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Kevin J. Kurland Director Treaty Compliance Division U.S. Department of Commerce

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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Kevin J. Kurland Director Treaty Compliance Division U.S. Department of Commerce

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  1. CWC Industry Compliance Program: Problems and Resolutions in Preparing Industry Declarations Kevin J. Kurland Director Treaty Compliance Division U.S. Department of Commerce

  2. Topics of Discussion • Components of a successful industry compliance program • Declaration problems and resolutions • Advantages of a robust declaration compliance program

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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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