a

GAO

United States General Accounting Office

Report to the Chairman, Committee on 

Armed Services, House of 

Representatives

March 2004 NONPROLIFERATION

Delays in 

Implementing the 

Chemical Weapons 

Convention Raise 

Concerns About 

Proliferation

GAO-04-361
www.gao.gov/cgi-bin/getrpt?GAO-04-361.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Joseph 

Christoff, (202) 512-8979 or 

christoffj@gao.gov. 

Highlights of GAO-04-361, a report to the 

Chairman, Committee on Armed Services, 

House of Representatives 

March 2004

NONPROLIFERATION

Delays in Implementing the Chemical 

Weapons Convention Raise Concerns 

About Proliferation 

The CWC has helped reduce the risks from chemical weapons, but CWC 

member states are experiencing delays in meeting key convention 

requirements as the CWC’s goals have proven more difficult to achieve than 

anticipated. For example, we estimate that Russia and the United States will 

not complete destruction of their chemical weapons stockpiles until after 

the convention’s deadline of 2012, if extended. Less than 40 percent of 

member states have adopted national laws to prosecute individuals that 

pursue CWC-prohibited activities. The Department of State also believes that 

China, Iran, Russia, and Sudan have not fully declared the extent of their 

chemical weapons programs. 

The OPCW faces resource challenges in addressing the proliferation threat 

posed by commercial facilities and inspecting an increased number of 

military facilities that destroy possessor states’ chemical weapons. Although 

the OPCW has conducted nearly 1,600 inspections in 58 member states since 

April 1997, more than half have been conducted at military facilities. About 

36 percent of OPCW commercial inspections have taken place at facilities 

producing the most dangerous chemicals identified by the CWC. The OPCW 

recognizes that it must increase the number of inspections conducted at 

facilities that produce dual-use chemicals. Some of these facilities may pose 

a proliferation threat. 

 

The lack of a credible Russian chemical weapons destruction plan has 

hindered and may further delay destruction efforts, leaving Russia’s vast 

chemical weapons arsenal vulnerable to theft or diversion. As of September 

2003, Russia had one operational destruction facility and had destroyed 1.1 

percent of its 40,000 metric tons of chemical weapons. Russia’s destruction 

efforts rely heavily on international assistance. Since 1993 international 

donors, including the United States, have obligated about $585 million for 

Russian destruction efforts while Russia has spent about $95 million. 

Status of CWC Implementation and Russian Destruction Efforts 1997-2003 

OPCW inspections 

at declared 

commercial facilitiesa

(968 commercial sites)

Russian chemical 

weapons 

to be destroyed: 

 (40,000 metric tons)

Total declared chemical 

weapons to be destroyed 

(70,000 metric tons)

 Number of CWC members 

with comprehensive national 

laws (total of 

158 member countries)

OPCW

inspections

Russian 

chemical weapons 

to be destroyed

Chemical weapons 

to be destroyed

Comprehensive 

national laws

11%

< 40% 36%

Sources: GAO analysis of Department of Defense and OPCW data.

aIncludes only facilities that produce scheduled chemicals as defined by the CWC.

7,700 

metric 

tons– 

amount

destroyed

Less than 

64 countries 

have 

adopted 

laws

351 

commercial

sites 

have been

inspected

1%

455 metric 

tons 

destroyed

The Chemical Weapons Convention 

(CWC) bans chemical weapons and 

requires their destruction by 2007, 

with possible extensions to 2012. 

The CWC also seeks to reduce the 

proliferation of these weapons by 

requiring member states to adopt 

comprehensive national laws to 

criminalize CWC-prohibited 

activities. The Organization for the 

Prohibition of Chemical Weapons 

(OPCW) monitors the destruction 

of chemical weapons and inspects 

declared commercial facilities in 

member states. 

GAO was asked to review (1) 

member states’ efforts to meet key 

convention requirements, (2) 

OPCW’s efforts in conducting 

inspections to ensure compliance 

with the convention, and 

(3) Russia’s efforts to destroy its 

chemical weapons stockpile. 

Agency Comments 

The Departments of State and 

Defense commented that our 

report is not balanced because it 

does not provide more examples of 

successful CWC implementation. 

We believe the CWC has made 

important contributions to 

nonproliferation and further 

clarified this point in this report. 

State and Defense also expressed 

concern that we included a policy 

option to condition future U.S. aid 

on development of a credible 

Russian chemical weapons 

destruction plan. However, we 

provide several policy options, 

including increasing aid to Russia. 
Page i GAO-04-361 Nonproliferation

Contents

Letter 1

Results in Brief 2

Background 4

Member States Are Experiencing Delays in Complying with Key 

CWC Requirements 7

OPCW Conducts Inspections, but Significant Challenges Remain 15

Russia Faces Significant Challenges in Destroying Its Chemical 

Weapons 20

Observations 25

Agency Comments and Our Evaluation 26

Appendixes

Appendix I: Scope and Methodology 29

Appendix II: Location, Number, and Type of Inspections Conducted by the 

OPCW (April 1997 - December 2002) 32

Appendix III: International and Russian Funding for Chemical Weapons 

Destruction at Shchuch’ye 34

Appendix IV: Comments from the Department of State 39

GAO Comments 43

Appendix V: Comments from the Department of Defense 46

GAO Comments 50

Appendix VI: Comments from the Department of Commerce 52

Appendix VII: Comments from the Organization for the Prohibition of 

Chemical Weapons 53

GAO Comment 54

Appendix VIII: GAO Contact and Staff Acknowledgments 55

GAO Contact 55

Acknowledgments 55

Tables Table 1: CWC Possessor States’ Declared Stockpiles and Amount 

Destroyed 7

Table 2: OPCW Inspection Activity at Military Facilities 16

Table 3: OPCW Inspection Activity at Commercial Facilities 17

Table 4: Time Line for Destroying Russia’s Chemical Weapons (as 

of December 2003) 20
Contents

Page ii GAO-04-361 Nonproliferation

Figures Figure 1: Location of Russian Chemical Weapons Stockpiles 9

Figure 2: Location of U.S. Chemical Weapons Stockpiles 12

Figure 3: Chemical Weapons Destruction Facility at Shchuch’ye 35

Figure 4: Construction of the U.S. Destruction Building at 

Shchuch’ye, November 2003 36

Figure 5: Construction of the Russian Destruction Building at 

Shchuch’ye, November 2003 37

Abbreviations

CW chemical weapons

CWC Chemical Weapons Convention

DOC discrete organic chemicals

DOD Department of Defense

OPCW Organization for the Prohibition of Chemical Weapons

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Page 1 GAO-04-361 Nonproliferation

United States General Accounting Office

Washington, D.C. 20548

A

March 31, 2004 Letr

The Honorable Duncan Hunter

Chairman

Committee on Armed Services

House of Representatives

Dear Mr. Chairman:

The Chemical Weapons Convention (CWC) entered into force in April 1997. 

It is the only multilateral treaty that seeks to eliminate an entire category of 

weapons of mass destruction within an established time frame and verify 

their destruction through inspections and monitoring. Specifically, the 

convention bans the production, possession, and use of chemical weapons 

and requires the destruction of chemical weapons stockpiles by 2007 with 

possible extensions to 2012. The CWC also requires member states to adopt 

national laws implementing the convention and to declare their military 

chemical weapons facilities and commercial facilities producing dual-use 

chemicals1

 to the Organization for the Prohibition of Chemical Weapons 

(OPCW). As of March 2004, 161 countries are CWC members, including the 

Russian Federation and the United States. At the CWC’s first review 

conference in spring 2003, some member states expressed concern that 

many member states are not meeting their key CWC obligations. For 

example, Russiathe world’s largest possessor of declared chemical 

weaponsis experiencing delays in destroying its stockpile.

In response to your request, we reviewed (1) member states’ efforts to 

meet key CWC requirements, (2) OPCW’s efforts to conduct inspections to 

ensure compliance with the convention, and (3) Russia’s efforts to destroy 

its chemical weapons stockpile.

In conducting our work, we reviewed the CWC, analyzed verification and 

program documents from the OPCW, and met with OPCW officials. 

Additionally, we met with officials from the Departments of Commerce, 

Defense, and State, as well as member states’ representatives to the OPCW 

at The Hague, the Netherlands. We also obtained information from Russian 

government officials and visited the U.S.-funded chemical weapons 

destruction facility site at Shchuch’ye in Russia. To assess the reliability of 

1

The term “dual use” applies to chemicals that have both military and commercial 

applications.
Page 2 GAO-04-361 Nonproliferation

the data used in the report, we reviewed relevant documents and obtained 

necessary information from agency and government officials. For the 

purposes of our work, we determined that the data are sufficiently reliable. 

We performed our work from April 2003 through March 2004 in accordance 

with generally accepted government auditing standards. (See app. I for the 

details of our scope and methodology.)

Results in Brief Member states are experiencing delays in destroying their chemical 

weapons stockpiles, adopting comprehensive national laws to criminalize 

the possession and use of chemical weapons, and submitting timely and 

accurate declarations of their CWC-related activities. While the CWC has 

played an important role in reducing the risks from chemical weapons, the 

CWC’s nonproliferation goals have proven more difficult to achieve than 

originally anticipated. Specifically, only 11 percent of the 70,000 metric 

tons of declared chemical weapons worldwide has been destroyed, as of 

November 2003. While Russia and the United States possess over 95 

percent of the world’s declared chemical weapons stockpile, they are 

unlikely to meet the convention’s extended deadline of 2012 for destroying 

their respective stockpiles.2

 In addition, less than 40 percent of member 

states have adopted national laws to criminalize CWC-prohibited activities. 

Finally, a 2001 Department of State report assesses that China, Iran, Russia, 

and Sudan have not fully declared the extent of their chemical weapons 

programs. 

Although the OPCW has established a credible inspection regime and 

conducted nearly 1,600 inspections in 58 member states between 1997 and 

2003, the organization faces significant challenges in balancing an 

increased demand for inspections at military and commercial sites with its 

limited resources. The CWC does not specify the number of inspections 

that the OPCW must conduct each year. Since 1997, the OPCW conducted 

over half of its inspections at military facilities. The organization also 

conducted inspections at 514 of the 5,460 declared commercial facilities. 

The OPCW plans to increase the number of inspections conducted at 

commercial facilities, that produce discrete organic chemicals, because 

they may pose a greater proliferation risk than other commercial sites. 

However, it simultaneously faces an increased demand for inspections at 

military destruction facilities. Over the past few years, the OPCW has also 

2

The CWC permits member states to request extensions between 2007 and 2012 for the 

elimination of declared chemical weapons.
Page 3 GAO-04-361 Nonproliferation

experienced financial difficulties. To help overcome the increasing 

demands being placed on its limited resources, the OPCW is working with 

member states to further improve the efficiency of its inspection 

procedures. 

Russia’s efforts to destroy its chemical weapons stockpiles face significant 

challenges. Russia is experiencing delays in destroying its chemical 

weapons stockpile. As of September 2003, Russia had destroyed 1.1 

percent of its total declared chemical weapons stockpile of 40,000 metric 

tons. This compares with the 24 percent already destroyed by the United 

States. In addition, current Russian destruction efforts are reliant upon 

international assistance. As of December 2003, international donors, 

including the United States, Germany, and others,3

 had obligated about 

$585 million and committed more than $1.7 billion toward Russia’s 

chemical weapons destruction. According to the Department of State, 

from 2001 through 2003 Russia budgeted about $420 million for chemical 

weapons demilitarization-related activities. Russia had spent about $95 

million. Furthermore, the lack of a credible Russian chemical weapons 

destruction plan has delayed destruction, and Russian planning efforts to 

date have not included detailed cost and schedule information. Without a 

credible plan, Russian destruction efforts may experience further delays, 

leaving the Russian chemical weapons stockpile vulnerable to theft or 

diversion. 

In commenting on our draft report, the Department of State (State) 

asserted that our report was incomplete, not balanced, and did not provide 

examples of the CWC’s accomplishments. We have added additional 

information to reflect State’s concerns. However, our report acknowledges 

the CWC’s important contribution to addressing the threat posed by 

chemical weapons and the OPCW’s establishment of a credible inspection 

regime. The Department of Defense (DOD) commented that the draft 

report (1) had little analysis of the relative degree of proliferation risk from 

those member states lacking implementing legislation and (2) did not 

present a balanced view of CWC implementation. However, DOD offered 

no criteria for determining which member states pose more of a 

proliferation risk. DOD also provided examples of CWC accomplishments 

in its comments that, while important, are secondary to the primary goal of 

3

Other donors include Canada, the Czech Republic, the European Union, Italy, Norway, 

Switzerland, and the United Kingdom. The Nuclear Threat Initiative is also providing 

assistance.
Page 4 GAO-04-361 Nonproliferation

destroying the world’s entire stockpile of chemical weapons. To ensure 

balance, we have incorporated discussion of these issues in the report. 

State and DOD said that our analysis estimating that Russia may not 

destroy its chemical weapons stockpile until 2027 did not include 

discussion of other options for destroying Russia’s stockpile, such as 

building additional destruction facilities. As of March 2004, only one facility 

capable of destroying nerve agent is under construction in Russia. The 

construction of this U.S-funded facility at Shchuch’ye began 11 years after 

the U.S. and Russia first agreed to build it. The Department of Commerce 

(Commerce) commended our draft report for focusing attention on CWC 

implementation. The OPCW also commended the report for reflecting what 

has been achieved through CWC implementation and recognizing areas 

where challenges still exist. We also received technical comments from 

State, DOD, and Commerce as well as the OPCW and have incorporated 

their comments where appropriate.

Background The CWC is a multilateral arms control treaty that bans the development, 

production, stockpiling, transfer, and use of chemical weapons by member 

countries and requires the declaration and destruction of those countries’ 

existing chemical weapons stocks and production facilities by 2007, with a 

possible extension to 2012. The CWC also monitors the production and 

transfer of chemicals at declared commercial facilities. When the CWC 

entered into force in April 1997, there were 87 member states. As of March 

2004, 161 nations are CWC member states, including Libya. Twenty-one 

countries are signatories but have yet to ratify the treaty.4

 According to the 

State Department, key nonsignatory states include North Korea and Syria, 

which are believed to possess or are actively pursuing chemical weapons 

capabilities.5

4

Those states that have signed but not ratified the CWC are the Bahamas, Bhutan, 

Cambodia, Central African Republic, Comoros, Congo, Democratic Republic of the Congo, 

Djibouti, Dominican Republic, Grenada, Guinea-Bissau, Haiti, Honduras, Israel, Liberia, 

Madagascar, Marshall Islands, Myanmar, Rwanda, Saint Kitts and Nevis, and Sierra Leone.

5

According to the statement by the U.S. Assistant Secretary of State for Arms Control before 

the CWC Review Conference in April 2003, the United States believed that Syria had a 

stockpile of nerve agent and was trying to develop more toxic and persistent nerve agents. 

North Korea has also acquired dual-use chemicals that could potentially be used to support 

its long-standing chemical warfare program.
Page 5 GAO-04-361 Nonproliferation

Upon ratification of the CWC, all member states are required to adopt 

national laws that criminalize CWC-prohibited activities and establish a 

national authority to serve as the national focal point for liaison with the 

OPCW. All members are required to submit initial declarations to the 

OPCW no later than 30 days after entering into the convention and annual 

declarations detailing transfer activities of all declared chemicals no later 

than 90 days after the end of the year. Member states must also declare 

chemical weapons stockpiles and production facilities, relevant chemical 

industry facilities, and other related information such as chemical exports 

and imports. Member states that possess chemical weapons stockpiles and 

production facilities must destroy them by April 2007. Six member states—

Albania, India, Libya, Russia, the United States, and A State Party6

have 

declared their chemical weapons stockpiles and are considered possessor 

states. Eleven member states have declared chemical weapons production 

facilities. 

The OPCW consists of three organsthe Conference of States Parties, the 

Executive Council, and the Technical Secretariatand was established by 

the convention to implement its provisions. The Technical Secretariat 

manages the organization’s daily operations, including the implementation 

of the convention’s verification measures. The Technical Secretariat serves 

as the repository for all member states’ declarations and relies upon 

individual member states to submit accurate, timely, and complete 

declarations. Based on these declarations, the Technical Secretariat 

inspects and/or monitors member states’ military and commercial chemical 

facilities and activities to ensure their compliance with the CWC. Also, if a 

member state suspects another member state of conducting activities 

prohibited by the convention, it may request a challenge inspection of the 

suspected site(s). As of December 2003, no member state has requested the 

OPCW to conduct a challenge inspection. 

6

The OPCW keeps the identity of this member state confidential.
Page 6 GAO-04-361 Nonproliferation

Technical Secretariat inspectors take inventories of the declared stockpiles 

to verify the accuracy of the declarations and ensure that chemical 

weapons are not removed. Inspectors continuously monitor7

 the 

destruction of chemical weapons at operating destruction facilities by 

observing the receipt of chemical weapons at sites and checking the type 

and quantity of chemical weapons destroyed. Inspectors also verify the 

destruction or conversion of declared chemical weapons production 

facilities by observing the destruction of applicable buildings and 

production equipment. So that dual-use chemicals are not diverted from 

their peaceful uses, the Technical Secretariat inspects declared commercial 

production facilities based on three schedules, or lists of chemicals, 

contained in the CWC.8

 Commercial facilities that produce discrete organic 

chemicals, above 200 metric tons, are also subject to inspections. OPCW 

inspectors verify that the types of chemicals being produced are consistent 

with the member states’ declarations. 

Funding for OPCW inspections and other operations comes primarily from 

the 161 member states’ required annual contributions, which are based on 

the United Nations’ scale of assessments. The other major source of 

funding comes from reimbursements of inspections costs paid by chemical 

weapons possessor states. The OPCW is partially reimbursed for 

inspection costs incurred while conducting inspections at declared 

chemical weapons facilities in those countries. The organization, however, 

must fund inspections at commercial facilities and any challenge 

inspections it conducts. The organization’s budget for calendar year 2004 is 

$82.6 million. 

7

The CWC requires the verification of chemical weapons destruction through continuous 

monitoring with on-site instruments and physical presence of inspectors. As such, 

whenever destruction facilities are operational in member states, OPCW inspectors are 

located at the facilities.

8

Schedule 1 chemicals are either chemical weapons or are closely related to chemical 

weapons. Schedule 2 chemicals can be used to make chemical weapons but can also be 

used for peaceful industrial purposes. Schedule 3 chemicals are toxic chemicals that can be 

used to make chemical weapons but are produced on a large scale to make common 

products such as oil, paper, and cloth.
Page 7 GAO-04-361 Nonproliferation

Member States Are 

Experiencing Delays in 

Complying with Key 

CWC Requirements

Although the CWC has helped to reduce the risks from chemical weapons, 

member states are experiencing delays in destroying their chemical 

weapons and implementing key requirements of the treaty. For example, 

Russia and the United States are unlikely to destroy their declared 

chemical weapons by the extended deadline of 2012, and many member 

states have not adopted national laws that fully implement the CWC. In 

addition, some member states have yet to provide the OPCW with complete 

and timely declarations detailing their CWC-related activities. 

Complete Destruction of 

Largest Possessor States’ 

Chemical Weapons 

Stockpiles Will Extend 

beyond Deadline 

 We estimate that the United States and Russia are unlikely to meet the 2012 

extended CWC deadline for destroying their chemical weapons. Three 

other possessor states—Albania, India, and A State Party—possess smaller 

stockpiles and are expected to destroy their stockpiles by the original April 

2007 deadline (see table 1). In addition, Libya became the sixth possessor 

state in February 2004 when it became a member of the CWC and declared 

that it possessed chemical weapons. According to OPCW officials and 

CWC possessor states, the destruction of chemical weapons has proven 

more complex, costly, and time consuming than originally anticipated.

Table 1: CWC Possessor States’ Declared Stockpiles and Amount Destroyed

Source: GAO analysis of information provided by DOD and State, OPCW, and chemical weapons possessor states.

Note: The amount of stockpile declared applies only to the most dangerous chemical weapons, known 

as category 1.

a

Projected data are GAO analysis based on declared stockpiles and destruction facilities currently in 

operation or under construction.

b

The amounts of the declared stockpiles are considered confidential by the OPCW and For Official Use 

Only by the U.S. government.

Possessor state

Amount of stockpile 

declared

(metric tons)

Stockpile 

destroyed, 

September 2003

(percent)

Projected date for 

complete 

destruction

Russian Federation 40,000 1.1 2027a

United States 27,771 24 2014a

Albania b 0 2007

India b 39 2007

A State Party b 29 2007

Libya 23 0 unknown
Page 8 GAO-04-361 Nonproliferation

Russia currently possesses the world’s largest declared chemical weapons 

stockpile at 40,000 metric tons stored at seven sites, as shown in figure 1. 

The stockpile includes 32,500 metric tons of nerve agent, the most toxic of 

all known chemical agents, and 7,500 metric tons of blister agent.9

 As we 

have previously reported, DOD has installed security upgrades at 

Shchuch’ye and Kizner, the two sites with portable nerve agent munitions. 

However, a large quantity of Russia’s chemical weapons will remain 

vulnerable to theft or diversion until they are destroyed.10 As of September 

2003, Russia had destroyed 1.1 percent of its total CWC-declared stockpile.

9

Blister agents can be lethal if inhaled but generally cause slow-to-heal burns on contact 

with skin. These agents are considered less of a threat to U.S. national security interests. 

10U.S. General Accounting Office, Weapons of Mass Destruction: Additional Russian 

Cooperation Needed to Facilitate U.S. Efforts to Improve Security at Russia Sites, GAO03-482 (Washington, D.C.: March 24, 2003).
Page 9 GAO-04-361 Nonproliferation

Figure 1: Location of Russian Chemical Weapons Stockpiles

Hami

Karamay

K hi

Korla

Yumen

Aktyubinsk

Aralsk

Atbassar

Balqash

Rudnyy

Altay

Dalandzadag

Hovd

Antipayuta

Bratsk

Igarka

Murmansk

Nizhnevartovsk

Norilsk

Vorkuta

Dudinka

Urumqi

Qaraghandy

Constanta

Irkut

Krasnodar

Krasnojarsk

Novosibirsk Omsk

Frunze

iv

Alma

Bishkek Ata

Minsk

ki

ga

aunas

rest

Ankara

Kiev

Tashkent

Astana

NLAND RUSSIA

A

ARIA

ELARUS

UKRAINE

MOLDOVA

A

ONIA

ARMENIA

AZERBAIJAN

GEORGIA

KYRGYZSTAN

RUSSIA

KAZAKHSTAN

TURKMENISTAN

UZBEKISTAN

Gorny

Maradykovsky

RUSSIA

Leonidovka

Kambarka

Kizner Shchuch'ye

Pochep

Moscow

1000 kilometers

Declared chemical weapons storage facilities

Sources: DOD (data); Nova Development and Map Resources (images). 

Pochep

Leonidovka

Maradykovsky

Kambarka

Large nerve munitions

Small nerve munitions

Bulk blister

Shchuch'ye

Kizner

Gorny 2.8%

Chemical weapons storage facility

Destruction facility

13.6%

15.9%

14.1%

17.4%

17.4%

18.8%
Page 10 GAO-04-361 Nonproliferation

Russia did not meet the original treaty deadline to destroy 1 percent of its 

stockpile by April 2000. In accordance with treaty provisions, Russia 

requested and received an extension of its 1-percent and 20-percent 

deadlines from the OPCW.11 In April 2003, Russia met the one percent 

destruction deadline. Based on information provided by DOD, we estimate 

that Russia may not destroy its declared chemical weapons stockpile until 

2027. Our analysis is predicated on Russia’s complete destruction of its 

approximately 7,500 metric tons of blister agent by the 2007 deadline and 

destroying the remaining 32,500 metric tons of nerve agent at the U.S. 

funded destruction facility at Shchuch’ye. In September 2003, Russia 

agreed to complete the elimination of all of its nerve agent at the 

Shchuch’ye destruction facility, which is scheduled to begin operations in 

2008. According to DOD, the Shchuch’ye facility may not be operational 

until 2009. For Russia to meet an extended April 2012 deadline, Russia 

would have to destroy about 9,100 metric tons of nerve agent per year. 

Operating at maximum capacity, the facility is estimated to destroy about 

1,700 metric tons of nerve agent per year.12 At that rate, unless the capacity 

for destruction is increased or additional destruction facilities are built, the 

complete destruction of Russia’s stockpile may not occur until 2027.13 (We 

discuss other options for destroying Russia’s nerve agent stockpile later in 

this report.)

11The OPCW extended Russia’s 1-percent deadline from April 2000 to May 31, 2003 and its 

20-percent deadline from April 2002 to April 2007. Russia also submitted requests to extend 

its 45-percent and 100-percent deadlines. As of October 2003, specific dates for these 

deadlines had not been agreed upon.

12According to DOD, the destruction rate for the Shchuch’ye facility applies to the munitions 

stored at Shchuch’ye and Kizner and may not apply to the bulk agent stored at 

Maradykovsky, Leonidovka, and Pochep. Our analysis is based on the capacity of the 

destruction facilities that are currently operational or under construction.

13Based on our discussion with Russian government officials, Russia may construct three 

additional chemical weapons destruction facilities.
Page 11 GAO-04-361 Nonproliferation

The United States possesses the second largest declared chemical weapons 

stockpile with 27,771 metric tons, which is stored at eight sites, as shown in 

figure 2. Currently, the United States is operating three destruction 

facilities; three additional facilities will be operational in the near future 

and two more will begin construction. As of December 2003, the United 

States destroyed 24 percent of its declared stockpile and met the 1-percent 

and 20-percent interim deadlines within the treaty time frames. However, 

the United States requested and received an extension of the 45-percent 

deadline from April 2004 to December 2007. The United States will not 

meet the 100-percent April 2007 destruction deadline and may not meet the 

2012 deadline, if extended,14 based on the current schedule. According to 

DOD, one U.S. chemical weapons destruction facility is not scheduled to 

complete its destruction operation until 2014. Persistent delays have 

occurred due to plant safety issues, environmental requirements, and 

funding shortfalls. We have previously reported on the significant 

management challenges in the U.S. chemical demilitarization program, as 

well as concerns over cost growth and schedule delays. As noted in our 

prior work, the U.S. chemical weapons demilitarization program spent 

$11.4 billion by the end of fiscal year 2003, which accounts for nearly half of 

the program’s life-cycle cost estimate of $24 billion.15

14According to DOD, the United States has received “in principle” an extension of its 100-

percent deadline to April 2012 and will request a formal extension of its 100-percent 

deadline by April 2006. 

15U.S. General Accounting Office, Chemical Weapons: Sustained Leadership, Along with 

Key Strategic Management Tools, Is Needed to Guide DOD’s Destruction Program, GAO03-1031 (Washington, D.C.: September 2003).
Page 12 GAO-04-361 Nonproliferation

Figure 2: Location of U.S. Chemical Weapons Stockpiles

Note: As of November 2003, all chemical weapons at Johnston Atoll have been destroyed and the 

destruction facility has been dismantled.

Oreg.

Utah

Colo. Ky.

Ala.

Md.

Ind.

Ark.

UNITED STATES

Deseret 

Chemical 

Depot

Umatilla 

Chemical 

Depot

Pueblo 

Chemical 

Depot

Johnston 

Atoll

Pine Bluff 

Chemical 

Activity

Newport 

Chemical 

Depot

Blue Grass 

Chemical 

Activity

Anniston 

Chemical 

Activity

Edgewood 

Chemical 

Activity

Umatilla, Oreg.

Pine Bluff, Ark.

Anniston, Ala.

Johnston Atoll 2 % Blue Grass, Ky. 2%

Pueblo, Colo.

Aberdeen, Md. 5%

Tooele, Utah

Newport, Ind. 4%

Chemical weapons storage facility

Destruction facility

Blister

and nerve

Blister

Nerve

Sources: DOD (data); Nova Development and Map Resources (images). 

45%

13%

12%

8%

9%

Declared chemical weapons storage facilities
Page 13 GAO-04-361 Nonproliferation

Three other possessor statesAlbania, India, and A State Partyaccount 

for about 3 percent of the global declared chemical weapons stockpile and 

are anticipated to meet the CWC complete destruction time line by April 

2007. With smaller stockpiles than those in Russia and the United States, 

these countries have had less difficulty meeting their deadlines. Albania 

declared its stockpile to the OPCW in 2003, and the United States is 

providing assistance to destroy its chemical weapons stockpile. Other 

nations, including Canada and Italy, may also provide assistance. State 

officials estimate that Albania will meet the 2007 destruction deadline. 

According to Indian officials, India has the third largest stockpile after 

Russia and the United States; however, information on its chemical 

weapons destruction program is not publicly available. The fifth possessor 

state, A State Party, experienced interim delays due to technical difficulties. 

It requested and received an extension of its 45-percent chemical weapons 

destruction deadline in 2003. According to government officials, it remains 

on track to meet the 2007 deadline. Libya, the sixth possessor state, has 

just declared its chemical weapons to the OPCW and has yet to develop a 

destruction plan for its stockpile.

Many Member States Have 

Yet to Adopt National Laws 

Implementing the CWC

According to the OPCW, less than 40 percent of CWC member states have 

adopted national laws to criminalize CWC-prohibited activities. Although 

the treaty does not establish a time line for the adoption of such measures, 

according to the OPCW, member states are expected to implement these 

laws soon after ratifying the convention. OPCW officials stated that many 

member states lack sufficient legal expertise and financial resources to 

adopt the required laws. At the 2003 CWC Review Conference, however, 

the United States launched an initiative to assist all CWC member states in 

adopting comprehensive national laws. The effort culminated in an OPCW 

action plan to help member states adopt necessary laws by 2005.

According to the OPCW, 126 member states have designated a national 

authority to collect and submit their declarations. However, OPCW and 

State officials estimate that a large number of member states’ national 

authorities are not effective because they lack sufficient financial and 

human resources. National authorities are important in implementing the 

treaty because they facilitate member states’ ability to submit accurate and 

timely declarations to the OPCW and host OPCW inspections. To 

encourage member states to improve the effectiveness of their national 

authorities, the OPCW hosts workshops to identify common problems and 

assist member states in addressing them accordingly.
Page 14 GAO-04-361 Nonproliferation

Some Member States Have 

Submitted Incomplete or 

Late Declarations

According to a 2001 Department of State report, four CWC member 

statesChina, Iran, Sudan, and Russiahad not acknowledged the full 

extent of their chemical weapons program.16 The CWC requires member 

states to fully and accurately declare their chemical weapons capabilities. 

However, State believes that China maintains an active chemical weapons 

research and development program, a possible undeclared chemical 

weapons stockpile, and weapons-related facilities that were not declared to 

the OPCW.17 Iran has not submitted a complete and accurate declaration 

and is seeking to retain and modernize key elements of its chemical 

weapons program, according to the report. Sudan established a research 

and development program with a goal to produce chemical weapons 

indigenously. The report also assesses that Russia has not divulged the full 

extent of its chemical agent and weapons inventory. State views Russia’s 

declaration of its chemical weapons production, development facilities, 

and chemical agent and weapons stockpiles as incomplete. In addition, 

State reported that Russia may have knowledge of a new generation of 

agents that could circumvent the CWC and possibly defeat western 

detection and protection measures. The significance of this issue was 

addressed at the 2003 CWC Review Conference. The Director-General of 

the OPCW urged member states to provide accurate and complete 

declarations to increase transparency and confidence in the treaty.

Furthermore, member states have been late in submitting their required 

initial and annual declarations to the OPCW. As of December 2002, nearly 

97 percent of all member states submitted their initial declarations, but a 

large percentage of member states did not submit their initial declarations 

within the required 30-day time frame. The OPCW also engaged in bilateral 

consultations to assist member states in submitting their initial 

declarations. As of October 2003, nearly one-third of member states had 

failed to submit their annual declarations in a timely manner. According to 

the OPCW, delays in submitting the required declarations make it difficult 

for the organization to plan its annual inspections and track chemical 

transfers.

16The U.S. government also has concerns about other member states’ CWC compliance; 

however, the identities of these countries remain classified.

17See U.S. Department of State, Adherence to and Compliance with Arms Control and 

Nonproliferation Agreements and Commitments, Washington, D.C., 2001. 
Page 15 GAO-04-361 Nonproliferation

OPCW Conducts 

Inspections, but 

Significant Challenges 

Remain

The OPCW has established a credible inspections regime. Between 1997 

and 2003, the OPCW conducted nearly 1,600 inspections in 58 member 

states. However, the organization faces significant challenges as it prepares 

to balance an increased number of inspections at both military and 

commercial facilities with its limited resources. The CWC does not specify 

the number of annual inspections that the OPCW is required to conduct. 

Since April 1997, more than half of OPCW inspections have taken place at 

military facilities even though some commercial facilities may pose a 

greater proliferation threat. To meet the increased demands on its limited 

resources, the OPCW is working with member states to further improve the 

efficiency of its inspection activities. 

OPCW Implementing CWC 

Inspection Regime 

From April 1997 through December 2003, the OPCW’s Technical Secretariat 

has conducted nearly 1,600 inspections at both military and commercial 

chemical facilities in 58 member states. (See app. II for a chart depicting 

the locations of inspections conducted.18) According to OPCW officials and 

member states’ representatives we interviewed, inspections are proceeding 

as planned under the CWC. Within the United States, officials from the 

State, DOD, and Commerce, as well as chemical industry representatives, 

stated that the United States and OPCW inspectors work cooperatively to 

implement the inspection regime. When questions or concerns arise, the 

Technical Secretariat and the affected member state(s) work to resolve 

them. For example, the United States and the OPCW have resolved issues 

such as clarifying which portions of declared commercial facilities are 

subject to inspection. According to DOD, OPCW inspectors have good 

access to declared sites and facilities.

As of December 2003, the Technical Secretariat conducted 965 inspections 

at 167 of 190 declared military sites. The military sites that have not been 

inspected are either chemical weapons production facilities destroyed 

prior to CWC entry into force or sites having old or abandoned chemical 

weapons. Although the CWC requires that OPCW maintain a continuous 

presence at member states’ sites when chemical weapons are being 

destroyed, it does not specify how many inspections are to be conducted 

annually. The Technical Secretariat determines how many inspections to 

18The data contained in appendix II reflect inspections conducted as of December 2002 

because the OPCW could not provide more current data until it has been approved by the 

CWC member states. 
Page 16 GAO-04-361 Nonproliferation

conduct annually based on the number of military facilities declared by 

member states, member states’ annual destruction plans, annual 

declarations, and the annual OPCW budget documents. The greatest 

number of inspections has taken place at chemical weapons destruction 

facilitiesprimarily in the United States, Russia, and India. About one-third 

of all inspections conducted by the Technical Secretariat have taken place 

in the United States, mostly at chemical weapons destruction facilities. 

Table 2 shows the number of inspections conducted at different types of 

facilities at military sites from April 1997 through December 2003. 

Table 2: OPCW Inspection Activity at Military Facilities

Source: OPCW data.

a

“Abandoned chemical weapons” refers to those left by one country (after January 1, 1925) on the 

territory of another country without the consent of the latter.

b

“Old chemical weapons” refers to those produced before 1925 or those produced between 1925 and 

1946 that have deteriorated to such an extent that they cannot be used as weapons.

Between April 1997 and December 2003, Technical Secretariat officials 

conducted 634 inspections at 514 sites among the 5,460 commercial 

facilities declared by member states (see table 3). Because the CWC does 

not specify the specific number of inspections to be conducted each year, 

the Technical Secretariat selects the facilities it will inspect based on those 

requiring initial inspections and the potential proliferation risk of facilities. 

The annual budget document specifies the number of inspections to be 

conducted. Since April 1997, most OPCW commercial inspections have 

taken place at facilities that produce chemicals listed on the CWC’s three 

schedules. Of the declared 4,492 facilities that produce discrete organic 

chemicals (DOC), the organization has inspected 163. DOC facilities 

produce a wide range of common commercial chemicals and may also be 

CWC military 

facility inspection 

requirements

Declared sites or 

facilities, as of 2003

Inspections, as of 

December 2003

Sites inspected, 

1997-2003

CW production 

facilities 61 298 63

CW destruction 

facilities 39 376 26

CW storage 

facilities 33 219 34

Abandoned CWa 15 22 17

Old CWb 42 50 27

Total 190 965 167
Page 17 GAO-04-361 Nonproliferation

capable of producing chemical weapons. According to U.S. government 

and OPCW officials, such dual-use DOC facilities may pose a proliferation 

threat because they may conceal CWC-prohibited activities. Most 

significantly, these DOC facilities may be modified to produce scheduled 

and other chemicals that are not specifically listed on current CWC 

schedules but are still banned by the CWC, if intended for prohibited 

purposes. In commenting on a draft of our report, the OPCW provided 

clarification of this proliferation issue. While the majority of commercial 

facilities produce discrete organic chemicals, the OPCW estimates that less 

than 20 percent of these DOC sites may pose highly relevant proliferation 

risks.

Table 3: OPCW Inspection Activity at Commercial Facilities

Source: OPCW data. 

a

Schedule 1 chemicals are either chemical weapons or are closely related to chemical weapons.

b

Schedule 2 chemicals can be used to make chemical weapons but can also be used for peaceful 

industrial purposes. These chemicals are not produced in large quantities.

c

Schedule 3 chemicals are toxic chemicals that can be used to make chemical weapons but are also 

produced on a large scale to make products such as oil, cement, cloth, and paper.

d

DOCs cover a wide range of chemicals that are not listed in the Schedules but could be used to 

produce chemical weapons.

OPCW Faces Significant 

Challenges in Conducting 

More Inspections

Although the OPCW has made progress in conducting inspections as 

mandated by the convention, it faces challenges in meeting an increase in 

its inspection workload. As possessor states’ destruction activities 

increase over the next few years, the OPCW will have to maintain a 

continuous inspection presence at more facilities. Concurrently, the OPCW 

wants to increase the number of inspections it conducts at commercial 

CWC required 

inspections at 

commercial 

facilities

Declared sites or 

facilities as of 

December 2003

Inspections as of 

December 2003

Number of sites 

inspected, April 1997- 

December 2003

Schedule 1 

chemicalsa 27 123 34

Schedule 2 

chemicalsb 432 233 202

Schedule 3 

chemicalsc 509 115 115

DOCd 4,492 163 163

Total 5,460 634 514
Page 18 GAO-04-361 Nonproliferation

DOC facilities to address proliferation concerns. However, the OPCW has 

experienced financial difficulties over the past few years. To better meet 

the increased demand on its resources, the OPCW is working with member 

states to find more efficient and cost-effective means of conducting its 

inspection activities. 

The OPCW projects that the number of chemical weapons destruction 

facilities that will require monitoring will increase from seven to nine by 

2007. Under the CWC, OPCW inspectors must maintain a continuous 

onsite presence at chemical weapons destruction facilities to monitor and 

verify the destruction of chemical weapons stockpiles. According to OPCW 

officials, the organization is reimbursed for about two-thirds of the 

expenses it incurs during such inspections.19 OPCW inspection costs will 

increase, if the organization maintains a continuous on-site presence at the 

additional chemical weapons destruction sites that will begin operations in 

the near future. However, the Technical Secretariat and member states are 

currently discussing possible monitoring alternatives that may reduce costs 

without compromising the credibility of the inspections.

According to the OPCW, the organization is working to increase the 

number of inspections it conducts at commercial DOC facilities to address 

the proliferation risks they pose. In 2002, for example, 32 of 85 commercial 

inspections conducted were at DOC facilities. In 2004, the OPCW plans to 

increase the number of DOC facility inspections to 70 out of a total of 150 

inspections planned at commercial facilities. Furthermore, OPCW and 

member states20 are working to refine the current criteria used to select 

DOC facilities for inspections to ensure that the selection process takes 

into account all factors mandated by the CWC. 

19The OPCW is reimbursed for all the operational expenses and roughly one-third of the 

inspector salary costs for chemical weapons inspections at military facilities in chemical 

weapons possessor states.

20A U.S.-Swiss proposal to clarify guidance on how the Technical Secretariat should 

implement paragraphs 11(b) and 11(c) of the CWC’s verification annex is currently being 

discussed.
Page 19 GAO-04-361 Nonproliferation

Due to budget deficits in 2001 and 2002, the Technical Secretariat had to 

reduce the number of inspections it planned to conduct at commercial 

chemical facilities. Such deficits were mostly the result of member states’ 

late payment of their annual assessments and reimbursements for military 

inspections.21 When funding was limited, the OPCW could not reduce the 

number of inspections at destruction facilities because inspectors are 

required to continuously monitor these sites when operational. Instead, it 

reduced the number of commercial inspections it conducted. In 2001, the 

OPCW conducted 57 percent (75 of 132) of its planned inspections at 

commercial sites. For 2002, it conducted 64 percent (85 of 132) of its 

planned inspections. Although previous financial difficulties caused a 

reduction in the number of inspections, the Technical Secretariat 

completed its planned number of 132 commercial inspections for 2003. 

Member states approved a more than 6-percent increase in the OPCW’s 

budget for 2004. According to OPCW officials, such budget increases are 

unlikely to continue in future years, and the problem of late receipt of 

member states’ annual assessments and reimbursements will likely 

reoccur.

To meet the increased demand for inspections, the Technical Secretariat is 

working to improve the efficiency of its inspection activities. The 

organization has reduced the size of inspection teams at military sites, 

thereby lowering daily allowance and travel costs. For example, the team 

size for most inspections conducted at chemical weapons storage facilities 

was reduced from eight in 2002 to six in 2003. The Technical Secretariat has 

also devised new contracts for inspectors of chemical weapons destruction 

facilities that permit hiring part-time inspectors for 1 year. When 

implemented, such contracts could reduce staff costs and provide for more 

flexibility in assigning inspection teams. The OPCW and member states are 

also exploring greater use of monitoring and recording instruments at 

chemical weapons destruction facilities to reduce the number of inspectors 

needed on-site. Cost-saving measures have also been proposed and 

implemented to increase the efficiency of inspections conducted at 

commercial facilities, including reducing the size of inspection teams and 

the time they spend on-site. 

21U.S. General Accounting Office, Chemical Weapons: Organization for the Prohibition of 

Chemical Weapons Needs Comprehensive Plan to Correct Budgeting Weaknesses, GAO-03-

5 (Washington, D.C.: Oct. 24, 2002).
Page 20 GAO-04-361 Nonproliferation

Russia Faces 

Significant Challenges 

in Destroying Its 

Chemical Weapons

Russia is experiencing delays in destroying its chemical weapons. As of 

September 2003, Russia had destroyed 1.1 percent of its 40,000 metric tons 

of chemical weapons at its only operational destruction facility. Russian 

destruction efforts have also relied almost entirely on international 

assistance. As of December 2003, international donors have shipped about 

$585 million and committed more than $1.7 billion to Russian destruction 

efforts. According to State, from 2001 through 2003 Russia budgeted about 

$420 million for chemical weapons demilitarization-related activities. 

Russia spent about $95 million. However, based on its current destruction 

efforts and the international assistance committed, Russia will not meet the 

extended CWC destruction deadline of 2012. Furthermore, Russia has yet 

to develop a comprehensive destruction plan that includes the types of 

projects and funding needed to completely destroy its declared stockpile, 

which may further delay destruction efforts.

One−Percent Milestone 

Achieved at Gorny; Two 

Additional Facilities under 

Construction

Russia plans to destroy its chemical weapons stockpiles at Gorny, 

Kambarka, and Shchuch’ye, primarily using assistance provided by 

Germany and the United States. Russia has yet to develop a credible plan to 

destroy the remaining 50-percent of its chemical weapons stockpile stored 

at Maradykovsky, Leonidovka, and Pochep. Table 4 provides the time line 

for Russia’s destruction efforts at facilities in operation or under 

construction.

Table 4: Time Line for Destroying Russia’s Chemical Weapons (as of December 2003)

Source: GAO analysis of DOD, State, and German government data.

a

Russia plans to destroy all nerve agent located at Shchuch’ye and Kizner at the Shchuch’ye facility.

Location of 

destruction facilities

Estimated date for 

completing 

destruction facility

Estimated start of 

destruction

Estimated end of 

destruction

Type of agent to 

be destroyed

Amount of 

chemical weapons 

to be destroyed 

(metric tons)

Gorny August 2002 December 2002 December 2005 Blister 1,120 

Kambarka December 2005 December 2005 December 2009 Blister 6,360 

Shchuch’ye September 2008 September 2008 After 2012 Nervea 11,080 
Page 21 GAO-04-361 Nonproliferation

Gorny and Kambarka to Destroy 

All Blister Agent

Russia is relying on German assistance to destroy its stockpile of blister 

agent at the Gorny and Kambarka facilities. According to DOD, Germany 

focused its assistance in this area because it had experience destroying 

World War II blister agents. As of September 2003, Russia destroyed 455 

metric tons of blister agent (1.1 percent of the Russian stockpile) stored at 

the Gorny facility. Russia will destroy the remaining stockpile at Gorny by 

December 2005, according to a German official. Russia constructed the 

building for the destruction facility, while Germany spent about $58 million 

from 1993 to 2003 to equip the facility.22 Germany has committed $120 

million for the Kambarka destruction facility, currently under construction, 

and up to $300 million in additional funds, according to a German 

government official. The facility at Kambarka will destroy the entire 

stockpile of blister agent located there by December 2009. The 

construction schedule of this facility may be delayed, according to a 

German government official overseeing the assistance. 

Shchuch’ye Will Destroy 30 

Percent of Russia’s Chemical 

Weapons Stockpile 

Once operational, the Shchuch’ye chemical weapons destruction facility 

will begin to destroy nerve agent from two Russian storage sites that house 

nearly 30 percent of the total Russian stockpile.23 The storage facilities at 

Kizner and Shchuch’ye each house about 5,500 metric tons of nerve agent 

stored in projectiles and rockets. According to DOD and State officials, the 

United States has focused its assistance to Russia at Shchuch’ye because 

these chemical weapons are portable and thus vulnerable to theft and 

diversion.

The United States has agreed to pay for the destruction facility at 

Shchuch’ye.24 The facility is scheduled to destroy the nerve agent 

stockpiles located at both the Shchuch’ye and Kizner storage sites. DOD’s 

Cooperative Threat Reduction program has obligated more than $460 

million on planning, design, and construction of the facility. In October 

2003, DOD updated the costs and schedule for completing the Shchuch’ye 

facility and projected that the cost would increase from about $888 million 

22From 2000 to 2003, the European Union also provided $6 million for the Gorny facility. 

Both the German and European Union figures are expressed in constant 2003 dollars.

23The Shchuch’ye storage site is located about 10 miles from the destruction facility. The 

chemical weapons stored at Kizner are located more than 450 miles from the Shchuch’ye 

destruction facility. Nerve agent from each location will be sent to Shchuch’ye by rail.

24The United States plans to finance the construction of all buildings within the facility, 

except for one destruction building, which the Russians will fund.
Page 22 GAO-04-361 Nonproliferation

to more than $1 billion. DOD also noted that the operation of the facility 

may be delayed from September 2008 to July 2009. DOD attributes the 

increased cost to changed site conditions, new requirements, risk factors, 

and delays due to lack of U.S. funding for 2 years caused by Russia’s 

inability to meet U.S. congressional conditions. Once operational, the 

facility is estimated to destroy 1,700 metric tons of chemical weapons per 

year. With a July 2009 operational date, we estimate that the destruction of 

chemical weapons stored at Shchuch’ye and Kizner will not be completed 

until at least 2016. (For more detailed information on international 

assistance for chemical weapons destruction at Shchuch’ye, see app. III.) 

Russian Plans for 

Destroying Remainder of Its 

Nerve Agent Stockpile Are 

Unknown

In November 2003, the Director of the Russian Munitions Agency informed 

us that Russia has not yet decided how it will destroy the remaining nerve 

agent stored at Maradykovsky, Leonidovka, and Pochep. This nerve agent 

represents over 50 percent of the total Russian chemical weapons 

stockpile. In September 2003, the United States and Russia amended a 

March 2003 agreement under which the Russian Munitions Agency agreed 

to complete the elimination of all nerve agent at the Shchuch’ye destruction 

facility, unless otherwise agreed in writing. According to DOD and Russian 

government officials, there is uncertainty whether Russia will comply. 

Russian officials have concerns about the costs and risks of transporting 

the weapons from these sites to Shchuch’ye, most of which are located 

more than 500 miles away. As a result, Russian officials have indicated that 

Russia may construct three chemical weapons neutralization facilities for 

the nerve agent stored at Maradykovsky, Leonidovka, and Pochep. Under 

this option, Russia would neutralize the chemical weapons at the three 

sites so the agent would be safe for transport, and then complete the 

destruction process at Shchuch’ye. This would require the construction of 

three neutralization facilities plus new destruction capacity at Shchuch’ye, 

because the neutralized agent would likely be destroyed using a different 

process than the unneutralized agent from the Shchuch'ye and Kizner sites. 

In November 2003, however, Italy agreed to commit funding for the 

construction of a destruction facility at Pochep.25

25According to DOD, Italy has committed up to 360 million euros from 2004 to 2008 for the 

construction of the facility.
Page 23 GAO-04-361 Nonproliferation

International Donors Assist 

Russian Chemical Weapons 

Destruction

While Germany and the United States have obligated about $515 million 

and committed an additional $1 billion for Gorny, Kambarka, and 

Shchuch’ye, other donors have spent about $70 million at these sites.26

Furthermore, in June 2002, the Group of Eight launched the Global 

Partnership initiative, which was designed to prevent the proliferation of 

weapons of mass destruction to terrorists and their supporters. Among 

other projects in Russia, the initiative is currently assisting with chemical 

weapons destruction.27 As of December 2003, international donors, 

including the United States, Germany, Canada, Italy, and the United 

Kingdom, 28 have committed more than $1.7 billion for Russian chemical 

weapons destruction. 

Lack of Plan May Hinder 

Russia’s Progress in 

Destroying Chemical 

Weapons 

Congress has conditioned U.S. funding for the Shchuch’ye facility on a 

Secretary of Defense certification that Russia has developed a practical 

chemical weapons destruction plan.29 In September 2003, Russia signed an 

agreement with the United States to provide a chemical weapons 

destruction plan by March 2004. The plan would include the types of 

projects and funding needed to completely destroy its declared chemical 

weapons. Officials from State and DOD were not optimistic that the 

Russians will deliver a plan within the required time. 

According to State and DOD officials, Russia’s planning efforts to date have 

been based on inaccurate assumptions and have lacked detailed 

information on how the destruction of chemical weapons will occur at each 

site. For example, Russian officials have stated that they expect the 

Shchuch’ye chemical weapons destruction facility to be operational in 

2006, despite DOD estimates that it may take until July 2009. DOD officials 

stated that additional time is needed to procure and install the equipment 

needed for the destruction facility.

26Donors to Shchuch’ye include Canada, Italy, and the United Kingdom.

27Other priority concerns of the Global Partnership initiative include plutonium disposition, 

nuclear submarine dismantlement, and employment of former weapons scientists in Russia.

28In addition, the Czech Republic, the European Union, Norway, Switzerland, and the 

Nuclear Threat Initiative are also providing assistance.

29In accordance with Public Law 108-136, Sec. 1306, the President exercised his authority to 

waive congressional stipulations and continue funding of the Shchuch’ye facility.
Page 24 GAO-04-361 Nonproliferation

In addition, Russia’s plans need greater specificity. Russia has provided 

some information to the United States regarding the following:

• where the chemical weapons will be destroyed,

• when they will be destroyed and the amounts at each location, 

• costs for each facility, and

• how each facility will contribute to the destruction efforts.

According to officials from State and DOD, the information provided does 

not appear credible and lacks key elements. Russia has not provided the 

method, schedule, and cost for transporting its chemical weapons to the 

destruction facility at Shchuch’ye. In addition, Russia has no credible plan 

to destroy the nerve agent at Maradykovsky, Leonidovka, and Pochep. 

Russian officials indicated that the nerve agent may be neutralized at each 

site but did not provide any details regarding what would be needed to 

undertake such an effort, including a plan to dispose of the toxic chemicals 

resulting from the neutralization process. 

Russia’s chemical weapons destruction efforts at Pochep, Leonidovka, and 

Maradovski may be further complicated by Russia’s definition of 

destruction, which differs from that of the United States and the OPCW. 

The CWC defines destruction of chemical weapons as an essentially 

irreversible process.30 The United States and the OPCW maintain that 

chemical weapons are not destroyed until the materials resulting from the 

destruction process are essentially irreversible (i.e., can no longer be 

reversed back to chemical weapons) and the remaining materials can be 

inspected by the OPCW. The United States neutralizes some of its chemical 

weapons in a two-phase process that first neutralizes the agent and then 

transports the resulting hazardous waste to a commercial chemical facility 

for final disposition. The OPCW inspects both phases of the neutralization 

process. Russian officials maintain that chemical weapons should be 

considered destroyed after the initial neutralization phase and not require 

further processing or OPCW inspections. Russian officials argue that, 

30Under the CWC, the destruction of chemical weapons is defined as “a process by which 

chemicals are converted in an essentially irreversible way to a form unsuitable for 

production of chemical weapons, and which in an irreversible manner renders munitions 

and other devices unusable.”
Page 25 GAO-04-361 Nonproliferation

although toxic chemicals resulting from the neutralization process could be 

reverted to chemical weapons, the cost to do so would be prohibitive. 

Russia raised this issue at the May 2003 CWC Review Conference, but 

OPCW member states maintained that complete destruction should be an 

essentially irreversible process as specified in the CWC. Despite this 

opposition, Russian government officials at the Russian Munitions Agency 

and the Ministry of Foreign Affairs stated in November 2003 that they 

consider initial neutralization equivalent to destruction. 

Observations The CWC has played an important role in reducing the risks from chemical 

weapons. Member states have destroyed more than 7,700 metric tons of 

chemical weapons and the OPCW has established a credible inspection 

regime that has inspected many military and commercial chemical facilities 

in 58 countries. Nearly 7 years after entry into force, the CWC’s 

nonproliferation goals have proven more difficult to achieve than originally 

anticipated. CWC member states and the OPCW face difficult choices in 

addressing the delays in Russia’s destruction program, the limited number 

of inspections at dual-use commercial sites, and the slow progress in 

passing laws criminalizing CWC-prohibited activities. Decision-makers 

will have to make some combination of policy changes in these areas if the 

CWC is to continue to credibly address nonproliferation concerns 

worldwide. 

First, the destruction of chemical weapons will likely take longer and cost 

more than originally anticipated. Even with significant international 

assistance, Russia may not destroy its declared chemical weapons until 15 

years beyond the extended CWC deadline. Russia’s large stockpile will thus 

remain vulnerable to theft and diversion. Several options exist, however, 

for the United States and other donors to reduce the proliferation risks 

from Russia’s chemical weapons stockpile. Such options may include (1) 

increasing funding for security improvements at Russia’s chemical 

weapons storage sites, (2) deferring financing for Russia’s chemical 

weapons destruction effort until the Russian government develops a 

credible destruction plan, or (3) financing the construction of additional 

destruction facilities.

Second, technical advancements in the chemical industry and the 

increasing number of dual-use commercial facilities worldwide challenge 

the CWC and the OPCW’s ability to deter and detect proliferation. Member 

states will need to determine the best policies for addressing potential 

proliferation at dual-use commercial facilities. CWC member states could 
Page 26 GAO-04-361 Nonproliferation

decide that the OPCW should conduct more commercial inspections, 

which would require member states to provide more funding and subject 

their national chemical industries to additional inspections. Alternatively, 

member states may determine that the current level of commercial 

inspections is sufficient to detect and deter activities prohibited by the 

CWC.

Third, many member states have not yet adopted national laws to fully 

implement the convention, or have not submitted complete and accurate 

declarations of their CWC-related activities. These problems undermine 

confidence in overall treaty compliance. It is important for the OPCW and 

member states to reinforce member states’ obligations to adopt national 

laws, enforce them accordingly, and submit accurate and timely 

declarations. Challenge inspections may also be a vehicle to ensure 

member states’ compliance with the CWC.

Agency Comments and 

Our Evaluation

We obtained written comments on a draft of this report from State, DOD, 

Commerce, and the OPCW, which are reprinted in appendixes IV, V, VI, and 

VII respectively. We also received technical comments from the 

departments as well as the OPCW, which we have incorporated where 

appropriate. In commenting on our draft report, State asserted that our 

report was misleading, incomplete, and not balanced. State did not 

provide specific examples but instead claimed that the report omitted 

positive CWC accomplishments such as growth in the number of member 

states, correction of OPCW management inefficiencies, and OPCW 

execution of the CWC inspection regime. In response, we agree that the 

CWC has played an important role in reducing the threat posed by chemical 

weapons and the report acknowledges this accomplishment. With regard 

to State’s comment about the growth in the number of CWC member states, 

the report focuses on CWC implementation among already existing 

member states. For clarification however, we have provided additional 

information on the increase in CWC membership since entry into force. 

Secondly, State commented that the report did not assess OPCW 

management corrections. In this report we reviewed OPCW’s efforts to 

conduct inspections, not the management of the organization. We had 

previously reported on this topic in October 2002.31 Thirdly, the report 

31U.S. General Accounting Office, Chemical Weapons: Organization for the Prohibition of 

Chemical Weapons Needs Comprehensive Plan to Correct Budgeting Weaknesses,

GAO-03-5 (Washington, D.C.: Oct. 24, 2002).
Page 27 GAO-04-361 Nonproliferation

clearly articulates that the OPCW has established a credible inspection 

regime and has conducted nearly 1,600 inspections in 58 member states. 

While this report discusses several important delays in CWC 

implementation, it still acknowledges that the CWC and OPCW have made 

important contributions to addressing the threat posed by chemical 

weapons.

DOD commented that our draft report had little analysis of the relative 

degree of proliferation risk from those member states lacking 

implementing legislation. DOD, however, does not offer what criteria one 

would use to make a determination about which member states are more 

important to CWC implementation. As stated in the report, the CWC 

requires all member states to adopt national implementing legislation. In 

addition, DOD believes that the report is not conducive to providing a 

balanced perspective because it does not acknowledge successes in 

implementing the CWC. For example, DOD cites that progress has been 

made in eliminating former chemical weapons production facilities and 

destroying category 2 and 3 chemical weapons related munitions. Such 

successes, however, remain secondary to the CWC’s primary goal of 

destroying actual chemical weapons. As stated in this report, the CWC is 

the only multilateral treaty that seeks to eliminate an entire category of 

weapons of mass destruction under an established time frame and verify 

their destruction through inspections. DOD also asserts that the report 

does not recognize the significant changes occurring within the OPCW. As 

mentioned previously, this report does not assess OPCW functions or 

performance because we conducted such a review of the OPCW in October 

2002. This report does, however, credit the OPCW with finding more 

efficient and cost-effective means of conducting its inspection activities as 

it faces the challenge of meeting an increased inspection workload. We 

have included additional information in this report to further clarify the 

achievements of the CWC and the OPCW. 

Both DOD and State commented that our analysis estimating that Russia 

may not destroy its chemical weapons stockpile until 2027 was misleading. 

We have clarified our presentation of this analysis to include a discussion 

of other options being considered for destroying Russia’s stockpile. As of 

March 2004, only one facility capable of destroying nerve agent is being 

constructed in Russia. Although plans to build additional facilities are 

being discussed, we note that construction of the U.S-funded facility at 

Shchuch’ye began 11 years after the U.S. and Russia first agreed to build it. 
Page 28 GAO-04-361 Nonproliferation

Commerce commended the report for focusing attention on the important 

issue of member states’ achieving compliance with the CWC. The 

department noted that the U.S. government has taken a leading role at the 

OPCW in promoting an action plan to ensure all member states’ adoption of 

national law implementing the CWC and is providing assistance to member 

states to achieve this goal.

The OPCW commended the draft report for reflecting what has been 

achieved through CWC implementation and recognizing areas where 

challenges still exist. It noted, however, that some statements as presented 

in the report do not reflect the views of the Technical Secretariat.

As arranged with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days after the 

date of this letter. At that time we will send copies of this report to the 

Secretaries of State, DOD, and Commerce; the Director-General of the 

OPCW; and other interested congressional committees. We will also make 

copies available to others upon request. In addition, this report will be 

available free of charge on the GAO Web site at http://www.gao.gov.

Please contact me at (202) 512-8979 if you or your staff have any questions 

concerning this report. Another GAO contact and staff acknowledgments 

are listed in appendix VIII.

Sincerely yours,

Joseph A. Christoff, Director

International Affairs and Trade
Page 29 GAO-04-361 Nonproliferation

Appendix I

Scope and Methodology ApApenednxidexiIs

To determine what efforts member states have made in meeting key 

Chemical Weapons Convention (CWC) requirements, we compared these 

requirements with documents obtained from the Organization for the 

Prohibition of Chemical Weapons (OPCW) and the Department of State 

(State), including annual reports that assess member states’ compliance 

with the treaty, surveys assessing the status of member states’ compliance 

with key requirements, and member states’ official statements to the 2003 

CWC Review Conference. We also obtained information from OPCW 

officials including the Director-General, the Deputy Director-General, the 

Administration Division, the Verification and Inspectorate Division, and the 

Office of Internal Oversight, as well as member states’ representatives to 

the OPCW in The Hague.1

 To assess the reliability of the OPCW data 

regarding whether the member states are meeting their CWC requirements, 

which include the destruction of chemical weapons, we reviewed 

numerous OPCW and U.S. government documents, interviewed OPCW and 

U.S. officials, and examined OPCW's procedures for ensuring data 

reliability. We determined that the OPCW data was sufficiently reliable for 

the purposes of this engagement. In addition, we met with officials from 

State’s Bureau of Arms Control, the Bureau of Nonproliferation, the Bureau 

of Verification and Compliance, and the Bureau of Intelligence and 

Research in Washington, D.C., and with representatives of the intelligence 

community. We also met with officials at the U.S. Mission to the OPCW at 

The Hague. To obtain information on how the CWC is implemented in the 

United States we attended the June 2003 Defense Threat Reduction 

Agency’s CWC Orientation Course held in Fairfax, Virginia.

To assess the OPCW’s efforts in conducting inspections to ensure 

compliance with the convention, we analyzed the CWC and various OPCW 

documents including Verification and Implementation Reports, annual 

budgets, and other reports. In The Hague, we met with Director-General, 

the Deputy Director-General, of the OPCW, and with officials from the 

Administration Division and the Verification and Inspectorate Division. We 

also visited the inspection laboratory and equipment store at Rijswijk, The 

Netherlands. To assess the reliability of the OPCW data regarding the 

number of inspections being conducted in the CWC member states, we 

reviewed numerous OPCW and U.S. government documents, interviewed 

OPCW and US officials, and examined OPCW's procedures for ensuring 

1

During our visit to the OPCW in September 2003, we met with representatives from “A State 

Party,” Albania, China, the Czech Republic, Finland, France, Germany, India, Italy, Japan, 

Malaysia, Norway, the Russian Federation, and the United Kingdom.
Appendix I

Scope and Methodology

Page 30 GAO-04-361 Nonproliferation

data reliability. We determined that the OPCW data was sufficiently 

reliable for the purposes of this engagement. To assess member states’ 

experiences with OPCW inspections, we spoke with numerous member 

states’ representatives to the OPCW. We also met with officials at the U.S. 

Mission to the OPCW at The Hague. In addition, we met with officials from 

State’s Bureau of Arms Control, the Bureau of Nonproliferation, and the 

Bureau of Verification and Compliance. To obtain an understanding of how 

OPCW inspections are conducted at military chemical weapons-related 

facilities in the United States, we met with Department of Defense (DOD) 

officials from the Defense Threat Reduction Agency. We also toured the 

U.S. chemical weapons destruction facility in Aberdeen, Maryland. To 

obtain an understanding of how OPCW inspections are conducted at 

commercial chemical facilities in the United States, we met with 

Department of Commerce officials from the Bureau of Industry and 

Security, Office of Nonproliferation Controls and Treaty Compliance, as 

well as representatives from the American Chemistry Council.

In reviewing Russia’s efforts to destroy its chemical weapons stockpile, we 

visited the Russian Federation and obtained information from Russian 

government officials at the Chamber of Accounts, the Russian Munitions 

Agency, and the Ministry of Foreign Affairs. We also met with 

representatives from the Russian Duma who have funding authority over 

Russian chemical weapons destruction. In addition, we traveled to 

Shchuch’ye to observe the U.S.-funded chemical weapons destruction 

facility and surrounding infrastructure projects. While in Shchuch’ye, we 

spoke with local government officials and the Cooperative Threat 

Reduction program funded contractor responsible for building the 

Shchuch’ye facility. We obtained information from officials in the Bureau of 

Nonproliferation and the Bureau of Arms Control in the Department of 

State. At DOD, we met with officials and acquired documents from the 

Office of the Secretary of Defense for Cooperative Threat Reduction Policy 

and the Defense Threat Reduction Agency, which set policy and manage 

the implementation of CTR assistance to the Shchuch’ye facility. We also 

obtained information on international donors commitments for Russian 

chemical weapons destruction efforts from DOD and government 

representatives from Canada, Germany, and the United Kingdom. We 

obtained data from a variety of sources on the funding and assistance 

provided for Russian chemical weapon destruction efforts. To assess the 

reliability of these data, we interviewed officials from the United States, 

Canada, France, Germany, Great Britain, Italy, Russia, and the OPCW. We 

also asked these officials to corroborate other nations’ data wherever 

possible. In addition, we cross-checked the data on funding to Russia that 
Appendix I

Scope and Methodology

Page 31 GAO-04-361 Nonproliferation

we were given by our different sources. We determined that data on 

funding and assistance provided for Russian chemical weapon destruction 

were sufficiently reliable for the purposes of this engagement.

The information on foreign law in this report does not reflect our 

independent legal analysis, but is based on interviews and secondary 

sources. We performed our work from April 2003 through March 2004 in 

accordance with generally accepted government auditing standards.
Page 32 GAO-04-361 Nonproliferation

Appendix II

Location, Number, and Type of Inspections 

Conducted by the OPCW (April 1997 - 

December 2002) ApendxiI

Member state CWPF CWDF CWSF ACW OCW Schedule 1 Schedule 2 Schedule 3 DOC Total

A State Partya 102

Algeria 3 3

Argentina 4 4

Australia 3 1 41 9

Austria 1 1 2

Belarus 1 2 3

Belgium 2 3 1 3 2 11

Bosnia and 

Herzegovina 2 2

Brazil 2 31 6

Bulgaria 1 12 4

Canada 2 5 5 12

Chile 1 2 3

China 2 16 10 21 9 1 59

Costa Rica 1 1

Croatia 4 4

Czech Republic 2 5 7

Denmark 1 1

Estonia 2 2

Federal 

Republic of 

Yugoslavia 2 2 1 5

Finland 72 3 12

France 10 6 5 18 7 46

Germany 15 29 7 51

Hungary 4 1 5

India 21 38 13 4 2 7 85

Iran 2 1 1 5 9

Ireland 3 2 5

Italy 2 5 23 3 33

Japan 5 4 4 24 8 1 46

Lithuania 1 1

Mexico 1 2 3

Morocco 2 2

Netherlands 4 7 21 14

New Zealand 1 2 3
Appendix II

Location, Number, and Type of Inspections 

Conducted by the OPCW (April 1997 - 

December 2002)

Page 33 GAO-04-361 Nonproliferation

Source: OPCW.

Notes:

CWPF = chemical weapons production facility

CWDF = chemical weapons destruction facility

CWSF = chemical weapons storage facility

ACW = abandoned chemical weapons

OCW = old chemical weapons

DOC = discrete organic chemicals

The inspection data contained in the table is through December 2002 because the OPCW could not 

provide more current data until it has been approved by the CWC member states. Also, the table does 

not include inspections of the destruction of hazardous chemical weapons or the emergency 

destruction of chemical weapons in the United States and Russia. 

a

The OPCW considers the inspection details for A State Party to be confidential.

Norway 51 4 10

Panama 1 1

Poland 1 3 5 9

Romania 3 3 6

Russian 

Federation 106 35 35 3 1 1 181

Saudi Arabia 2 2

Singapore 2 12 5

Slovak Republic 4 1 3 8

Slovenia 3 3

South Africa 6 12 9

Spain 433 10

Sweden 4 1 11 7

Switzerland 3 11 3 17

Turkey 1 3 4

Ukraine 5 5

United Kingdom 20 6 9 12 5 52

United States 86 219 75 3 13 31 3 430

Uzbekistan 1 1 2

Total 257 292 123 20 43 99 197 89 94 1,316

(Continued From Previous Page)

Member state CWPF CWDF CWSF ACW OCW Schedule 1 Schedule 2 Schedule 3 DOC Total
Page 34 GAO-04-361 Nonproliferation

Appendix III

International and Russian Funding for 

Chemical Weapons Destruction at Shchuch’ye ApendxiI

As of December 2003, the United States and other international donors 

have obligated about $525 million to develop, build, and support a chemical 

weapons destruction facility at Shchuch’ye. Russia has spent about $95 

million.1 These funds support three related areas of effort: (1) the design 

and construction of the destruction facility, (2) the completion of 

infrastructure located outside the destruction facility necessary for its 

operation, and (3) community improvement projects in the town of 

Shchuch’ye. 

When completed, the Shchuch’ye chemical weapons destruction facility 

will comprise a complex of about 100 buildings and structures designed to 

support and complete the destruction of the chemical weapons stored at 

Shchuch’ye and Kizner, which represents about 30-percent of Russia’s total 

stockpile. The United States, through the Department of Defense’s (DOD) 

Cooperative Threat Reduction program, has obligated more than $460 

million for the design, construction, equipment acquisition and installation, 

systems integration, training, and start-up of the facility.2

 The United States 

plans to spend a total of more than $1 billion to finance the construction of 

99 of the 100 buildings and structures within the facility, including one 

building where the chemical munitions will be disassembled and the 

chemical agent destroyed. Russia has agreed to fund the construction of a 

second destruction building at an estimated cost of $150 million to $175 

million, according to a DOD official. Russia spent an estimated $6 to $8 

million for the construction of the second destruction building.

3

 Figure 3 

illustrates the buildings and structures within the destruction facility at 

Shchuch’ye.

1

Since 2001, Russia has allocated at least $25 million per year at Shchuch’ye, satisfying a 

Congressional condition for U.S. assistance.

2

This includes funding for a Russian chemical analytical lab but does not include funding for 

demilitarizing former Russian chemical weapons production facilities and securing Russian 

chemical weapons stockpiles.

3

According to DOD and Russian officials, international donors may provide assistance for 

construction of the Russian destruction building at Shchuch’ye.
Appendix III

International and Russian Funding for 

Chemical Weapons Destruction at Shchuch’ye

Page 35 GAO-04-361 Nonproliferation

Figure 3: Chemical Weapons Destruction Facility at Shchuch’ye

In March 2003, the United States began construction of the Shchuch’ye 

facility. Figure 4 shows the completed foundation work for the U.S. 

destruction building as of November 2003. Prior DOD estimates indicated 

that the facility would begin destroying chemical weapons in August 2008. 

However, in October 2003, DOD stated the facility may not be operational 

until July 2009.

Administration 

building

Bituminization 

building

Chemical gas 

storage

Waste storage 

area

Boiler house 

area

Site-wide 

underground 

utilities, waste 

water, electrical 

distribution

Administration 

area

Water treatment 

area

Water 

circulation

Transformer 

substation

Fire station 

area

Gas rescue 

area

Destruction 

building

Destruction 

building

Source: Department of Defense.

Russian funded

U.S. funded
Appendix III

International and Russian Funding for 

Chemical Weapons Destruction at Shchuch’ye

Page 36 GAO-04-361 Nonproliferation

Figure 4: Construction of the U.S. Destruction Building at Shchuch’ye,

November 2003

Based on the U.S. design, Russia also began constructing its destruction 

building at the Shchuch’ye complex in 2003, according to a DOD official, 

but Russia has not provided a completion date for its destruction building.

Figure 5 shows the uncompleted foundation work on the Russian funded 

destruction building, as of November 2003.

Source: GAO.
Appendix III

International and Russian Funding for 

Chemical Weapons Destruction at Shchuch’ye

Page 37 GAO-04-361 Nonproliferation

Figure 5: Construction of the Russian Destruction Building at Shchuch’ye, 

November 2003

The operation of the chemical weapons destruction facility at Shchuch’ye 

depends upon the completion of several infrastructure projects, such as the 

installation of natural gas and water lines and an electric distribution 

station. As of October 2003, Russia had spent more than $56 million to 

support those projects. International donors have spent about $65 million 

for these and other infrastructure projects, such as the construction of 

access roads.

4

 About $66 million of infrastructure projects, including the 

installation of sewage and fiber optic lines, remain unfunded. In September 

2003, Russia signed an agreement with the United States stating that it 

would complete all necessary infrastructure to support initial testing of the 

Shchuch’ye facility. 

4

International donors include Canada, the Czech Republic, the European Union, Italy, 

Norway, the Nuclear Threat Initiative, and the United Kingdom.

Source: GAO.
Appendix III

International and Russian Funding for 

Chemical Weapons Destruction at Shchuch’ye

Page 38 GAO-04-361 Nonproliferation

In addition, Russian and U.S. officials stated that the town of Shchuch’ye 

lacks adequate housing, schools, roads, and other services to support the 

expected influx of destruction facility workers and their families. As of 

October 2003, the Russian government had spent more than $31 million for 

a variety of community improvement projects in Shchuch’ye, including a 

new school, improved medical facilities, and new housing. 
Page 39 GAO-04-361 Nonproliferation

Appendix IV

Comments from the Department of State ApendxiIV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix IV

Comments from the Department of State

Page 40 GAO-04-361 Nonproliferation

See comment 1.

See comment 2.

See comment 3.
Appendix IV

Comments from the Department of State

Page 41 GAO-04-361 Nonproliferation

See comment 5.

See comment 6.

See comment 7.

See comment 4.
Appendix IV

Comments from the Department of State

Page 42 GAO-04-361 Nonproliferation

See comment 8.
Appendix IV

Comments from the Department of State

Page 43 GAO-04-361 Nonproliferation

The following are GAO’s comments on the Department of State letter dated 

March 19, 2004.

GAO Comments 1. State asserts that this report did not sufficiently present positive CWC 

accomplishments such as the continuous growth in the number of CWC 

member states, the identification and correction of management 

inefficiencies at the OPCW, and the effective implementation of the 

OPCW inspection regime. In response, we included additional 

information in this report to acknowledge the growth in the number of 

member states. We also cite that Libya, the sixth possessor state, 

acceded to the CWC in February 2004. This report does not discuss the 

management of the OPCW, as we previously reported on the 

management of the organization under the leadership of the former 

Director-General, Jose Bustani.1

 We did not review the management of 

the OPCW under the current Director-General, Rogelio Pfirter but 

acknowledge that he is committed to implementing management 

reforms. Finally, this report clearly articulates that the OPCW has 

established a credible inspection regime.

2. State concluded that the entry into force of the CWC caused two 

previously unknown stockpiles to be discovered and accelerated 

chemical weapons destruction efforts. In its comments, however, State 

did not identify the member states that possess the unknown 

stockpiles. 

3. State cites that of the 158 member states, 56 of 61 member states with 

CWC-declarable facilities have adopted national laws. This statement 

implies that only countries with CWC-declarable facilities should adopt 

national implementing laws. As stated in the report, the CWC requires 

all member states to adopt national implementing laws. Assistant 

Secretary of State for Arms Control stated in his remarks to the 2003 

CWC Review Conference that the lack of national implementing laws 

among member states is troubling “in light of the efforts of Al Qaeda 

and other terrorist organizations to acquire chemical weapons.”

1

U.S. General Accounting Office, Chemical Weapons: Organization for the Prohibition of 

Chemical Weapons Needs Comprehensive Plan to Correct Budgeting Weaknesses, GAO-03-

5 (Washington, D.C.: Oct. 24, 2002).
Appendix IV

Comments from the Department of State

Page 44 GAO-04-361 Nonproliferation

4. State indicated that Russia budgeted roughly $420 million for all of its 

chemical weapons demilitarization-related activities between 2001 and 

2003 and that Russia’s approved 2004 budget requests about $180 

million more. We have included this additional information in the 

report, as it was not previously provided to us.

5. State contends that our estimated deadline of 2014 for the complete 

destruction of the U.S. chemical weapons stockpile is unsubstantiated. 

The department further asserts that our 2027 estimate for the 

completion of Russia’s chemical weapons destruction assumes a single 

nerve agent destruction facility, at Schuch’ye and that we omit the 

possibility of constructing additional destruction facilities. We have 

clarified the 2014 deadline by adding information citing a U.S. chemical 

weapons destruction facility schedule that indicates that the facility 

will not complete its destruction operations until 2014. While we 

acknowledge that Russia may construct additional destruction 

facilities, our analysis is based on the destruction capacity of the one 

nerve agent destruction facility currently under construction. At this 

time, there are no other nerve agent destruction facilities under 

construction and no definitive plans for building additional facilities. 

Furthermore, Russia has agreed to eliminate all nerve agent at 

Shchuch’ye, unless otherwise agreed in writing. In a March 2004 

congressional testimony, the Deputy Undersecretary of Defense for 

Technology Security Policy and Counterproliferation stated that the 

Shchuch’ye facility “will destroy all of Russia’s nerve agent inventory.” 

While Russian officials have indicated that Russia may construct 

neutralization facilities at Pochep, Leonidovka, and Maradovski, a 

detailed plan and/or cost estimates have yet to be provided. 

6. State contends that the option of delaying further assistance to Russia 

could result in a greater proliferation threat. State implies that we are 

only presenting one option, when in fact this report provides numerous 

options, including providing additional assistance for Russian chemical 

weapons destruction. Furthermore, Congress has previously exercised 

the option of withholding U.S. assistance for Russian chemical 

weapons destruction.

7. State claims that facilities that produce discrete organic chemicals 

(DOC) are of little or no proliferation concern to the CWC. However, 

information we obtained from State, Commerce, DOD, and the OPCW, 

contradicts this statement. Officials and documents from all four 

organizations clearly expressed concern over the potential 
Appendix IV

Comments from the Department of State

Page 45 GAO-04-361 Nonproliferation

proliferation risks from DOC facilities. This report, therefore, indicates 

that these facilities produce a wide range of common commercial 

chemicals and may be capable of producing chemical weapons. 

8. State cites that this report omits the fact that all existing chemical 

weapons production, storage, and destruction facilities have been 

inspected multiple times. To further clarify the inspection information 

contained in this report, we have included the information.
Page 46 GAO-04-361 Nonproliferation

Appendix V

Comments from the Department of Defense ApendxiV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix V

Comments from the Department of Defense

Page 47 GAO-04-361 Nonproliferation
Appendix V

Comments from the Department of Defense

Page 48 GAO-04-361 Nonproliferation

See comment 1.

See comment 2.

See comment 3.
Appendix V

Comments from the Department of Defense

Page 49 GAO-04-361 Nonproliferation

See comment 4.

See comment 5.
Appendix V

Comments from the Department of Defense

Page 50 GAO-04-361 Nonproliferation

The following are GAO’s comments on the Department of Defense letter 

dated March 18, 2004.

GAO Comments 1. DOD stated that this report provides little or no analysis to conclude 

how many of those member states lacking implementing legislation 

truly pose a proliferation risk. In its comments, however, DOD does not 

offer what criteria one would use to make a determination about which 

member states are more important to CWC implementation. As stated 

in this report, the CWC requires all member states to adopt national 

implementing legislation after ratifying the convention.

2. According to DOD, this report does not give the visibility it should have 

to some of the central nonproliferation aspects of the CWC, such as a 

discussion of the proliferation risks associated with discrete organic 

chemical facilities. This report includes a specific discussion of how 

such dual-use facilities pose a proliferation threat because they may 

conceal CWC-prohibited activities. This report does not further 

elaborate on the degree of proliferation posed by these facilities as 

such information is classified.

3. DOD believes that this report is not conducive to providing a balanced 

perspective because it does not acknowledge successes in 

implementing the CWC. For example, DOD cites that progress has 

been made in eliminating former chemical weapons production 

facilities and destroying category 2 and 3 chemical weapons related 

munitions. Such successes, while important, remain secondary to the 

CWC’s primary goal of destroying actual chemical weapons. As stated 

in the report, the CWC is the only multilateral treaty that seeks to 

eliminate an entire category of weapons of mass destruction under an 

established time frame and verify their destruction through inspections. 

DOD also asserts that this report does not recognize the significant 

changes occurring within the OPCW. This report does not assess OPCW 

functions or performance because we conducted such a review of the 

OPCW in October 2002. This report does, however, credit the 

organization with finding more efficient and cost-effective means of 

conducting its inspection activities as it faces the challenge of meeting 

an increased inspection workload. In addition, we have provided 

information in this report to further clarify that OPCW inspectors have 

access to declared facilities and that there are now 161 member states 

to the OPCW, including Libya.
Appendix V

Comments from the Department of Defense

Page 51 GAO-04-361 Nonproliferation

4. DOD raised a concern about this report’s option to delay financial 

assistance for Russia’s destruction program. The report provides a 

variety of policy options for decision-makers including providing more 

financial assistance to finance the construction of additional 

destruction facilities in Russia. Furthermore, Congress has restricted 

U.S. assistance for Russian chemical weapons destruction in the past.

5. DOD stated that this report does not adequately point out that two 

additional stockpiles have been added to the list of chemical weapons 

being destroyed. In its comments, however, DOD did not identify the 

member states that possess these stockpiles. If DOD had provided 

clarification, such information could have been included in this report, 

provided that the information was not classified.
Page 52 GAO-04-361 Nonproliferation

Appendix VI

Comments from the Department of 

Commerce ApendxiVI
Page 53 GAO-04-361 Nonproliferation

Appendix VII

Comments from the Organization for the 

Prohibition of Chemical Weapons ApendxiVI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.
Appendix VII

Comments from the Organization for the 

Prohibition of Chemical Weapons

Page 54 GAO-04-361 Nonproliferation

The following is GAO’s comment on the Organization for the Prohibition of 

Chemical Weapons’ letter dated March 25, 2004.

GAO Comment 1. We made changes to this report to accurately reflect the technical 

comments we received from the OPCW.
Page 55 GAO-04-361 Nonproliferation

Appendix VIII

GAO Contact and Staff Acknowledgments ApendxiVI

GAO Contact David Maurer (202) 512-9627

Acknowledgments In addition to the individual named above, Beth A. Hoffman León, Nanette 

J. Ryen, Julie A. Chamberlain, and Lynn Cothern made key contributions to 

this report. Etana Finkler and Pierre R. Toureille also provided assistance.

(320186)
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