Chemical Weapons Convention (CWC) Notice of Inquiry

Last week, the Bureau of Industry and Security (BIS) issued a notice of inquiry seeking public comments on the impact that implementation of the Chemical Weapons Convention (CWC) has had on commercial activities involving “Schedule 1” chemicals during 2011. The list of CWC “Schedule 1” chemicals includes several Chemicals of Interest (COIs) found in Appendix A to the Chemical Facility Anti-Terrorism Standards (CFATS). Some of these include, for instance, Sarin, VX, Tabun, Lewsite 1, 2 and 3, Nitrogen Mustards (HN1, HN2, and HN3), and Mustard Gas.

The CWC is an international arms treaty that imposes certain obligations on countries that have ratified the Convention. These obligations include, among others, restricting commercial production of “Schedule 1” chemicals to research, medical, or pharmaceutical purposes. The BIS is therefore interested in public comments to help it determine whether the legitimate commercial activities and interests of U.S. chemical, biotechnology, and pharmaceutical companies are significantly harmed by the CWC limitations on access to, and production of, “Schedule 1” chemicalsAdditionally, the BIS is seeking comment on:

  1. Whether the addition of salts of certain CWC "Schedule 1" chemicals (specifically saxitoxin and nitrogen mustards) to the list of "Schedule 1" chemicals in the CWC Annex on Chemicals would impact commercial activities; and
  2. Whether any U.S. commercial chemical production activities could possibly involve the production of a "Schedule 1" chemical as an intermediate in the synthesis of other chemicals.

Industry’s feedback is critical to developing regulations that mitigate risk of terrorist activity and enhance national security while supporting the legitimate use of these chemicals. You or your organization have an opportunity to provide input, as public comments on this notice of inquiry will be accepted until January 9, 2012.

Ryan Loughin is Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT- www.adtbusiness.com/petrochem. He provides security education to CFATS and MTSA-affected companies and is a member of the National Petrochemical and Refiners Association (NPRA), Society of Chemical Manufacturers and Associates (SOCMA), Energy Security Council (ESC) and American Society for Industrial Security (ASIS). Loughin has also completed multiple levels of CVI Authorized User training (Chemical- Terrorism Vulnerability Information) which was authored by the U.S. Department of Homeland Security.

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