purposes not prohibited

  • Maximize the protection of confidential and other critical information

  • Minimize burdens and costs to industry


Keys to success
Keys to Success

  • Clear guidance to industry on basic concepts and requirements

  • User-friendly declaration forms

  • Cooperation with industry

  • National Authority/Government services

    • Outreach (e.g., surveys, mass mailings, website (www.cwc.gov), seminars, site assistance visits)

    • Chemical determinations

    • Declaration completion support


Declaration problems
Declaration Problems

  • Certain treaty terms are undefined or inconsistent with common industrial usage, e.g.:

    • “Production by synthesis”

    • “Main activities”

    • “Plant site”

  • Application of quantity thresholds and mixtures to activities requires clarification

  • Limited harmonization among States Parties on how export and import data is declared

  • No OPCW provisions for declaration amendments


Resolution
Resolution

  • Issue clear guidance and declaration handbooks for industry

    • Clarify terms and application

    • Ensure that all persons, trading companies, and chemical facilities are subject to rules

  • Ensure accurate OPCW declaration submissions through use of standardized declaration forms

    • Including electronic versions

  • Require companies to designate declaration points of contact to clarify submissions

  • Conduct outreach


Advantages of a robust declaration compliance regime
Advantages of a Robust Declaration Compliance Regime

  • Allows a State Party to honor its treaty commitments

  • Lends credibility to the legitimate chemical activities in a State Party

  • Facilitates inspection activities

  • Enhances a State Party’s national security:

    • Increases knowledge of domestic manufacturing, use, export, and import of toxic chemicals/precursors related to chemical weapons

    • Improves the ability to deter, detect, or prevent proliferation by domestic or foreign actors


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