Working Paper by Great Britain : Use of a Simulated Declaration Format in a Practice Visit (WP.251)
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AD HOC GROUP OF THE STATES PARTIES
TO THE CONVENTION ON THE PROHIBITION
OF THE DEVELOPMENT, PRODUCTION AND
STOCKPILING OF BACTERIOLOGICAL
(BIOLOGICAL) AND TOXIN WEAPONS
AND ON THEIR DESTRUCTION
BWC/AD HOC GROUP/WP.251
17 December 1997
Original : ENGLISH
Ninth session
Geneva, 5-23 January 1998
Working paper submitted by the United Kingdom of Great Britain
and Northern Ireland
USE OF A SIMULATED DECLARATION FORMAT IN A PRACTICE VISIT
Introduction
1. The United Kingdom wishes to share its recent experience of the use of a simulated facility declaration format during a practice visit at an industrial facility. The scenario chosen for exercise purposes assumed that the facility had been triggered for a declaration prior to the visit, and that the fermenter pilot plant at the facility concerned had in some way triggered a declaration, although no wording was suggested for the trigger that might have caused this. The broader results of the visit, which are still under discussion, will be reported later to the Ad Hoc Group, but it is already possible to present some preliminary comments on the experience with the simulated declaration format.
The focus of a BTWC declaration at a facility
2. An issue that has yet to be decided by the Ad Hoc Group is how the term "facility" should be defined and differentiated from the term "site" for measures under the Protocol. In the Ad Hoc Group work on declaration formats, one concept suggested is that the information declared by a facility should focus on scientific and technical functions rather than geographic relationships. (See WP.215 and Appendix E) This approach could lead to situations in which a facility triggered for declaration is situated within a large geographically defined site,
GE.97-65297
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operated as an entity for administrative or commercial reasons but where the scientific and technical work relevant for declaration under the Protocol comprises only part of the work at the site.
3. The industrial site at which the United Kingdom practice visit took place was of this type. Our aim was to gain experience of a declaration focusing on scientific and technical attributes. As part of the practice we therefore asked the facility operators to complete a simulated declaration format, which was based closely on the stand-alone trigger approach of the format in Appendix E. (The later section of the format in Appendix E for use with combination triggers was not relevant to the practice visit and was therefore omitted.)
The simulated declaration format used in the practice visit
4. The simulated declaration format used in the practice asked for information on the following:
(a) the triggered function, in this case the pilot plant function of the facility;
(b) any associated scientific or technical functions at the facility, to be considered as functions that are integrated with the triggered function and essential to its aims and objectives and/or to its day to day operation. Examples suggested were parts of the facility that deal with operating records, medical records, quality control tests, health and safety or regulatory aspects of the triggered function.
Since questions in the practice declaration format were explicitly directed at the above focii, this format differed from current Appendix E in that there was no need to define "facility". It was felt that this revised format design would be easier for the declarer to understand whilst achieving the same key objective - focus on the relevant scientific and technical functions at the facility.
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5. Specifically, the simulated declaration format was based on the draft in Appendix E of the rolling text, with the following minor modifications needed for the new explicit foci:
(a) The format asked for an aggregate statement for the triggered function and its associated scientific and technical functions (paragraph 4, (a) and (b) above), in the General Information section (Appendix E, Part A, questions 1-9), now under the following heading:
GENERAL INFORMATION FOR THE TRIGGERED FUNCTION AND ANY ASSOCIATED SCIENTIFIC OR TECHNICAL FUNCTIONS AT THE SAME LOCATION
The same aggregate approach was adopted for the questions on "Scientific and Technical Detail" (Appendix E, questions 13-21), by changing the Appendix E heading "Information for the facility as a whole" to "Information for all the above declared functions at the facility";
(b) The Appendix E questions 10-12 about (scientific) fields of activity were asked twice in the simulated format, once in respect of the triggered function, and once in respect of the associated scientific and technical functions;
(c) Where range questions in existing Appendix E do not yet include suggested range values, we sought to choose values which could discriminate between small, medium and large scales of work but at the same time minimise the reporting burden and also to reduce the chance of inaccurate reporting. For instance, the ranges for staff questions were constructed as
1 / 1-10 / 10s / 100s / 1000s.
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6. An additional question was included at the end of the form to allow a statement about activities at the site other than the triggered function and the associated scientific and technical functions. This question was drafted as follows:
ADDITIONAL INFORMATION FOR SITES COMPRISING FUNCTIONS OTHER THAN THOSE DECLARED ABOVE
22. If the site comprises functions other than those declared above, provide a general description of the type of work at the site as a whole. For example, specify if: military (oriented) R & D, testing or evaluation / other military / commercial R & D / commercial production / university / other educational / other non-profit.
Lessons learned about the declaration format
7. The review of the completed declaration return carried out during the practice visit helped to identify questions in the format, especially among the scientific terms in the fields of activity question 11, that could be misinterpreted by a declarer. Further work to clarify these terms would be worthwhile.
8. One particular problem is that terms used in format questions may in fact already be used by the facility in a slightly different sense. For example, a facility may have put some effort into developing detection, identification or diagnostic techniques, or decontamination / disinfection techniques, in order to set up standard operating procedures for equipment at the facility. In contrast, a declaration format question is likely to be directed not at such techniques, but at techniques being developed for more general application outside the immediate needs of the facility. A question of this type thus needs to be drafted very clearly to avoid misinterpretation by the declarer. It is also clear that any containment terms used in declaration questions will have to be clearly defined, given that the declarer may have used somewhat different national regulations and/or terminology during health and safety assessments of equipment and/or rooms at the facility.
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9. One term that will need particularly careful handling in a declaration format is "production". Industrial practice may be to use "manufacturing" rather than "production" to describe production of items for sale or for subsequent formulation and packaging. Also, at the lower end of the production scale, some additional discriminators such as amounts of media used would be needed to discriminate between questions about laboratory scale growth, that is the type of activity that would only occasionally involve production of up to a few litres of culture, and questions directed at pilot plant scale production.
10. The facility operators understood the focus in the declaration format on triggered and associated activities at the facility, and were able to complete their return, with little effort. Although it is clear from the practice visit that further work needs to be done to achieve a declaration format that is as simple to use and unambiguous as practicable, our experience indicates that an acceptable format concentrating on facility scientific and technical functions associated with a triggered function is a realistic goal.
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