The workshop’s third session focused on various aspects of security and chemical weapons production and featured presentations by four speakers. Jonathan Forman, Science Policy Advisor for the Organisation for the Prohibition of Chemical Weapons (OPCW), spoke on the topic of preventing chemical weapons proliferation. Matthew Moakler, Foreign Affairs Officer in the U.S. Department of State’s Office of Missile, Biological, and Chemical Nonproliferation and Chair of the interagency Shield Licensing Group, presented a policy perspective on dual-use chemical equipment non-proliferation. Richard Cupitt, the U.S. Coordinator for United Nations Security Council Resolution (UNSCR) 1540 in the Office of Counterproliferation Initiatives at the U.S. Department of State, then discussed implementation of UNSCR 1540, which addresses proliferation of nuclear, chemical, and biological weapons and illegal trafficking in these weapons of mass destruction (WMD). The final presentation by Elizabeth Scott Sangine, Director of the Chemical and Biological Controls Division at the U.S. Department of Commerce, described the U.S. approach to chemical equipment export controls. A discussion moderated by Nancy Jackson, Franklin Fellow at the U.S. Department of State and a member of the workshop organizing committee, followed the presentations.
- The role of non-state actors is a major challenge for non-proliferation activities, particularly since the control of those actors depends on individual nations enforcing international agreements and developing sufficient national-level controls to govern the use and transfer of chemical manufacturing equipment within their own borders. Additional challenges arise from non-state actors using less sophisticated technologies to make chemical weapons. (Forman)
- Treaties are important as matters of principle, but they are only implemented to the degree that national-level laws that address criminal legislation, trade controls, and the reporting and monitoring of industry within the national boundaries are both developed to conform with treaty obligations and enforced. (Forman) As of 2011, fewer than half of the member nations of the United Nations had created a legal framework to account for the production, use, storage, or transport of chemical weapons-related materials, and even fewer countries had enforcement measures in place. (Cupitt)
- Chemicals can be listed under the CWC, but there is a concern that new methods that avoid listed compounds can be developed to create toxic chemicals or that novel delivery technologies, such as nanotechnology, can be used to turn an unlisted compound into a chemical weapon. (Forman)
- Changing technology can create difficulties for inspectors trying to differentiate between a legitimate chemical plant and one making chemical weapons (Forman).
- The ability to transfer information, DNA sequences for example, without the additional need to transfer material may present a future challenge for controlling dual-use materials. (Forman)
- The non-physical transfer of technology thanks to avenues such as the Internet is a major concern and can only be addressed through a combination of activities, such as promoting global norms and developing non-proliferation regimes that can link like-minded countries in a concerted effort to stop such proliferation. (Moakler)
- Sound export licensing decisions by suppliers and nations have had a tangible impact on proliferators by denying them access to the world’s best sources of technology and corrosion-resistant equipment. (Moakler)
- The trend for chemicals production to move to lower-cost countries creates a challenge for the effective use of export controls because fewer chemical-producing nations are now part of the Australia Group. (Moakler)
- Information exchange between industry and regulators is critical for making regulations work and reducing the overall burden on industry. Applications for an export license should include information on the specific intended end use, as well as other potential uses; the intended destination; and what kind of relationship and for how long has the licensee had with the intended recipient company and its background. Volunteering such information takes a strong corporate culture that encourages this degree of sharing. (Sangine)
- Education, training, and outreach efforts have lagged behind other approaches to non-proliferation but are needed to help create a culture of support for nonproliferation activities. (Sangine, Cupitt)
- There is little political will at the national level to increase the number of chemicals on control schedules. (Cupitt, Maennig)
The OPCW is the implementing body for the CWC, the multilateral disarmament treaty for chemical weapons, explained Jonathan Forman. The OPCW is located in The Hague and has a staff of about 500 people—120 of which are chemical weapons inspectors—from 80 nations with an annual operating budget of about $101 million excluding the cost of the current disarmament activities in Syria, which are funded by voluntary contributions from the member states. There are 190 member states, all signatories to the CWC; all but Israel and Myanmar have also ratified the treaty. Four countries—Angola, North Korea, Egypt, and South Sudan—have not signed the treaty.
There are four core activities for OPCW: chemical disarmament, which includes the destruction of military chemical weapons stockpiles; non-proliferation, which includes verification; assistance with and protection against chemical weapons; and fostering international cooperation. Verification, Forman explained, is a process by which the State’s Parties declare the chemicals and chemical activities that they have going on in their territories, including industrial activities that meet certain criteria and that are subject to random inspection by a team of international inspectors. At military sites, verification entails having inspectors confirm that every chemical weapon and all related munitions are accounted for and destroyed. In some cases, the verification process involves sampling and analysis, while in other instances it involves just looking around and checking records, said Forman. At a higher level, verification includes looking at the national-level controls that the member states put into place. The goal of this process is to build confidence among nations that each signatory to the CWC is following through with its obligations to comply with the treaty’s provisions.
Treaties are great in principle, said Forman. “They say that this is what we believe in and this is what we are committed to,” he said. “But how do you actually implement the laws and regulations that make a treaty effective? That is what is done at the national level.” He explained that each nation is responsible for enacting the laws and regulations needed to meet the responsibilities obligated by the treaty. One limitation of this approach is that in today’s world, non-state actors are a major worry and non-state actors are not covered directly by the treaty. “How non-state actors get dealt with in terms of the treaty is really through the implementation of national laws,” said Forman. “National laws take care of criminal legislation, trade controls, and the reporting and monitoring of industry within the national boundaries. That is complicated in a way because if all of the different states are allowed to have their own laws that create a lot of interesting situations when you are trying to import and export across international boundaries.”
Forman presented a brief history of chemical weapons, starting with World War I. The first attempt at stopping the use of chemical weapons occurred in 1952 when countries signed the Geneva Protocol and pledged not to use chemical weapons in war except in response to a chemical weapons attack. Under the Geneva Protocol, countries continued to maintain stockpiles of chemical weapons and agents that were far more potent than the mustard gas used in the First World War.
The verification process, said Forman, starts with a country declaring the chemical weapons it has in its possession. The verification division at OPCW evaluates these declarations, monitors data for the production of specific chemicals, and sends inspectors into the field for on-site inspections. The chemicals fall into three schedules: warfare agents, chemical weapons precursors and breakdown products, and industrial dual-use chemicals, which include substances such as hydrogen cyanide and phosphorous trichloride that have important uses but that could be turned into chemical weapons. Also included are chemical production facilities producing more than 200 metric tons per year of discrete organic chemicals, or greater than 30 metric tons if the discrete organic chemicals contain phosphorous, sulfur, or fluorine. There are exemptions for chemical plants that make fuels, explosives, and oligomers. For those plants, verification involves ensuring that there is an absence of chemicals identified in the CWC Schedules. Forman noted that between 30,000 and 35,000 chemicals are scheduled, a
small percentage of the 140 million unique chemicals that have been synthesized.
There are a number of concerns about chemicals listed under the CWC, Forman said. “We are always concerned if there are new routes to make toxic chemicals,” he said, citing the advent of biotechnological process as one example. “There are concerns that you might be able to take a chemical that wouldn’t have been considered as something weaponizable and through some new technology, perhaps drug delivery strategies that people use with nanoparticles, to turn it into something that could be used as a weapon. This is really less about chemical production and more about the formulation of chemicals,” Forman noted. Another concern is that banned activities can be disguised and not subject to the verification regime.
One challenge for inspectors is telling the difference between a chemical weapons production facility and a commercial chemical production plant. This challenge has been exacerbated by the continued development of new ways to make chemicals, such as through fermentation. “If you are looking for specific types of equipment that are being sold or imported or exported, it is not always obvious that the traditional equipment is the only thing you have to look at,” Forman said. Even more vexing are differences in national level regulations concerning what types of plants are declared. “Declarations are not always consistent from state party to state party,” said Forman. “One of the States Parties actually declares breweries just to make the point that fermentation is a chemical process.”
The ability to transfer information easily is another confounding issue today for weapons inspectors. As an example, Forman said that it is possible to send a DNA sequence to a DNA synthesizing machine located anywhere in the world. “The people on the other end don’t actually have to know what I am making. They just have to be able to load up the machines with the right precursor materials,” said Forman. He added that his thinking on how to account for this type of information exchange is still in flux.
Chemical weapons programs carried out by nations are fairly easy to spot because they are usually technologically sophisticated, but this is not the case with non-state actors, where simple, cheap, obtainable technology is more valuable than sophistication. While such operations are supposed to be covered by national laws, it is possible for a non-state actor to cobble together simple technologies at a scale small enough to avoid being declared or detected. Forman noted that weaponization requires more than just chemicals and facilities that are creating weaponizable materials have a certain look to them that can serve as a telltale sign for inspectors.
The biggest challenge with chemical weapons is being ready to react. “For the OPCW, that means keeping a well-maintained and well-skilled inspectorate, being up to date on analytical capabilities, knowledge of chemical weapons issues and how to handle them, and also having trained responders,” explained Forman. One way forward, he said, is to take a holistic view that looks at the big picture of what a facility looks like, the kinds of materials at the plant, the regulatory environment in which it exists, and the possible motivations of the people who are acquiring chemical manufacturing equipment. Taking a holistic view requires engaging experts with a broad range of skill sets. “You need people that can recognize when technologies might be of concern,” said Forman. “You need people that can recognize when new technologies could also be used to help you do better non-proliferation or better verification.” Finally, it is important to maintain a dialog and share information. “You need to teach people what is important and to understand the changes that are taking place in the world and how they fit into this bigger security picture,” Forman said in closing.
Kathryn Hughes from the NRC asked if inspectors check the tracking numbers on equipment. Forman replied that the inspectors will do visual inspections in some plants and sampling and analysis in other plants. “They are not looking for tracking numbers of individual equipment. They are looking to see that this plant has been declared as a discrete organic chemicals plant,” said Forman. He noted that if the inspectors are doing sampling or analysis, which is based on gas chromatography/mass spectrometry readings, they check to see if the analytical results are in the database of scheduled compounds.
The reason that the United States opposes chemicals weapons, said Matthew Moakler, is that they are weapons of mass destruction that can only be used indiscriminately and that have a disproportionate impact on civilians. Since the 1980s, the key to U.S. strategy regarding non-proliferation in this area has been to impede the flow of the items needed to make chemical weapons. He noted that the chemical weapons programs of rogue states such as Iraq, Libya, and Syria were based almost entirely on items purchased from abroad. He also said that the real threat today is not from nation states as much as from so-called lone actors, such as the five Iraqis arrested in 2013 who were creating Sarin using small-scale production equipment or the American who pled guilty to producing ricin in his home and sending ricin-laced letters to various public officials, including President Obama and Senator John Wicker.
Addressing the impact of controlling the export of dual-use equipment, Moakler said that export controls help prevent proliferators from acquiring the items that they need to make chemical weapons. “Sound export licensing decisions by supplier and transshipment countries, time and again, have had a tangible impact on proliferators by denying them access to the world’s best sources of technology and
equipment,” said Moakler. He noted that since the 1980s, particularly after the chemical weapons attacks during the Iran/Iraq war, individual countries cannot employ effective national export controls individually but have to do so in concert with one another. “The more states that adopt and effectively administer similar controls, the more effectively this objective can be achieved,” said Moakler.
To that end, the United States coordinates its national export controls with the Australia Group, which includes 41 countries and represents roughly 80 percent of the global trade in chemicals and chemical equipment. Over the past 30 years, the Australia Group has focused on harmonizing and updating export controls of dual-use chemical and biological manufacturing items to ensure they do not contribute to weapons programs. The Australia Group has also shared information and lessons learned pertaining to the threat of chemical and biological weapons and regarding technology, enforcement, and interdiction in order to harmonize export controls across nations. It also reaches out to nonmembers to foster a better understanding of what this group is trying to accomplish and to encourage adoption of comparable export controls. That effort, said Moakler, has led many key exporters outside of the Australia Group, including China, India, Russia, South Africa, and the United Arab Emirates, to implement export controls.
The reason for controlling the materials that are exported, Moakler explained, is that manufacturing chemical warfare agents is not unlike manufacturing other chemicals. It involves assembling a plant out of component parts that perform the basic unit operations of chemical engineering—transportation, combination, separation, and reaction. These component parts are similar to those in any chemical plant around the world, with a few caveats. First, most chemical warfare agents are acids and many of their precursors are highly corrosive. Therefore, any surface that comes in contact with them must be made of corrosion-resistant materials. It is possible to use regular stainless steel equipment, which is what Iraq was using at the end of its chemical weapons program, but these items must be replaced regularly because of corrosion, significantly increasing the cost of production and the time needed to realize a weapons program. The second caveat is that there is an extreme safety risk inherent in chemical warfare agent production, so there is a premium placed on preventing leaks through the use of equipment made of robust, corrosion-resistant materials, and then detecting those leaks with toxic gas monitors.
Moakler explained that deciding on a list of items to include in an export control program requires balancing the non-proliferation benefit with the commercial impact of licensing, a point made earlier by Charles Mooney in his presentation. “Finding that sweet spot is a challenge, especially at the policy level,” said Moakler, which is why export control lists are supplemented by what is known as the “catch-all” rule. The overriding goal, he said, is to capture items such as reactors, storage vessels, distillation columns, heat exchangers, pumps, valves, piping, filling equipment, and toxic gas monitors made of corrosion-resistant materials including glass, high-nickel steel, graphite, ceramics, fluoropolymers, titanium, zirconium, and other corrosion-resistant exotic alloys.
Looking forward, there are several challenges for the use of effective export controls. One challenge is that the trend for chemical production to move to lower-cost countries means that fewer chemical producers will be part of the Australia Group, which is why that group has been reaching out to new supplier countries to encourage them to adopt export controls. Another challenge arises from unlisted items, primarily those that are not corrosion resistant, which is the reason for the catch-all control lists that allow the United States and other Australia Group members to intervene and require export licenses for unlisted items when they believe that the exports will contribute to chemical weapons proliferation. Moakler added that there is a great opportunity for industry to approach U.S. regulators if they have any suspicions that export of a given piece of equipment might lead to chemical weapons production.
The transfer of technology, either tangible or intangible, from one entity to another via non-physical means such as the Internet, was identified by Moakler as a major concern. He noted that controlling proliferation of this type of information requires a combination of activities, such as promoting global norms via treaties and developing non-proliferation regimes in addition to the Australia Group that can marshal like-minded countries to work together to curb the spread of chemical weapons. Other tools for impeding the flow of technology includes unilateral interdiction of suspect shipments, the threat of sanctions, providing technical and financial assistance to help countries put into place more effective export controls and destroy any chemical weapons stockpiles or production facilities, and visa screening that aims to identify individuals that are coming to the United States solely, incidentally, or principally to violate or evade any law prohibiting the exports of goods, technology, or sensitive information.
Richard Cupitt began by providing an overview of UNSCR 1540, noting that it was unanimously adopted by the United Nations Security Council in 2004. The resolution was the first formal decision taken by the Security Council to address the proliferation of nuclear, chemical, and biological weapons as well as their means of delivery as a threat to international peace and security. To that end, UNSCR 1540 identifies illicit trafficking in these weapons of mass destruction and their means of delivery, as well as related materials such as manufacturing equipment, as a new area of concern. In addition, this resolution focuses on
proliferation to and by non-state actors, another new emphasis for the Security Council. Within its text are more than 200 specific obligations, and because it was adopted under Chapter 7 of the United Nations Charter, these obligations are legally binding on all states. The resolution explicitly embraces various international legal instruments, including the CWC, while implicitly endorsing the lists from other multilateral agreements on export controls, such as those of the Australia Group.
The specific points listed in UNSCR 1540 include the requirement to account for and secure “related materials,” which includes equipment as well as technologies and materials in production, use, storage, and transportation. UNSCR 1540 also obliges member states to restrict trafficking and brokering of such items by, among other means, controlling their export, transit, transshipment, and re-export. The resolution specifically requires states to have end-user controls to help assure that non-state (and state) actors cannot use these methods to acquire indirectly the materials they need to produce weapons of mass destruction.
Cupitt explained that UNSCR 1540 also created a committee, with a current mandate that runs until 2021, to oversee enforcement. This committee, a subsidiary body of the Security Council, is advised by a group of experts, and its primary role is to monitor and report on implementation. The committee’s other tasks include data collection regarding the status of each nation state in terms of the measures they have taken to plan or implement each of the 200-plus obligations in the resolution. The committee creates a matrix1 for each of the 193 U.N. member states and each matrix has 382 fields that account for some aspect of implementation. “There is a lot of information in these matrices on legal measures and the legal framework,” explained Cupitt. Additional information on enforcement actions is also included in the matrix. The committee last reported to the Security Council in 2011 and is currently in the process of updating these matrices.
The 2011 report showed that fewer than half of the member nations had created a legal framework to account for the production, use, storage, or transport of chemical weapons-related materials, and even fewer countries had enforcement measures in place. For those countries with laws on the books, very few had rules relating to accounting for equipment or technology and fewer than half had measures in place to secure equipment, technologies, and related materials. Out of the approximately 80 countries that have declared chemical weapons production facilities, 20 or so do not have any measures in place to secure production, use, storage, and transport of equipment, materials, and technologies at those facilities. One conclusion that Cupitt said can be drawn from the 2011 report is that very few of the measures taken by countries are designed to address terrorism or proliferation. Most measures addressed other objectives, particularly environmental concerns, worker safety, and public health. This is not true, however, for those nations in the Australia Group.
One of the committee’s activities involves identifying the effective practices that nations are taking and to share those findings. “On the security side, most of the effective practices that the committee was able to identify would come from unconventional chemical sources,” said Cupitt, from organizations such as the International Marine Organization, the International Civil Aviation Organization, the U.N. Environmental Program, the Food and Agriculture Organization, and the World Health Organization. He noted, too, that the committee has worked with the OPCW on ways of securing materials based on the OPCW’s work on accounting, verification, and destruction.
The committee has also surveyed nations for their effective national practices and received submissions from 42 states so far. “Unfortunately, only five of those even referenced chemical security in any way,” said Cupitt. He added that the U.S. Chemical Facility Anti-Terrorism Standards appear to be unique and the committee has been sharing these with the other nations. Several states, including the United States, are preparing new submissions on effective national practices.
Cupitt concluded his remarks by stating that while many members of the committee will say that nuclear or biological weapons are more important because the mortality and morbidity associated with the use of those weapons is likely to be higher than for a chemical weapon attack, he takes the perspective that the risk of a successful chemical attack is much higher. “These things are easier to get and easier to produce. There is a real risk,” said Cupitt. On a positive note, he added that there is an opportunity for action because there are many ways of fitting chemical weapons non-proliferation activities into existing environmental compliance programs.
To start the session’s final presentation, Elizabeth Scott Sangine reminded the workshop that the authority for the federal government to require industry to take the appropriate steps to control the export of equipment that could be used to make chemical weapons comes from the Export Administration Act of 1970, when the primary worry was over the Soviet Union’s chemical weapons program. “There was not a comprehensive chemical weapons treaty at the time, but many of the supplier states did get together,” said Sangine. Export controls for chemical equipment were first added unilaterally to the U.S. Commerce Control List and then by the Australia Group in 1991. At the time, equipment was available from 20 non-Australia Group countries, including Russia, China, India, South Africa, and Taiwan. Until 2005, she added, a U.S. export license was required only for so-called countries of concern. Today, an export license is required for all non-Australia Group member countries.
Sangine said that though the number of applications for chemical equipment export licenses has soared since 1999 to close to 3,000 in 2013, the number of those applications that get rejected has stayed small, around three to four a year. “That just shows that most of the equipment is used for legitimate business,” said Sangine. The requirement for a license, she said, is to enable the federal government to keep track of end-users and to provide information about end-users that a potential licensee might not be able to access. She added that there are export control lists for both chemicals and chemical equipment and that there are license exceptions available for industry to use for certain situations, such as in the case where there is a plant shutdown and a customer needs a replacement part. Temporary exemptions are granted so that companies can take equipment to international trade shows, and government-to-government exceptions are granted for emergency responses to disease outbreaks, for example.
When it receives an application for an export license, Sangine’s office first reviews the construction materials and the performance capabilities for a given piece of equipment. She provided some advice for those who do need to apply for a license. “The reasons your export licenses might take longer than you would like is if we don’t really understand what you are shipping or why,” she told the workshop. “We really need this information when you apply.” Applications for an export license should include information on the specific intended end use, as well as other potential uses; the intended destination; and a description of the relationship the licensee has with the intended recipient company, including information such as how long they have worked with the company and any other relevant background information.
When a license is issued, it comes with a set of standard conditions that include a statement of end use; that there should be no resale, retransfer, or re-export without prior U.S. government authorization; that the equipment not be used to make chemical or biological weapons; and that the applicant must inform the consignee of these license conditions. She explained that from the standpoint of the U.S. government, control continues to exist over an item for its entire lifetime, even if gets incorporated into some other piece of equipment. The reality, though, is that the U.S. government is incapable of knowing if an item is resold. There are Department of Commerce export control officers with law enforcement responsibilities stationed in Singapore, Hong Kong, Russia, India, China, and the United Arab Emirates who conduct pre-license checks and post-shipment verifications. In addition, the Office of Export Enforcement collaborates with all of the U.S. law enforcement agencies to develop leads and monitor proliferation activities. She noted that most of the indicators of a proliferation network’s activities are financial in nature.
Sangine said that export controls are applicable when technology takes the form of technical data or technical assistance and whether that technology is tangible or intangible. This provision becomes particularly germane for academics and universities who may not be aware that having a foreign national come to a laboratory to learn a new technology does fall under the export control regulations. The exceptions are if the foreign national is a green card holder, permanent resident, or protected individual as defined under U.S. Code. The applicable regulations are spelled out in Export Administration Regulations 734.2(b)(3), she added.
One of the big changes that have taken place since the 1980s is that companies no longer store parts on site and now expect replacement parts to be delivered within hours, not days. However, issuing export licenses takes longer than that, explained Sangine. The Department of Commerce has adjusted to this new reality by allowing in-country storage, enacting internal procedures to shorten review times, and granting 4-year licenses. Another significant change has been the shift in concern from state chemical weapons programs to those run by terrorist organizations. As a result, the Commerce Department now works closely with the Department of State on sanction and embargo lists, and it issues regime denial notifications within the context of the Australia Group. She also said, “If you have a gut feeling that something is not right, apply for a license and let us be the ones to judge.”
Sangine ended her comments by stating, “We know chemical equipment and chemical production is global and we have these controls to make it harder for proliferators. We know there are other things they can use, but this is just to hopefully slow it down a little bit. We do licensing as rapidly as possible, but we are always open to new ideas that help us. As I said, these are pretty old methods of doing export controls, so any and all new ideas are welcome.”
To open the discussion, Clara Zahradnik asked Sangine if the federal government would consider revising the CB3 regulations in light of the migration of production and technology for chemical equipment. Sangine replied that the Department of Commerce is always open to taking suggestions from industry and will take that idea under consideration. Zahradnik replied, “I think maybe some creativity would help industry a lot.”
In response to a question from Nancy Jackson about enforcement, Cupitt acknowledged that enforcement is a difficult problem for the U.N. committee. “To some extent the committee is focused on the legal aspects and whether a law exists. If there is no legal measure, it is unlikely there will be any enforcement that will take place,” he said. What the committee has done is work closely with the United States and the World Customs Organization (WCO) to develop a strategic trade control enforcement project that the WCO will conduct. These activities will be similar to those the WCO has conducted for other illicit trafficking areas such as endangered species and human trafficking. He added that
Interpol has an effort underway to identify potential chemical, biological, radiological, and nuclear facilities that non-state actors could use for nefarious purposes. Cupitt noted that the European Union is training prosecutors, investigators, and judges to deal with these cases.
Kathryn Hughes asked if there are any efforts underway to educate and train chemical engineers so that they can identify things that might be questionable when they go visit other facilities. Sangine replied that the Commerce Department does a great deal of outreach with industry and with major domestic trade groups. Academia, however, has been tougher to reach, she added. Cupitt said that outreach is not required under the U.N. resolution, but it is recommended and the committee does collect data on outreach efforts. “I would say there are a fair number of government outreach programs on the chemical side compared to the nuclear and biological sides,” said Cupitt. He added that the committee is engaging industry to develop codes of conduct at the facility level. Jonathan Forman acknowledged that OPCW’s efforts to “work with chemical engineers, particularly in the academic sector, have been fairly lax.” He also noted that OPCW often has difficulty hiring chemical engineers as inspectors, which he said creates a “compelling reason to recommend to our management that we go out and try to talk to the chemical engineering community in order to keep our inspectorate well informed and well trained going into the future.”
Jackson asked the speakers if they thought there should be additional chemicals added to the schedules list. Forman replied that there does not seem to be the political will from the member states to do that, and Cupitt said that this is really up to the individual states to define what goes on its control lists. Detlef Maennig added that the chemical industry’s position on this matter is that it is against increasing the number of chemicals on the schedules at the moment unless there is a demonstrated case or there is a risk identified or there is a loophole in the convention. Cupitt also commented that when the U.S. Chemical Facility Anti-Terrorism Standards were released, which included a list of chemicals of interest that included the scheduled compounds, the result was that several thousand chemical facilities changed their processes to get rid of the chemicals that were on the chemicals of interest list. “In essence, they became more proliferation resistant,” said Cupitt.