a

GAO

United States Government Accountability Office

Report to Congressional Requesters

October 2005 NUCLEAR 

NONPROLIFERATION

IAEA Has 

Strengthened Its 

Safeguards and 

Nuclear Security 

Programs, but 

Weaknesses Need to 

Be Addressed

GAO-06-93
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-06-93.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gene Aloise at 

(202) 512-3841or aloisee@gao.gov. 

Highlights of GAO-06-93, a report to 

congressional requesters 

October 2005

NUCLEAR NONPROLIFERATION

IAEA Has Strengthened Its Safeguards 

and Nuclear Security Programs, but 

Weaknesses Need to Be Addressed 

IAEA has taken steps to strengthen safeguards, including conducting more 

intrusive inspections, to seek assurances that countries are not developing 

clandestine weapons programs. IAEA has begun to develop the capability to 

independently evaluate all aspects of a country’s nuclear activities rather 

than only verifying the peaceful use of a country’s declared nuclear material. 

IAEA is also taking steps to improve the management of the safeguards 

program. However, despite successes in uncovering some countries’ 

undeclared nuclear activities, safeguards experts cautioned that a 

determined country can still conceal a nuclear weapons program. 

IAEA faces challenges that limit its ability to implement strengthened 

safeguards. First, about two-thirds of NPT signatories have not brought the 

Additional Protocol, which is designed to give the agency new authority to 

search for clandestine nuclear activities, into force. Second, safeguards are 

significantly limited or not applied to many NPT signatories because they 

possess small quantities of nuclear material or they have not concluded a 

comprehensive safeguards agreement. Third, IAEA faces a looming human 

capital crisis caused by the large number of inspectors and safeguards 

management personnel expected to retire in the next 5 years. Finally, IAEA 

does not have a system in place to measure how effective its strengthened 

safeguards system is in detecting undeclared nuclear activities. 

For 2004, the United States is providing $45.3 million to support IAEA 

safeguards in assessed and voluntary cash contributions—over 34 percent of 

IAEA’s safeguards budget. In addition, various U.S. agencies provided an 

estimated $27.2 million in technical support. IAEA’s reliance on voluntary 

contributions, particularly from the United States, will continue despite the 

agency’s recent budget increase. Finally, the agency does not have a process 

in place to systematically evaluate long-term resource requirements. 

IAEA has increased its efforts to help countries improve the physical 

protection of nuclear materials and facilities, secure other radioactive 

materials, and respond to acts of terrorism. In 2002, IAEA established a 

Nuclear Security Fund to which countries have voluntarily contributed $36.7 

million. However, IAEA’s reliance on these voluntary funds creates 

budgetary challenges, and State Department officials raised concerns about 

the agency’s inability to measure the results of its efforts. 

IAEA Inspectors Performing Safeguards Duties 

Source: IAEA.

The International Atomic Energy 

Agency’s (IAEA) safeguards system 

has been a cornerstone of U.S. 

efforts to prevent nuclear weapons 

proliferation since the Treaty on 

the Non-Proliferation of Nuclear 

Weapons (NPT) was adopted in 

1970. IAEA has strengthened its 

safeguards system and increased 

efforts to combat nuclear terrorism 

by helping countries secure nuclear 

and radioactive material and 

facilities. This report (1) identifies 

the steps IAEA has taken to 

strengthen safeguards, (2) assesses 

the challenges in implementing 

strengthened safeguards, (3) 

identifies U.S. financial support for 

safeguards, and (4) describes 

IAEA’s efforts to help secure 

nuclear material and facilities. 

What GAO Recommends

GAO recommends, among other 

things, that the Department of State

work with IAEA to consider (1) 

eliminating or reducing the number 

of agreements that limit IAEA’s 

authority to implement 

strengthened safeguards in 

countries with small quantities of 

nuclear material, (2) establishing 

better measures to evaluate the 

effectiveness of safeguards and 

nuclear security activities, and (3) 

rectifying human capital practices 

that negatively impact IAEA’s 

ability to recruit and retain critical 

safeguards staff. The Department 

of State generally agreed with our 

recommendations. IAEA provided 

technical comments, which we 

incorporated into the report. 
Page i GAO-06-93 Nuclear Nonproliferation

Contents

Letter 1

Results in Brief 4

Background 7

IAEA Has Taken Steps to Strengthen Safeguards, but Detecting 

Clandestine Nuclear Weapons Programs Is Not Assured 9

IAEA Faces Challenges That Impede Its Ability to Effectively 

Implement Strengthened Safeguards 22

IAEA Depends Heavily on U.S. Financial Support to Meet Its 

Safeguards Obligations 34

IAEA Has Increased Efforts to Help Countries Protect Their Nuclear 

Material and Facilities, but Reliance on Voluntary Contributions 

Poses a Challenge 47

Conclusions 56

Recommendations for Executive Action 58

Agency Comments and Our Evaluation 59

Appendixes

Appendix I: Scope and Methodology 62

Appendix II: Countries’ Safeguards Agreements with IAEA That Are In 

Force, as of July 2005 67

Appendix III: Comments from the Department of State 73

Appendix IV: GAO Contact and Staff Acknowledgments 79

Tables Table 1: Contributions to IAEA’s Safeguards Budget from 1998 

through 2004 36

Table 2: U.S. Nuclear Security Fund Contributions, 2002–2004 51

Figures Figure 1: Types of Information Used by IAEA to Verify Countries’ 

Compliance with Their Safeguards Obligations 15

Figure 2: Status of the Additional Protocol by Country 24

Figure 3: U.S. Contributions to IAEA’s Safeguards Program for 

2004 35
Contents

Page ii GAO-06-93 Nuclear Nonproliferation

Abbreviations

DOD Department of Defense

DOE Department of Energy

EURATOMEuropean Atomic Energy Community

IAEA International Atomic Energy Agency

NPT Treaty on the Non-Proliferation of Nuclear Weapons

NRC Nuclear Regulatory Commission

MOX Mixed plutonium/uranium oxide fuel

POTAS U.S. Program of Technical Assistance to IAEA Safeguards

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Page 1 GAO-06-93 Nuclear Nonproliferation

United States Government Accountability Office

Washington, D.C. 20548

A

October 7, 2005 Letr

The Honorable Norm Coleman

Chairman

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Bennie Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Revelations about the clandestine nuclear programs of North Korea, Iran, 

and Libya, as well as clandestine nuclear trafficking networks, have 

significantly increased international concerns about the spread of weapons 

of mass destruction. In February 2004, President Bush highlighted the 

proliferation dangers of nuclear weapons and called on the international 

community to support the International Atomic Energy Agency’s (IAEA) 

strengthened safeguards measures.1

 Since the Treaty on the NonProliferation of Nuclear Weapons (NPT) came into force in 1970, IAEA’s 

safeguards system has been a cornerstone of U.S. and international efforts 

to prevent nuclear weapons proliferation. The NPT expanded IAEA’s 

original inspection responsibilities by requiring signatory non- nuclear 

weapons states—countries that had not manufactured and detonated a 

nuclear device before January 1, 1967—to agree not to acquire nuclear 

weapons and to accept IAEA safeguards on all nuclear material used in 

peaceful activities.2

Safeguards allow the agency to independently verify that non-nuclear 

weapons states that signed the NPT are complying with its requirements. 

Under the safeguards system, IAEA, among other things, inspects all 

1

IAEA, an autonomous international organization affiliated with the United Nations, was 

established in Vienna, Austria, in 1957. The agency has the dual role of promoting the 

peaceful uses of nuclear energy by transferring nuclear science and technology through its 

nuclear science and applications and technical cooperation programs, and verifying, 

through its safeguards program, that nuclear materials subject to safeguards are not 

diverted to nuclear weapons or other proscribed purposes.

2

Under the NPT, nuclear weapons states pledged to facilitate the transfer of peaceful nuclear 

technology to non-nuclear weapons states, but not to assist them in acquiring nuclear 

weapons.
Page 2 GAO-06-93 Nuclear Nonproliferation

facilities and locations containing nuclear material declared by countries to 

verify its peaceful use. Inspectors from IAEA’s Department of Safeguards 

verify that the quantities of nuclear material that these non-nuclear 

weapons states declared to the agency have not been diverted for other 

uses. In addition, the agency installs containment and surveillance 

measures, such as video cameras, to detect movement of nuclear material 

and tampering with agency equipment. As of December 2004, 923 facilities 

and other locations containing about 164,000 metric tons of nuclear 

material were under safeguards. In 2004, IAEA’s safeguards budget was 

approximately $115.2 million, or about 38 percent of IAEA’s total budget.

The discovery in 1991 of a clandestine nuclear weapons program in Iraq 

confirmed the need for a broader and more effective approach to 

safeguards. As a result, IAEA began a two-stage process of strengthening 

its safeguards system to provide assurance that non-nuclear weapons 

states were not engaged in undeclared nuclear activities. First, in the early 

1990s, IAEA began using its existing authority under safeguards 

agreements with individual countries to obtain additional information 

about states’ nuclear and nuclear-related activities. Most countries have 

negotiated an agreement with IAEA, known as a comprehensive safeguards 

agreement. Second, in 1997, IAEA’s Board of Governors approved what it 

called the “Model Additional Protocol,” which, when brought into force, 

requires countries to provide the agency with a broader range of 

information on its nuclear and nuclear-related activities. It also gives the 

agency’s inspectors access to an expanded range of declared activities and 

locations, including buildings at nuclear sites, and locations where 

undeclared activities are suspected. The Additional Protocol is a separate 

agreement, which supplements each country’s existing safeguards 

agreement with IAEA.

In addition to its safeguards activities, IAEA has been called upon by its 

member states to confront the threat of nuclear terrorism. For example, 

since 1995, IAEA’s nuclear security program has helped member states 

improve the security of their nuclear material by assessing the vulnerability 

of their nuclear facilities. Additionally, IAEA has helped states to meet their 

responsibilities under the Convention on the Physical Protection of 

Nuclear Material, which entered into force in 1987 and, among other things, 

binds its signatories to ensure certain levels of physical protection while 

transporting nuclear materials internationally. In light of the September 11, 

2001 attacks, IAEA increased its nuclear security efforts by developing and 

updating physical protection guidelines and recommendations to help 

countries improve the security of their nuclear facilities and helping 
Page 3 GAO-06-93 Nuclear Nonproliferation

countries install radiation detection equipment at their borders to try and 

prevent illicit trafficking of nuclear materials.

As the largest contributor to IAEA, the United States has a strong interest 

in supporting and improving IAEA’s safeguards system and nuclear security 

activities to curb the spread of weapons of mass destruction. In July 1998, 

we reported that IAEA had tested and started to implement strengthened 

safeguards measures, but that it was too early to assess IAEA’s progress.3

 

In this context, you asked us to review IAEA’s safeguards and nuclear 

security activities. This report (1) identifies the steps IAEA has taken to 

strengthen its safeguards system, (2) assesses the challenges IAEA faces in 

implementing its strengthened safeguards measures, (3) identifies the 

extent to which IAEA relies on the United States for safeguards budgetary 

support, and (4) describes how IAEA is helping its member states secure 

their nuclear material and facilities and identifies challenges to 

implementing the program.

To address these objectives, we collected and analyzed documentation 

related to IAEA’s safeguards and nuclear security programs from IAEA and 

U.S. agencies, including the Departments of Commerce, Defense (DOD), 

Energy (DOE), and State and the Nuclear Regulatory Commission (NRC). 

We also interviewed key IAEA and U.S. agency officials. In addition, we 

conducted structured interviews based on a nonprobability sample to 

obtain the views of representatives of nine IAEA member states—Canada, 

China, Germany, Hungary, Israel, Japan, Russia, the United Kingdom, and 

the United States—on IAEA’s safeguards and nuclear security programs.4

 

This sample included states that belonged to IAEA’s Board of Governors, 

both nuclear and non-nuclear weapons states, and states with special 

safeguards agreements with IAEA. We also analyzed budgetary 

information, performed a data reliability assessment of the data we 

obtained, and interviewed knowledgeable IAEA and U.S. officials on the 

reliability of the data. We determined that these data were sufficiently 

reliable for the purposes of this report. We conducted our work from 

October 2004 to August 2005 in accordance with generally accepted 

3

GAO, Nuclear Nonproliferation: Uncertainties With Implementing IAEA’s Strengthened 

Safeguards System, GAO/NSIAD/RCED-98-184 (Washington, D.C.: July 9, 1998).

4

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample.
Page 4 GAO-06-93 Nuclear Nonproliferation

government auditing standards. Appendix I provides a more detailed 

discussion of our methodology.

Results in Brief IAEA has taken steps to strengthen safeguards by more aggressively 

seeking assurances that countries have not engaged in clandestine nuclear 

activities, but the agency still cannot be certain that countries are not 

developing secret weapons programs. In a radical departure from the past 

practice of only verifying the peaceful use of a country’s declared nuclear 

material at declared facilities, IAEA has begun to develop the capability to 

independently evaluate all aspects of a country’s nuclear activities by, 

among other things, conducting more intrusive inspections and collecting 

and analyzing environmental samples to detect traces of nuclear material at 

facilities and other locations. In addition, IAEA is trying to improve the 

efficiency of its efforts by applying integrated safeguards, which could 

result in a reduction in the number of inspections in certain countries. 

IAEA is also taking a number of steps to strengthen its management of the 

safeguards program. For example, current initiatives include developing 

multiyear strategic plans and modernizing the agency’s safeguards 

information management system. Finally, although Department of State 

and IAEA officials told us that IAEA’s strengthened safeguards measures 

have successfully revealed previously undisclosed nuclear activities in 

Iran, South Korea, and Egypt, IAEA’s former Deputy Director General for 

Safeguards and a group of safeguards experts cautioned that a determined 

country can still conceal a nuclear weapons program.

IAEA faces a number of challenges that hamper its ability to effectively 

implement strengthened safeguards. First, about two-thirds, or 120 out of 

189, of the NPT signatories have not yet brought the Additional Protocol 

into force, including the United States. Impediments to expanding adoption 

of the Additional Protocol include, among other things, the financial costs 

associated with implementing it. A second challenge to implementing 

strengthened safeguards is that safeguards are significantly limited or not 

applied in about 60 percent, or 113 out of 189, of the NPT signatory 

countries—either because they have an agreement (known as a small 

quantities protocol) with IAEA, and are not subject to most safeguards 

measures, or because they have not concluded a comprehensive 

safeguards agreement with IAEA. IAEA cannot verify that these countries 

are not diverting nuclear material for non-peaceful purposes or engaging in 

secret nuclear activities. Third, while IAEA is increasingly relying on the 

analytical skills of its staff to detect countries’ undeclared nuclear 

activities, the agency is facing a looming human capital crisis. In the next 5 
Page 5 GAO-06-93 Nuclear Nonproliferation

years, IAEA will experience a large turnover of senior safeguards 

inspectors and high-level management officials. Delays in filling critical 

safeguards positions and a shrinking pool of nuclear experts limit IAEA’s 

ability to implement strengthened safeguards. Further, personnel policies, 

such as a mandatory retirement age, impede IAEA’s ability to hire and 

retain staff with critical safeguards skills. For example, IAEA would not 

hire one expert with unique skills in environmental sample analysis 

because he was over the agency’s retirement age. Consequently, to retain 

his skills, the United States hired him as a part-time consultant to IAEA. 

Finally, IAEA does not have a system in place to measure how effective its 

strengthened safeguards system is in detecting undeclared nuclear 

activities.

IAEA relies heavily on the United States to meet its safeguards obligations, 

and this situation is likely to continue despite IAEA’s recent budget 

increase. For 2004, the United States is providing $45.3 million to support 

IAEA’s safeguards program in assessed and voluntary cash contributions—

over 34 percent of IAEA’s total safeguards budget. In addition, in 2004, the 

U.S. Departments of State, Energy, and Defense and the Nuclear Regulatory 

Commission provided an estimated $27.2 million in technical support for 

activities such as analyzing environmental samples to detect the presence 

of nuclear material. In 2004, IAEA’s safeguards budget was increased for 

the first time in 20 years (beyond adjustments for inflation and staff 

salaries) by about $19 million to be phased in over a 4-year period. 

However, despite this increase, U.S. and IAEA officials said that IAEA is 

likely to continue to rely on voluntary contributions—in particular, those 

from the United States—to meet critical needs because of the agency’s 

growing responsibilities under strengthened safeguards. Finally, IAEA does 

not have a process to systematically evaluate resource requirements more 

than 2 years into the future or develop reliable estimates of the costs of all 

its safeguards activities. Without a systematic process to evaluate 

requirements and their costs over the long term, IAEA cannot make a 

convincing case to its member states that the agency requires additional 

resources. 

In the aftermath of September 11, 2001, IAEA increased its efforts to help 

countries improve the physical protection of nuclear material and facilities, 

secure other radioactive materials, and respond to malicious acts or 

threats. However, IAEA’s reliance on voluntary funds for these efforts 

creates challenges, and Department of State officials raised concerns about 

the agency’s inability to measure the results of its efforts. Specifically, to 

help countries improve their nuclear security, IAEA, among other things, 
Page 6 GAO-06-93 Nuclear Nonproliferation

assesses the vulnerability of facilities to better protect them against 

sabotage and helps provide radiation detection equipment to prevent illicit 

trafficking in nuclear and radioactive materials. In 2002, IAEA established a 

Nuclear Security Fund to support these activities, and countries provided 

about $36.7 million as of mid-May 2005. However, IAEA relies on this 

voluntary support for about 89 percent of its nuclear security funding, 

which creates a budgetary challenge to long-term planning because funding 

levels vary from year to year. Furthermore, in 2003, over 94 percent of these 

funds were earmarked by donors for specific activities. As a result, IAEA 

does not have the flexibility to allocate contributions to meet its highest 

priority needs. In addition, Department of State officials raised concerns 

about IAEA’s inability to track the use of nuclear security funds and 

measure achievements in a systematic way. In response, IAEA developed a 

system to monitor and report on program expenditures. However, IAEA 

still does not systematically measure the impact of its nuclear security 

activities.

To help strengthen IAEA’s safeguards system and nuclear security program, 

this report makes several recommendations. We recommend, among other 

things, that the Secretary of State, working with IAEA and its member 

states through the Board of Governors, consider (1) eliminating, or at a 

minimum, reducing the number of agreements, which limit IAEA’s authority 

to implement strengthened safeguards activities in countries with small 

quantities of nuclear material; (2) establishing clear and meaningful 

measures to better evaluate the effectiveness of safeguards and nuclear 

security activities; and (3) rectifying human capital practices that 

negatively impact IAEA’s ability to recruit and retain critical safeguards 

staff.

We provided the Department of State and IAEA with draft copies of this 

report for their review and comment. IAEA provided technical comments, 

which we incorporated as appropriate. In its written comments, the 

Department of State generally agreed with our findings, conclusions, and 

recommendations and noted that our recommendations offered reasonable 

ways that the administration can continue to work with IAEA to improve 

its effectiveness. State also noted that the draft report fairly recognized the 

significant progress IAEA has made, with support from the United States 

and other member states, in strengthening the safeguards system and in 

supporting international efforts to improve the physical protection and 

security of nuclear materials. State also provided technical comments, 

which we incorporated in the report as appropriate. 
Page 7 GAO-06-93 Nuclear Nonproliferation

Background IAEA is an independent organization affiliated with the United Nations. Its 

governing bodies include the General Conference, composed of 

representatives of the 138 IAEA member states, and the 35-member Board 

of Governors, which provides overall policy direction and oversight. A 

Secretariat, headed by the Director General, is responsible for 

implementing the policies and programs of the General Conference and 

Board of Governors. The United States is a permanent member of the 

Board of Governors. IAEA funds its programs through its regular budget, 

for which all members are assessed, and by voluntary cash contributions 

and technical support from member states, including the United States. 

U.S. policy regarding the agency is developed by an interagency process 

chaired by the Department of State. The U.S. Mission to the U.N. System 

Organizations in Vienna, Austria, works closely with the department in 

Washington, D.C., to promote the effective function of the agency, including 

management reform.

IAEA derives its authority to establish and administer safeguards from its 

statute, the Treaty on the Non-Proliferation of Nuclear Weapons and 

regional nonproliferation treaties, bilateral commitments between states, 

and project agreements with states.5

 Since the NPT came into force in 1970, 

it has been subject to review by signatory states every 5 years. The 1995 

NPT Review and Extension conference extended the life of the treaty 

indefinitely, and the latest review conference occurred in May 2005. Article 

III of the NPT binds each of the treaty’s 184 signatory states that had not 

manufactured and exploded a nuclear device prior to January 1, 1967 

(referred to in the treaty as non-nuclear weapon states) to conclude an 

agreement with IAEA that applies safeguards to all source and special 

nuclear material in all peaceful nuclear activities within the state’s territory, 

under its jurisdiction, or carried out anywhere under its control.6

5

Regional treaties, including the Treaty for the Prohibition of Nuclear Weapons in Latin 

America (the 1967 Treaty of Tlatelolco), the South Pacific Nuclear Free Zone Treaty (the 

1985 Treaty of Rarotonga), the African Nuclear-Weapon-Free Zone Treaty (the 1995 Treaty of 

Pelindaba), and the Southeast Asia Nuclear-Weapon-Free Treaty (the 1995 Bangkok Treaty) 

require each participating country to conclude a comprehensive safeguards agreement with 

IAEA. Additionally, in February 2005, five Central Asian states announced that they had 

reached agreement on the text of a treaty to establish a nuclear-weapon-free zone.

6

Nuclear materials include source materials, such as natural uranium, depleted uranium, 

and thorium, and special fissionable materials, such as enriched uranium and plutonium.
Page 8 GAO-06-93 Nuclear Nonproliferation

The five nuclear weapons states that are parties to the NPT—China, 

France, the Russian Federation, the United Kingdom, and the United 

States—are not obligated by the NPT to accept IAEA safeguards. However, 

each nuclear weapons state has voluntarily entered into legally binding 

safeguards agreements with IAEA, and have submitted designated nuclear 

materials and facilities to IAEA safeguards to demonstrate to the nonnuclear weapon states their willingness to share in the administrative and 

commercial costs of safeguards. (App. II lists states that are subject to 

safeguards, as of July 2005.)

As of July 2005, all but four countries with significant nuclear activities had 

comprehensive safeguards agreements with IAEA in force. India, Israel, 

and Pakistan are not parties to the NPT or other regional nonproliferation 

treaties.7

 As a result, they do not have comprehensive safeguards 

agreements with IAEA. Instead, these three states have IAEA safeguards 

agreements that limit the scope of the agency’s safeguards activities to 

specific material, equipment, and facilities. India and Pakistan are known 

to have nuclear weapons programs and to have detonated several nuclear 

devices during May 1998. Israel is also believed to have produced nuclear 

weapons. Additionally, North Korea joined the NPT in 1985 and briefly 

accepted safeguards in 1992 and 1993, but expelled inspectors and 

threatened to withdraw from the NPT when IAEA inspections uncovered 

evidence of undeclared plutonium production. North Korea announced its 

withdrawal from the NPT in early 2003, which under the terms of the treaty, 

terminated its comprehensive safeguards agreement.

IAEA’s safeguards objectives, as traditionally applied under comprehensive 

safeguards agreements, are to account for the amount of a specific type of 

material necessary to produce a nuclear weapon, and the time it would 

take a state to divert this material from peaceful use and produce a nuclear 

weapon. IAEA attempts to meet these objectives by using a set of activities 

by which it seeks to verify that nuclear material subject to safeguards is not 

diverted to nuclear weapons or other proscribed purposes. For example, 

IAEA inspectors visit a facility at certain intervals to ensure that any 

diversion of nuclear material is detected before a state has had time to 

produce a nuclear weapon. IAEA also uses material-accounting measures 

7

Previously, Cuba was included in this group of states; however, Cuba acceded to the NPT, 

effective November 4, 2002, and to the Tlatelolco Treaty, effective October 23, 2002. Cuba 

signed a comprehensive safeguards agreement on September 18, 2003, which was brought 

into force June 3, 2004.
Page 9 GAO-06-93 Nuclear Nonproliferation

to verify quantities of nuclear material declared to the agency and any 

changes in the quantities over time. Additionally, containment measures 

are used to control access to and the movement of nuclear material. 

Finally, IAEA deploys surveillance devices, such as video cameras, to 

detect the movements of nuclear material and discourage tampering with 

IAEA’s containment measures.

In addition to IAEA’s long-standing role in safeguarding nuclear materials, it 

has undertaken efforts to assist states in better securing their nuclear 

materials. In 1972, IAEA issued a set of guidelines that outlined the 

minimum standards for ensuring the physical protection of nuclear 

materials. Following the breakup of the Soviet Union, concern about 

smuggling nuclear and other radioactive materials increased. In 1992, IAEA 

started assisting former Soviet states to enhance the security of their 

nuclear materials. IAEA also established a database to systematically 

collect information on reported incidents of trafficking in radioactive 

materials. Additionally, in 1994, the Board of Governors agreed to enhance 

the services that IAEA could offer countries to improve the protection of 

nuclear material and to detect and suppress trafficking of nuclear 

materials. For example, in 1996, IAEA started conducting advisory 

missions at states’ request that involved assessing the physical protection 

of nuclear materials at a facility.

IAEA Has Taken Steps 

to Strengthen 

Safeguards, but 

Detecting Clandestine 

Nuclear Weapons 

Programs Is Not 

Assured

IAEA has taken steps to strengthen safeguards by more aggressively 

seeking assurances that a country is not pursuing a clandestine nuclear 

program. In a radical departure from past practices of only verifying the 

peaceful use of a country’s declared nuclear material at declared facilities, 

IAEA has begun to develop the capability to independently evaluate all 

aspects of a country’s nuclear activities. IAEA is trying to improve the 

efficiency of its efforts by applying integrated safeguards which could 

result in a reduction in the number of inspections in countries that have a 

proven record of complying with safeguards. In addition, the agency is 

taking a number of steps to strengthen its management of the safeguards 

program. Finally, Department of State and IAEA officials told us that 

strengthened safeguards measures have successfully revealed previously 

undisclosed nuclear activities in Iran, South Korea, and Egypt. However, a 

group of safeguards experts recently cautioned that a determined country 

can still conceal a nuclear weapons program. 
Page 10 GAO-06-93 Nuclear Nonproliferation

Strengthened Safeguards 

Have Broadened IAEA’s 

Focus to Examine All 

Nuclear Activities in a 

Country

Over the past decade, IAEA has taken steps to strengthen its safeguards 

system to detect clandestine nuclear activities. These strengthened 

safeguards are a radical departure from the agency’s traditional safeguards 

approach, which focused on verifying that declared nuclear material at 

specific facilities or locations in a country had not been diverted for 

nuclear weapons. While the strengthened safeguards system continues to 

rely on traditional nuclear material accountancy, and containment and 

surveillance measures to ensure declared material is not diverted, IAEA 

has broadened its focus from declared nuclear materials to a more 

comprehensive assessment of a country’s nuclear activities. The first 

strengthened safeguards steps, which began in the early 1990s, increased 

the agency’s ability to monitor declared and undeclared activities at nuclear 

facilities. These measures were implemented under the agency’s existing 

legal authority under comprehensive safeguards agreements at declared 

nuclear facilities and include (1) conducting short notice and unannounced 

inspections, (2) taking location-specific environmental samples inside 

facilities to detect traces of nuclear material, and (3) using measurement 

and surveillance systems that operate unattended and can be used to 

transmit data about the status of nuclear materials directly to IAEA 

headquarters. IAEA reported that in 2004 it performed 2,302 inspections at 

598 facilities and other locations and took 590 environmental samples at 90 

facilities. In addition, by June 2004, it had installed 91 unattended 

monitoring systems in 44 nuclear facilities. 

The second series of steps under strengthened safeguards began in 1997 

when IAEA’s Board of Governors approved the Additional Protocol.8

 The 

Additional Protocol is designed to supplement countries’ safeguards 

agreements by requiring countries to provide IAEA with broader 

information on and access to nuclear and nuclear-related activities. 

Because the Additional Protocol broadens IAEA’s authority and the 

requirements on countries under existing comprehensive safeguards 

agreements, each country must take certain actions to bring it into force. 

Under the Additional Protocol, IAEA has the right to 

8

Model Protocol Additional to the Agreement(s) Between State(s) and the International 

Atomic Energy Agency for the Application of Safeguards.
Page 11 GAO-06-93 Nuclear Nonproliferation

• receive more comprehensive information from a country about all 

aspects of its nuclear fuel cycle,9

 including information about research 

and development on the fuel cycle, the manufacturing and exporting of 

sensitive and other key nuclear-related equipment, and all buildings on a 

nuclear site, and compare this information with information from other 

sources;

• conduct “complementary access,” which enables IAEA to expand its 

inspection rights for the purpose of ensuring the absence of undeclared 

nuclear material and activities; and 

• collect environmental samples beyond declared nuclear facilities, when 

deemed necessary. 

When IAEA can use the full range of strengthened safeguards measures 

(under a comprehensive safeguards agreement and the Additional 

Protocol), the agency can provide assurances that all declared nuclear 

material is being used for peaceful purposes and that a country has 

declared all of its nuclear material or activities, as required. In 2004, the 

agency reported that comprehensive safeguards agreements with the 

Additional Protocol were implemented in 61 countries and Taiwan,10 and 

that

• for 21 countries, there was no indication of the diversion of nuclear 

material placed under safeguards and no indication of undeclared 

nuclear material or activities for the country as a whole. On this basis, 

IAEA concluded that all nuclear material in these countries remained in 

peaceful use or was otherwise adequately accounted for;

• for an additional 37 countries (plus Taiwan), there was no indication of 

the diversion of nuclear material placed under safeguards, and 

evaluations aimed at drawing conclusions about the absence of 

undeclared nuclear material and activities had not been completed; and

9

There are several steps in the nuclear fuel cycle. The front end of the fuel cycle includes 

uranium mining and milling, conversion, enrichment, and fuel fabrication. Once uranium 

becomes spent fuel (after being used to produce electricity), the back end of the cycle 

follows. This may include temporary storage, reprocessing, recycling, and waste disposal.

10Although IAEA does not officially recognize Taiwan, the agency applies safeguards there, 

including measures under a comprehensive safeguards agreement and the Additional 

Protocol.
Page 12 GAO-06-93 Nuclear Nonproliferation

• three countries (Iran, Libya, and South Korea) were engaged in 

previously undisclosed nuclear activities and therefore were not 

complying with their respective safeguards agreements. Although Iran 

and Libya have not formally brought the Additional Protocol into force, 

they have informed IAEA that they are acting as if the agreement has 

been implemented.

For each country with a safeguards agreement, IAEA independently 

evaluates all information available about the country’s nuclear activities 

and draws conclusions regarding a country’s compliance with its 

safeguards commitments. Major sources of information available to the 

agency include data submitted by countries to IAEA under their safeguards 

agreements—referred to as state declarations—and information from 

internal IAEA databases, open sources, third parties, and IAEA inspections. 

Countries are required to provide an expanded declaration of their nuclear 

activities under the Additional Protocol within 180 days of bringing the 

Additional Protocol into force. Examples of information provided in an 

Additional Protocol declaration include the manufacturing of key nuclearrelated equipment; research and development activities related to the 

nuclear fuel cycle; the use and contents of buildings on a nuclear site; the 

location and operational status of uranium mines; and the quantities, uses, 

and locations of nuclear material exempted from safeguards. The agency 

uses the state declarations as a starting point to determine if the 

information provided by the country is consistent and accurate with all 

other information available based on its own review. A confidential 

document, known as a state evaluation report, serves as the basis of IAEA’s 

assessment of a country’s compliance with its safeguards commitments.

State evaluations are central to the process by which safeguards 

conclusions are drawn. For a state with an Additional Protocol in force, 

drawing the initial broader conclusion regarding the absence of undeclared 

nuclear material and activities for the country as a whole can take several 

years to complete depending on (1) the size of a country’s nuclear program, 

(2) whether there are gaps in the data submitted by the country, and (3) 

whether there are inconsistencies between the country’s declaration and 

IAEA’s independent evaluation of that country’s nuclear program. IAEA 

officials told us that the agency took 5 years to draw the initial broader 

safeguards conclusion for Japan because of the volume of information 

contained in Japan’s declaration and the magnitude of its nuclear
Page 13 GAO-06-93 Nuclear Nonproliferation

program.11 Drawing the initial broader safeguards conclusion for Canada is 

also expected to take a similar amount of time because of the size of its 

nuclear program. State evaluation reports are updated annually for a 

country after the Additional Protocol is in force. In 2004, 76 evaluation 

reports were completed and reviewed, including 55 for countries that had 

additional protocols in force or were acting as if they did.

IAEA uses various types of information to verify the state declaration. 

Inspections of nuclear facilities and other locations with nuclear material 

are the cornerstone of the agency’s data collection efforts. Under an 

Additional Protocol, IAEA has the authority to conduct complementary 

access at any place on a site or other location with nuclear material in 

order to ensure the absence of undeclared nuclear material and activities, 

confirm the decommissioned status of facilities where nuclear material 

was used or stored, and resolve questions or inconsistencies related to the 

correctness and completeness of the information provided by a country on 

activities at other declared or undeclared locations. During complementary 

access, IAEA inspectors may carry out a number of activities, including (1) 

making visual observations, (2) collecting environmental samples, (3) using 

radiation detection equipment and measurement devices, and (4) applying 

seals. In 2004, IAEA conducted 124 complementary access in 27 countries.

In addition to its verification activities, IAEA uses other sources of 

information to evaluate countries’ declarations. These sources include 

information from the agency’s internal databases, open sources, satellite 

imagery, and outside groups. The agency established two new offices 

within the Department of Safeguards to focus primarily on open source and 

satellite imagery data collection. Analysts use Internet searches to acquire 

information generally available to the public from open sources such as 

scientific literature, trade and export publications, commercial companies, 

and the news media. In addition, the agency uses commercially available 

satellite imagery to supplement the information it receives through its open 

source information. Satellite imagery is used to monitor the status and 

condition of declared nuclear facilities and verify state declarations of 

11About one-third of Japan’s electricity is generated by nuclear power. Japan has been 

engaged in fuel reprocessing and the recycling of plutonium in mixed plutonium/uranium 

oxide (MOX) fuel for approximately 20 years to develop its nuclear fuel cycle. Japan is 

expanding this capability with the construction and commissioning of the commercial-scale 

Rokkashomura reprocessing plant in northern Japan. This fully integrated nuclear fuel cycle 

center will perform spent fuel receipt, storage, reprocessing, high-level waste treatment and 

MOX-fuel fabrication. Uranium enrichment is carried out at the same site.
Page 14 GAO-06-93 Nuclear Nonproliferation

certain sites. The agency also uses its own databases, such as those for 

nuclear safety, nuclear waste, and technical cooperation to expand its 

general knowledge about countries’ nuclear and nuclear-related activities. 

In some cases, IAEA receives information from third parties such as other 

countries.

Figure 1 shows the types of information IAEA uses to verify a country’s 

compliance with its safeguards obligations.
Page 15 GAO-06-93 Nuclear Nonproliferation

Figure 1: Types of Information Used by IAEA to Verify Countries’ Compliance with Their Safeguards Obligations

Source: GAO analysis of IAEA data; photos Dean Calma, IAEA.

IAEA uses a broad range of 

tools to independently evaluate 

countries' compliance with their 

safeguards obligations. The 

evaluation process begins 

when IAEA receives a state 

declaration from a country on 

its nuclear activities. 

IAEA then independently 

collects information to verify 

that the declaration is accurate 

and complete by, among other 

things, conducting physical 

inspections of nuclear facilities 

and collecting and analyzing 

environmental samples, 

satellite imagery, and open 

source information from the 

Internet.

Radiation detector

Surveilance cameras

and unattended remote

monitoring

Inspection of a nuclear facility

Collecting and analyzing

environmental samples

Sattelite imagery

Indicates sources of information that IAEA collects on countries' nuclear activities.

IAEA headquarters

Laboratory

Internet and IAEA

database searches
Page 16 GAO-06-93 Nuclear Nonproliferation

To further enhance its capability to detect undeclared nuclear material and 

activities, IAEA collects information about clandestine networks that are 

engaged in the illicit trafficking of nuclear material and equipment. In 2004, 

the agency established the Nuclear Trade Analysis Unit that is responsible 

for investigating and obtaining information about clandestine networks. 

The unit’s mission includes maintaining institutional memory of nuclear 

supply networks, centralizing the analysis of covert nuclear technology 

networks, and supporting IAEA’s reviews of state evaluations. Some 

information used by the unit is derived from safeguards reports routinely 

submitted to the agency, such as state declarations.

IAEA is seeking to streamline and make the safeguards system more 

efficient by applying integrated safeguards. Integrated safeguards are 

applied in countries (1) that have brought the Additional Protocol into 

force and complied with all its requirements; (2) where IAEA, through 

complementary access and other means, has resolved any questions or 

inconsistencies regarding nuclear activity in these countries; and (3) where 

IAEA has concluded that there has been no diversion of nuclear material 

and no indication of undeclared nuclear material or activities. As of July 

2005, IAEA was applying integrated safeguards in eight countries—

Australia, Bulgaria, Hungary, Indonesia, Japan, Norway, Peru, and 

Uzbekistan. For these countries, IAEA has reduced the number of routine, 

scheduled inspections at certain types of facilities, such as light water 

reactors and low enriched uranium conversion plants. Agency officials told 

us that they anticipate cost-savings resulting from the implementation of 

integrated safeguards, which will free up resources for increased activities 

in countries where significant questions and inconsistencies arise.

Although the U.S. government supports the introduction of integrated 

safeguards, some concerns have been raised about its implementation. 

According to Department of State officials, it is essential that integrated 

safeguards not compromise the underlying foundation of safeguards—

routine inspections of nuclear facilities. Verifying that declared quantities 

of nuclear material are accounted for and remain under safeguards 

continues to be the fundamental basis for reaching safeguards conclusions 

that countries are not diverting nuclear material for clandestine activities. 

Department of State officials said that integrated safeguards should be 

applied slowly and systematically to ensure that the safeguards system 

remains credible. 
Page 17 GAO-06-93 Nuclear Nonproliferation

IAEA Is Taking Steps to 

Improve the Management of 

the Safeguards System

IAEA has several management initiatives under way to support the 

strengthened safeguards system, including (1) developing multi-year 

strategic plans, (2) modernizing the agency’s safeguards information 

management system, (3) improving the agency’s coordination of efforts to 

develop and procure equipment and technology, and (4) expanding the 

inspector training program. IAEA has developed 5-year medium-term 

strategies that identify specific goals and objectives for critical agency 

missions, including safeguards. IAEA’s strategy for 2006-2011 calls for the 

agency’s safeguards system to be further strengthened and its capability to 

detect undeclared nuclear material and activities increased. In addition, the 

strategy calls for IAEA to continue to utilize new sources of information to 

help ensure that countries are not engaged in clandestine nuclear activities. 

According to IAEA officials, the strategy requires safeguards program 

managers to identify how their specific activities fit into the agency’s 

overall strategic objectives and medium term plan. These managers are 

required to plan and request funding based on the objectives identified in 

the medium-term strategies.

Another important initiative is IAEA’s efforts to re-engineer the agency’s 

information management system. This system serves as the central 

repository for all safeguards information, and it is used to generate reports 

for safeguards inspectors and IAEA management. According to U.S. and 

IAEA officials, the information management system, which started 

operation in the late 1970s, is outdated and needs to be modernized. As 

currently configured, IAEA inspectors and safeguards personnel cannot 

easily use the system for analytical purposes because there is no 

centralized database. With data stored in over 40 different databases, the 

agency dedicates significant amounts of time and funds to train staff on 

how to store and retrieve information. The project to modernize the 

safeguards information management system is expected to take about 3-1/2 

years to complete and cost over $30 million. IAEA plans to finance the 

project through its regular budget and member states’ voluntary 

contributions. However, sustained U.S. support for the project, which IAEA 

expects to amount to at least 50 percent of the total planned voluntary cash 

contributions, is uncertain. In May 2004, the former U.S. ambassador to the 

U.S. Mission to the U.N. Systems Organization in Vienna said that the 

United States could not commit to pledging continued support for the 

project due to, among other things, the lack of contributions by other 

countries. He noted that nuclear nonproliferation is a global problem and 

that the United States expects IAEA to work with other member states to 

secure funding for the project. However, at the time of our review, only the 
Page 18 GAO-06-93 Nuclear Nonproliferation

United States, Germany, the Czech Republic, and the United Kingdom had 

pledged voluntary contributions to fund the project.

In 2001, the Department of Safeguards took steps to improve its equipment 

management process. As part of this initiative, IAEA’s equipment 

coordination committee was reorganized to improve its effectiveness. The 

committee reviews, prioritizes, and approves equipment and technology 

needs for all divisions within the department. The committee also reviews 

and approves any equipment-related research and development projects. 

IAEA and U.S. government officials told us that the equipment management 

process has helped the agency improve coordination among member states 

to better plan for the more efficient use of funds. In addition, IAEA has 

generated 2-year program plans to help coordinate funding to implement 

projects and develop equipment. For example, in its most recent plan, 

IAEA identified major priorities, including developing technology that 

detects undeclared nuclear activities and re-engineering its safeguards 

information management system.

Finally, IAEA officials told us they recognize that the expansion of 

inspectors’ responsibilities under strengthened safeguards, in combination 

with advanced safeguards equipment and new technology, significantly 

increases the amount of training inspectors need. IAEA’s goal is to provide 

the best training possible to ensure that inspectors’ skills are continuously 

improved to maintain high standards of performance, enhance credibility, 

and promote a sense of professionalism among the staff. Inspectors must 

develop expertise in many new areas while maintaining competence in the 

application of material accountancy measures. As a result, IAEA has 

updated its training curriculum and continued the development and 

implementation of advanced and refresher training on strengthened and 

integrated safeguards measures, the Additional Protocol, and the use of 

new and upgraded containment and surveillance equipment. In 2005, the 

agency introduced a qualification process to ensure that all inspectors have 

the necessary knowledge and skills to perform their jobs at an acceptable 

level. Training also includes courses to strengthen analytical skills, 

including enhanced communication, observation, and writing skills. 

Initially, a new inspector performs verification duties in the field under the 

supervision of a more experienced inspector. Once an inspector becomes 

fully qualified to independently conduct inspections, additional training is 

required to maintain skills.

Despite IAEA’s recent efforts to strengthen its training program, it is 

uncertain the extent to which training alone will adequately prepare 
Page 19 GAO-06-93 Nuclear Nonproliferation

inspectors for their expanding responsibilities under strengthened 

safeguards. For example, U.S. safeguards experts, including a former IAEA 

inspector, raised concerns about the adequacy of training. One former 

inspector told us that all “in-house” training is done in English, the official 

working language of the agency. However, she noted that this makes it 

difficult for some inspectors who do not have a good grasp of English to 

fully absorb and understand the training materials and oral presentations. 

In addition, this official said that IAEA has not implemented a good system 

to provide mentors to new inspectors who need practical hands-on 

experience when they are in the field performing inspections. Brookhaven 

National Laboratory officials, who are responsible for managing the U.S. 

Program of Technical Assistance to IAEA Safeguards (POTAS), told us that 

many of the best qualified training instructors are leaving IAEA either 

through retirement or attrition. In addition, many of these instructors, who 

are also full-time inspectors, are facing increased workloads under 

strengthened safeguards and have less time to teach. Instructor staffing 

difficulty combined with expanding inspector responsibilities has created a 

gap in the effective transfer of knowledge and experience provided to 

entry-level inspectors.

Strengthened Safeguards 

Result in Discoveries of 

Some Countries’ 

Undisclosed Activities but 

System Has Limitations

IAEA’s strengthened safeguards system has produced tangible benefits as 

some countries’ previously undeclared nuclear activities have been 

disclosed. In particular, U.S. and IAEA officials noted that in the cases of 

Iran, South Korea, and Egypt, strengthened safeguards has surfaced 

undeclared activities requiring further investigation and clarification by the 

agency. Specifically:

• IAEA and Department of State officials noted that strengthened 

safeguards have helped the agency verify Iran’s nuclear activities, 

although many questions about that country’s nuclear program have not 

been resolved. In late 2003, Iran agreed to act as if the Additional 

Protocol were in force. Iran’s acceptance of the Additional Protocol has 

enabled the agency to gain increased access to Iran’s nuclear activities. 

Iran subsequently submitted a declaration of its nuclear activities, and 

IAEA has undertaken numerous inspections, conducted complementary 

access on numerous occasions, and prepared several status reports of 

its findings and concerns for its Board of Governors. In 2004, the agency 

completed four reports on the status of its efforts in Iran. IAEA noted 

that Iran had been providing information in response to the agency’s 

requests, but in some cases, the information was presented too slowly 

and did not fully meet the agency’s needs. IAEA noted that it is not yet 
Page 20 GAO-06-93 Nuclear Nonproliferation

prepared to draw definitive conclusions regarding the correctness and 

completeness of Iran’s declarations, but the agency continues to make 

steady progress in understanding the program. IAEA also noted that it 

had been able to verify Iran’s suspension of enrichment-related activities 

at specific facilities and sites, but key issues still remained regarding the 

extent and nature of Iran’s enrichment program. Further, the agency 

stated in its report to the board that it was important for Iran to support 

the agency’s efforts to gain a full understanding of all remaining issues 

by continuing to provide access to locations, personnel, and relevant 

information in order to meet its safeguards obligations.

• In August 2004, as a result of preparations to submit its initial 

declaration under the Additional Protocol, South Korea notified IAEA 

that it had not previously disclosed nuclear experiments involving the 

enrichment of uranium and plutonium separation. Specifically, South 

Korea told the agency that the experiments had been on a laboratory 

scale, involved the production of only milligram quantities of enriched 

uranium, and that these activities had been terminated. Subsequently, 

IAEA sent a team of inspectors to South Korea to investigate this case. 

In November 2004, IAEA’s Director General reported to the Board of 

Governors that although the quantities of nuclear material involved 

were not significant, the nature of the activities and South Korea’s 

failure to report these activities in a timely manner posed a serious 

concern. IAEA is continuing to verify the correctness and completeness 

of South Korea’s declarations.

• IAEA inspectors have investigated evidence of past undeclared nuclear 

activities in Egypt based on the agency’s review of open source 

information that had been published by current and former Egyptian 

nuclear officials. Specifically, in late 2004, the agency found evidence 

that Egypt had engaged in undeclared activities involving uranium 

extraction, conversion, and reprocessing at least 20 years ago. 

According to available reports, Egypt used small amounts of nuclear 

material to conduct experiments related to producing plutonium and 

highly enriched uranium. In January 2005, the Egyptian government 

announced that it was fully cooperating with IAEA and that the matter 

was limited in scope. IAEA inspectors have made several visits to Egypt 

to investigate this matter. IAEA’s Secretariat reported to its Board of 

Governors on these activities in February 2005, but has not drawn any 

final conclusions or made recommendations.
Page 21 GAO-06-93 Nuclear Nonproliferation

Although the strengthened safeguards system has helped IAEA obtain 

information about some countries’ previously undisclosed nuclear 

activities, and provided assurances that other countries are not engaged in 

clandestine activities, the system has limitations. These limitations impact 

the agency’s ability to draw conclusions—with absolute assurance—about 

whether a country is developing a clandestine nuclear weapons program. 

For example, IAEA does not have unfettered inspection rights and cannot 

make visits to suspected sites anywhere at any time. According to the 

Additional Protocol, complementary access to resolve questions related to 

the correctness and completeness of the information provided by the 

country or to resolve inconsistencies must usually be arranged with at least 

24 hours advanced notice. Complementary access to buildings on sites 

where IAEA inspectors are already present are usually conducted with a 2-

hour advanced notice. Furthermore, IAEA officials told us that there are 

practical problems that restrict access. For example, inspectors must be 

issued a visa to visit certain countries that cannot normally be arranged in 

less than 24 hours. In some cases, nuclear sites are in remote locations and 

IAEA inspectors need to make travel arrangements, such as helicopter 

transportation, in advance, which requires that the country be notified 

prior to the visit.

IAEA’s environmental sampling activities, which play a key role in detecting 

undeclared nuclear material and activities, are limited as well in two main 

areas. First, IAEA relies on a consortium of laboratories located in eight 

countries, including the United States, known as the Network of Analytical 

Laboratories, to analyze environmental samples it obtains. However, 

according to IAEA and U.S. officials, the network is being used beyond its 

capacity to analyze the significant increase in the number of samples 

collected from Iran and Libya. IAEA noted that the number of samples 

collected from those two countries from 2003 to 2004 increased by about 

100 samples during the year. The strain on the network’s capacity has had a 

negative impact on the timely processing and reporting of results from 

environmental samples being collected. Officials from the Department of 

Defense and the U.S. Air Force Technical Applications Laboratory, which is 

responsible for analyzing the majority of environmental samples, told us 

that some samples received from IAEA have taken as long as 6 months to 

analyze. Even if a sample is a high priority, it takes at least 3 weeks, and the 

average time to analyze a sample is 2 to 3 months. As a result, critical, time 

sensitive analyses are not being completed on a consistent basis. According 

to IAEA officials, IAEA needs to increase the capacity of the network to 

analyze more samples as more states bring the Additional Protocol into 

force. 
Page 22 GAO-06-93 Nuclear Nonproliferation

Second, an environmental sampling technique, which is known as wide 

area sampling, can only be used when approved by the Board of Governors. 

Wide area sampling, if implemented, would enable the agency to collect 

environmental data from soil, rivers, and streams outside of declared 

nuclear facilities. However, it has not been approved by the board because, 

among other reasons, wide area sampling requires reductions in cost 

before it would be practical, according to U.S. and international experts.

Finally, a November 2004 study by a group of safeguards experts appointed 

by IAEA’s Director General evaluated the agency’s safeguards program to 

examine how effectively and efficiently strengthened safeguards measures 

were being implemented. Specifically, the group’s mission was to evaluate 

the progress, effectiveness, and impact of implementing measures to 

enhance the agency’s ability to draw conclusions about the nondiversion of 

nuclear material placed under safeguards and, for relevant countries, the 

absence of undeclared nuclear material and activities. The group 

concluded that generally IAEA had done a very good job implementing 

strengthened safeguards despite budgetary and other constraints. 

However, the group noted that IAEA’s ability to detect undeclared activities 

remains largely untested. If a country decides to divert nuclear material or 

conduct undeclared activities, it will deliberately work to prevent IAEA 

from discovering this. Furthermore, IAEA and member states should be 

clear that the conclusions drawn by the agency cannot be regarded as 

absolute. This view has been reinforced by the former Deputy Director 

General for Safeguards who has stated that even for countries with 

strengthened safeguards in force, there are limitations on the types of 

information and locations accessible to IAEA inspectors.

IAEA Faces Challenges 

That Impede Its Ability 

to Effectively 

Implement 

Strengthened 

Safeguards

IAEA faces a number of challenges that hamper its ability to effectively 

implement strengthened safeguards. First, about two-thirds, or 120 out of 

189, of the NPT signatories have not yet brought the Additional Protocol 

into force, including the United States. A second challenge is that 

safeguards are significantly limited or not applied in about 60 percent, or 

113 out of 189, of the NPT signatory countries either because they possess 

small quantities of nuclear material—and are not subject to most 

safeguards measures—or they have not concluded a comprehensive 

safeguards agreement with IAEA. IAEA cannot verify that these countries 

are not diverting nuclear material for nonpeaceful purposes or engaging in 

secret nuclear activities. Third, IAEA faces a looming human capital crisis. 

In the next 5 years, IAEA will experience a large turnover of senior 

safeguards inspectors and high-level management officials. Delays in filling 
Page 23 GAO-06-93 Nuclear Nonproliferation

critical safeguards positions, a shrinking pool of nuclear experts, and 

restrictive personnel policies, such as a mandatory retirement age, impede 

IAEA’s ability to hire and retain staff with critical skills. Finally, IAEA does 

not have a system in place to measure how effective its strengthened 

safeguards system is in detecting undeclared activities.

IAEA’s Ability to Detect 

Clandestine Nuclear 

Activities Is Limited 

because Many Countries 

Have Not Adopted the 

Additional Protocol

One of the major challenges IAEA faces in implementing strengthened 

safeguards is increasing the number of countries that bring the Additional 

Protocol into force, which would greatly expand the agency’s access to 

countries’ nuclear programs. Without the Additional Protocol in force, 

IAEA has limited ability to detect clandestine nuclear programs, and its 

inspection efforts remain focused on declared nuclear material and 

facilities. Of the 189 countries that have signed the NPT, 120 (or 63 percent) 

have not brought the Additional Protocol into force, including two of the 

five nuclear weapons states—the United States and Russia. Figure 2 shows 

the countries that have brought the Additional Protocol into force 

worldwide.
Page 24 GAO-06-93 Nuclear Nonproliferation

Figure 2: Status of the Additional Protocol by Country

Of the 120 countries that have not adopted the Additional Protocol, 28 are 

engaged in significant nuclear activities,12 including Argentina, Brazil, 

Egypt, North Korea, and Syria. Moreover, although Iran and Libya have 

allowed IAEA to investigate their past nuclear activities as if the Additional 

Protocol were in force, IAEA cannot fully implement all strengthened 

safeguards measures, such as unannounced inspections—an important 

tool in detecting illicit activities. Lastly, while 69 countries have brought the 

Source: GAO analysis of IAEA data, MapArt.

Countries that have not brought 

the Additional Protocol into force

Countries that have not formally

brought the Additional Protocol into

force, but are acting as if the protocol

has been implemented

Countries that have brought 

the Additional Protocol into force

12IAEA defines a country with significant nuclear activities as one that has declared nuclear 

material in a facility or a location outside facilities.
Page 25 GAO-06-93 Nuclear Nonproliferation

Protocol into force, U.S. officials said that many of these countries do not 

pose a significant nuclear proliferation risk. 

IAEA has recognized that progress in getting countries to adopt the 

Additional Protocol since it was approved by the Board of Governors in 

1997 has been slow. In response, the agency has increased its efforts to 

encourage countries to adopt the Additional Protocol. In 2001, IAEA 

developed and began to implement a strategy to promote the 

implementation of the Additional Protocol through a number of outreach 

efforts, which included providing experts to assist countries in preparing 

their state declarations of nuclear activities and sponsoring technical 

workshops and seminars. For example, in 2004, IAEA sponsored seven 

training events at the national, regional, and international levels to improve 

countries’ nuclear material accounting and to explain what countries’ 

obligations would be under the Additional Protocol. Since IAEA 

implemented its strategy, 51 countries have brought the Additional 

Protocol into force. Further, in 2004, the United States, with support from 

the other G-8 group of countries, the European Union, and IAEA, sent 

demarches (or official requests) to 72 countries to urge them to bring the 

Additional Protocol into force and provide information on their efforts to 

bring it into force. The Department of State received responses from 47 

countries. Finally, in an effort to draw attention to countries that have not 

brought the Additional Protocol into force, IAEA has begun to list their 

names in its yearly safeguards report to the Board of Governors. 

Despite these efforts, the agency faces a number of challenges in getting 

more countries to adopt the Additional Protocol. According to responses to 

the Department of State’s demarches and discussions with U.S. and IAEA 

officials, some member states are hesitant to implement the Additional 

Protocol because of (1) concerns about the financial costs associated with 

it; (2) an unwillingness to submit to an intrusive inspection regime; (3) their 

inadequate regulatory systems to collect information on all nuclear-related 

activities; and (4) political factors, such as the time needed for national 

legislatures to approve the Additional Protocol. For example: 

• Brazil has delayed signing, stating that the measures under the 

Additional Protocol do not need to be universally applied to all 

countries and that inspections and IAEA requests for information are 

overly intrusive; 
Page 26 GAO-06-93 Nuclear Nonproliferation

• Egypt will not bring the Additional Protocol into force until Israel signs 

the NPT, concludes a comprehensive safeguards agreement, and 

implements the Additional Protocol; and 

• Serbia and Montenegro’s national legislature has to approve the 

Additional Protocol before it can proceed with developing an adequate 

nuclear regulatory system.

In addition, the United States has been slow to bring its Additional Protocol 

into force. According to IAEA officials, this presents a challenge because it 

weakens U.S. efforts to encourage other countries to bring their additional 

protocols into force. Although the United States signed its Additional 

Protocol in June 1998, the U.S. Senate did not provide its advice and 

consent until March 2004—a first step toward U.S. ratification of the 

Protocol.13 As a condition for ratifying the Protocol to make it legally 

binding on the United States, the Senate directed the President to meet 

certain conditions, including completing vulnerability assessments of U.S. 

nuclear facilities and developing regulations that limit or exempt certain 

nuclear facilities from IAEA inspections where those inspections could 

compromise sensitive proprietary or national security information.

Since March 2004, the Departments of State, Energy, Commerce, and 

Defense and the Nuclear Regulatory Commission have been involved in 

outreach, data collection, and other tasks, such as developing regulations 

for commercial nuclear facilities and completing vulnerability assessments, 

to meet the Senate’s conditions for ratification. Once the conditions are 

met, the President must ratify the Protocol in order to bring it into force. In 

addition, before the regulations to implement the Protocol can be 

published, U.S. officials said that Congress must pass legislation that 

establishes the legal framework for U.S. agencies to collect information on 

commercial nuclear activities and facilities, and grant access to IAEA 

inspectors. U.S. officials told us that adopting the Additional Protocol 

would underscore U.S. support for IAEA’s strengthened safeguards system 

and make U.S. efforts to encourage more countries to adopt the Additional 

Protocol more effective and credible. However, according to officials from 

the Departments of Commerce, Defense, Energy, and State and the Nuclear 

Regulatory Commission, there is no specific time frame for meeting the 

Senate’s conditions for ratification. 

13The U.S. Senate must consent to all international treaties before they enter into force.
Page 27 GAO-06-93 Nuclear Nonproliferation

IAEA Safeguards Are 

Significantly Limited or Not 

Applied in More than Half of 

the NPT Signatories

A second major challenge hampering IAEA’s ability to implement 

strengthened safeguards is that safeguards are significantly limited or not 

applied to about 60 percent, or 113 out of 189, of the NPT signatories: 76 

countries with agreements (known as small quantities protocols) in force 

that limit the agency’s ability to implement most strengthened safeguards 

measures and 37 countries that have not concluded a comprehensive 

safeguards agreement with the agency. As a result, IAEA cannot conduct 

inspections and independently verify that nuclear material has been placed 

under safeguards and is not being diverted to clandestine nuclear activities. 

In addition, IAEA has limited information and authority concerning nuclear 

activities in countries that are not signatories to the NPT—India, Israel, and 

Pakistan—and in North Korea, which recently withdrew from the NPT. 

Countries with Small Quantities 

of Nuclear Material Pose a 

Weakness to the Safeguards 

System

Countries with small quantities of nuclear material make up about 40 

percent of the NPT signatories and almost one-third of the countries that 

have the Additional Protocol in force.14 Since 1971, IAEA’s Board of 

Governors has authorized the Director General to conclude an agreement, 

known as a small quantities protocol, with 90 countries and 76 of these 

agreements were in force, as of July 2005. IAEA’s Board of Governors has 

approved the protocols for these countries without having IAEA verify that 

they met the requirements for it. Even if these countries bring the 

Additional Protocol into force, IAEA does not have the right to conduct 

inspections or install surveillance equipment at certain nuclear facilities. 

According to IAEA and Department of State officials, this is a weakness in 

the agency’s ability to detect clandestine nuclear activities or 

transshipments of nuclear material and equipment through the country. In 

February 2005, IAEA’s Director General stated that these small quantities 

protocols pose a challenge to the safeguards program. In response, IAEA 

submitted a proposal to the Board of Governors recommending that the 

board stop approving small quantities protocols and give IAEA the 

authority to negotiate with countries to rescind them. At the very minimum, 

the proposal recommended that IAEA be allowed to conduct inspections 

and limit the protocols to countries without any nuclear facilities. In 

September 2005, the Board of Governors endorsed IAEA’s view that small 

quantities protocols constituted a weakness of the safeguards system and 

14IAEA refers to a small quantity of nuclear material as being, among other things, less than 

one kilogram of plutonium or uranium with an enrichment of greater than 20 percent 

Uranium-235. 
Page 28 GAO-06-93 Nuclear Nonproliferation

directed IAEA to negotiate with countries to make changes to the 

protocols, including reinstating the agency’s right to conduct inspections. 

Some Countries Do Not Have 

Comprehensive Safeguards 

Agreements with IAEA

The application of safeguards is further limited because 37 countries that 

have signed the NPT have not brought into force a comprehensive 

safeguards agreement with IAEA. The NPT requires non-nuclear weapons 

states to conclude comprehensive safeguards agreements with IAEA within 

18 months of becoming a party to the Treaty. However, IAEA’s Director 

General has stated that these 37 countries have failed to fulfill their legal 

obligations. Moreover, 28 of the 37 have not yet brought comprehensive 

safeguards agreements into force more than 10 years after becoming party 

to the NPT, including Kenya, Niger, and Turkmenistan. In 2005, IAEA 

reported that some countries do not have comprehensive safeguards 

agreements with the agency because they (1) consider concluding an 

agreement a low priority compared with other national priorities, (2) have 

an insufficient understanding of the legal requirements to implement 

safeguards, and (3) lack a nuclear regulatory system to implement 

safeguards. As part of its strategy to help countries better understand and 

prepare for implementation of comprehensive safeguards agreements, 

IAEA is involved in a number of outreach efforts, such as seminars and 

workshops. However, according to IAEA officials, the agency is limited in 

its ability to encourage countries to conclude a comprehensive safeguards 

agreement because the agency is not responsible for enforcing compliance.

IAEA Has Limited Ability to 

Assess Nuclear Activities of 

Countries That Are Not Members 

of the NPT 

Another weakness in the strengthened safeguards system is that IAEA has 

only limited information about the nuclear activities of India, Israel, and 

Pakistan, which are not members of the NPT. Since these three countries 

are not signatories to the NPT, they do not have comprehensive safeguards 

agreements with IAEA, and are not required to declare all of their nuclear 

material to the agency. Instead, they have special safeguards agreements 

that limit the scope of the agency’s safeguards activities to monitoring only 

specific material, equipment, and facilities. In addition, under their special 

safeguards agreements, these countries are required to declare only 

exports of safeguarded nuclear material. With the recent revelations of the 

illicit international trade in nuclear material and equipment, IAEA officials 

told us that they would like more information, in particular, on these 

countries’ nuclear exports. 

IAEA also has limited information on the nuclear activities of North Korea. 

North Korea signed the NPT in 1985 and concluded a comprehensive 

safeguards agreement with IAEA in 1992. IAEA inspections conducted 

between 1992 and 1994 uncovered numerous discrepancies in North 
Page 29 GAO-06-93 Nuclear Nonproliferation

Korea’s nuclear material declarations. For example, when IAEA inspectors 

conducted environmental sampling tests of equipment at the declared 

facilities, they discovered a discrepancy between what North Korea 

reported and what the inspectors’ independent analysis revealed. Based on 

the analysis of these samples, IAEA determined that North Korea might 

have continued to reprocess plutonium much later than stated in its 

declaration and in much larger quantities than reported. In 1993, North 

Korea restricted IAEA’s inspection activities and never allowed the agency 

to resolve the discrepancies. Beginning in 1994, IAEA’s activities in North 

Korea were limited to verifying the stoppage, or freeze, of North Korea’s 

nuclear activities, as called for in an agreement negotiated between the 

United States and North Korea. In December 2002, North Korea expelled 

IAEA inspectors; removed surveillance equipment and seals at nuclear 

facilities; and, in January 2003, announced its withdrawal from the NPT. 

These actions have raised widespread concern that North Korea diverted 

some of its nuclear material to produce nuclear weapons. 

IAEA May Lose Critical 

Skills and Knowledge 

because of Difficulties in 

Filling Key Positions and 

Restrictive Personnel 

Policies

Another major challenge facing IAEA is a looming human capital crisis that 

may hamper the agency’s ability to meet its safeguards mission. About 51 

percent, or 38 out of 75, of IAEA’s senior safeguards inspectors and highlevel management officials, such as the head of the Department of 

Safeguards and the directors responsible for overseeing all inspection 

activities of nuclear programs, are retiring in the next 5 years.15 According 

to U.S. officials, this significant loss of knowledge and expertise could 

compromise the quality of analysis of countries’ nuclear programs. For 

example, several inspectors with expertise in uranium enrichment 

techniques, which is a primary means to produce nuclear weapons 

material, are retiring at a time when demand for their skills in detecting 

clandestine nuclear activities is growing. 

15In 2004, the Department of Safeguards had 552 staff members. Of these, 251 were 

safeguards inspectors.
Page 30 GAO-06-93 Nuclear Nonproliferation

The loss of this expertise raises concerns for IAEA and U.S. officials 

because IAEA is finding it increasingly difficult to recruit qualified 

inspectors. In 2004, less than 10 percent of the applicants applying for 

inspector positions at IAEA were considered well qualified. IAEA’s 

recruiting difficulties arise because of, among other things, a shrinking pool 

of people pursuing careers in the nuclear field in most countries and 

intense competition from the private industry for their services. For 

example, in 2000, a group of experts from U.S. national laboratories and the 

Organization for Economic Cooperation and Development’s Nuclear 

Energy Agency warned that an alarmingly sharp downward trend in 

enrollment in nuclear engineering programs in most countries, and in 

particular in the United States, placed the availability of future nuclear 

expertise at risk. This downward trend has continued. As we reported in 

February 2005, fewer U.S. students were seeking advanced degrees or 

technical training in areas such as science and engineering.16 In addition, 

according to IAEA officials, the pool of qualified candidates that would 

meet all of the agency’s requirements, such as 6 years of experience in the 

nuclear field and knowledge of uranium enrichment or fuel reprocessing, 

can be found in only a limited number of countries worldwide. 

IAEA officials told us that it is also difficult to hire analysts for critical 

Department of Safeguards positions. For example, hiring satellite imagery 

analysts can be complicated because it may require approval by the 

candidates’ national governments because of the sensitive nature of these 

positions. In addition, in some cases, IAEA cannot provide competitive 

salaries for analyst positions. To help meet certain critical needs, such as 

open source analysis, the agency hires consultants, cost-free experts, and 

interns, primarily from the United States. 

While IAEA has taken a number of steps to address these human capital 

issues, officials from the Department of State and the U.S. Mission to the 

U.N. System Organizations in Vienna have expressed concern that IAEA is 

not adequately planning to replace staff with critical skills needed to fulfill 

its strengthened safeguards mission. In 2004, IAEA began to develop a plan 

that includes (1) determining skills and competencies needed to meet 

strengthened safeguards objectives, (2) identifying gaps in skills and 

competencies, (3) implementing human capital strategies that are targeted 

16GAO, National Nuclear Security Administration: Contractors’ Strategies to Recruit and 

Retain a Critically Skilled Workforce Are Generally Effective, GAO-05-164 (Washington, 

D.C.: February 2005).
Page 31 GAO-06-93 Nuclear Nonproliferation

toward addressing the gaps, and (4) evaluating the success of these 

strategies. According to IAEA officials, implementing this plan will allow 

the agency to determine the number of inspectors and support staff 

needed, and to develop better policies and practices to recruit and retain 

critical staff. However, at the time of our review, this plan was not in place 

because it had not yet been reviewed or approved by the Department of 

Safeguards’ management. IAEA has also begun to enhance its recruiting 

efforts by targeting employees with experience in enrichment and 

reprocessing activities at nuclear facilities in five countries with major 

nuclear programs. IAEA officials hope that this new approach will improve 

the agency’s chances of recruiting highly qualified candidates in an 

increasingly competitive job market. Despite these recruitment efforts, 

Department of State and U.S. Mission officials expressed concern that 

IAEA is not acting quickly enough to address the agency’s high turnover 

rate. 

Compounding a likely shortage of staff with critical skills, U.S. and IAEA 

officials identified a number of IAEA personnel policies and practices that 

hamper the Department of Safeguards’ ability to recruit and retain these 

highly specialized experts, including (1) a mandatory retirement age, (2) 

limits on the number of support staff who contribute to the analysis of 

safeguards-related information, and (3) delays in filling critical positions. 

First, IAEA’s mandatory retirement age of 62 has hindered the agency’s 

ability to fill critical skills.17 For example, former IAEA personnel, now with 

the Los Alamos National Laboratory, said that the agency is losing senior 

safeguards inspectors with unique expertise and knowledge about 

countries’ nuclear fuel cycles because of mandatory retirements. In one 

case, an individual who had worked for IAEA for 25 years and had been a 

section head in each of the Department of Safeguards’ three operations 

divisions was forced to retire. According to Department of State officials, 

this policy may be misguided at a time when the agency is having difficulty 

finding qualified staff. U.S. officials also told us that IAEA’s mandatory 

retirement policy is negatively impacting the United States’ ability to 

provide IAEA with critical technical support. For example, in 2003, IAEA 

asked the United States to provide an expert with a unique expertise in 

environmental sample analysis—a critical tool in detecting undeclared 

nuclear activities—but would not hire him because he was 62 years old. To 

17IAEA’s mandatory retirement age is based on the United Nations Joint Staff Pension Fund. 

The normal retirement age is 60, but 62 for personnel that were hired or rehired on or after 

January 1, 1990.
Page 32 GAO-06-93 Nuclear Nonproliferation

prevent losing this expertise, the United States hired him as a part-time 

consultant to IAEA but at a higher cost. Although Department of State 

officials have raised these concerns with IAEA officials, IAEA officials have 

stated that they follow the United Nations retirement policy, which was 

approved by IAEA’s Board of Governors, and generally do not make 

exceptions, even to hire or retain highly skilled staff. 

Second, in 2004, Department of Safeguards officials reported that there was 

pressure across the agency to reduce the number of support staff. They 

found that this practice was shortsighted because support staff in the 

Department of Safeguards include not only secretaries and clerks in 

administrative positions, but also technicians who install unattended 

remote monitoring equipment and open source information analysts. 

According to Department of Safeguards officials who manage support staff, 

they do not have enough staff to meet growing strengthened safeguards 

requirements, such as technicians and engineers to test and install new 

surveillance and remote monitoring equipment. For example, in 2003, IAEA 

officials reported that they could not adequately test and install new 

surveillance and unattended monitoring systems at Chernobyl and a facility 

in Switzerland because of the lack of staff. This shortage increased the risk 

of failure of agency equipment because of accelerated testing and 

assembly.18 IAEA continues to rely heavily on the United States to supply 

experts and short-term contractors to meet growing demand for these 

technical services. 

Lastly, according to U.S. and IAEA officials, delays in filling critical 

safeguards positions limit IAEA’s ability to implement strengthened 

safeguards measures and detect clandestine activities. In many cases, a 

new inspector or support staff member is hired after a position becomes 

vacant, and since it takes, on average, 6 months to hire new staff, the 

position is vacant for at least that amount of time. For example, it took 

more than 2 years to fill a senior technician position to analyze 

environmental samples at the Safeguards Analytical Laboratory. U.S. 

Mission officials told us that they are concerned that there may not be 

18In an October 2003 internal written assessment regarding IAEA equipment testing, IAEA 

officials expressed concern that monitoring systems at a third site—the Iranian enrichment 

facility at Natanz—was also not thoroughly tested. In reviewing a draft of this report, IAEA 

officials clarified that there are currently no unattended monitoring systems at the Natanz 

facility in Iran and that the inclusion of Iran in this written assessment was a mistake. 

According to these officials, IAEA has installed standard surveillance cameras that were 

thoroughly tested before deployment at the Natanz facility.
Page 33 GAO-06-93 Nuclear Nonproliferation

sufficient time to pass on the knowledge and skills of senior safeguards 

inspectors and other nuclear experts to new recruits before these more 

experienced safeguards personnel retire. While new staff have advanced 

degrees and previous work experience, they require additional, job-specific 

training and mentoring because of IAEA’s specialized work. According to 

IAEA officials, it usually takes 1 to 2 years for inspectors, technicians, and 

engineers to be fully comfortable and capable on the job. Furthermore, if 

experienced staff retire before new inspectors are prepared to meet all 

mission requirements, there may be a gap in skills. 

IAEA Lacks a System to 

Evaluate the Results of 

Strengthened Safeguards

IAEA does not have a system in place to measure how effective its 

strengthened safeguards system is in detecting undeclared activities. The 

performance measures IAEA has in place are output-driven and directed at 

measuring the agency’s ability to detect the diversion of nuclear material at 

declared facilities. For example, in its annual report to the Board of 

Governors, IAEA, among other things, reports on the declared quantities of 

nuclear material it accounted for and whether it met its goal of conducting 

routine inspections at declared facilities. According to Los Alamos National 

Laboratory officials, these indicators may be appropriate for measuring 

progress in detecting the diversion of nuclear material at declared facilities, 

but are not adequate to measure the effectiveness of strengthened 

safeguards activities to detect undeclared activities or nuclear material. 

These officials told us that IAEA should assess the extent to which its 

strengthened safeguards activities, such as environmental sampling and 

complementary access, are sufficient to detect clandestine activities and 

establish specific performance measures to evaluate these efforts. IAEA 

officials recognized the difficulties of measuring the effectiveness and 

impact of the agency’s strengthened safeguards activities.

In June 2005, IAEA’s Board of Governors established an advisory 

committee, based on a proposal by President Bush in 2004, to consider 

ways to strengthen IAEA’s safeguards system. According to Department of 

State officials, this committee would, among other things, systematically 

evaluate lessons learned from strengthened safeguards implementation 

and illicit trafficking of nuclear material, and then provide 

recommendations to the Board of Governors to further strengthen the 

safeguards system by 2007. The committee will have an initial 2-year 

mandate, which will be reviewed for extension after 2 years.
Page 34 GAO-06-93 Nuclear Nonproliferation

IAEA Depends Heavily 

on U.S. Financial 

Support to Meet Its 

Safeguards Obligations

The United States is the largest financial contributor to IAEA’s safeguards 

program, and for 2004, is providing over 34 percent of the agency’s total 

safeguards budget through assessed and voluntary cash contributions. 

IAEA’s reliance on U.S. financial support is likely to continue despite the 

agency’s recent budget increase because, among other reasons, the 

agency’s budget has not kept pace with its increased workload under 

strengthened safeguards, and cost-savings expected from the application of 

integrated safeguards have not yet materialized. Further, because the 

agency’s budget has not kept pace with its increased workload, IAEA 

depends on voluntary annual contributions from the United States and 

other countries to meet critical safeguards needs, such as equipment and 

funding for staff with specialized skills. In addition, IAEA’s ability to 

successfully negotiate future budget increases from member states is 

hampered by the absence of systematic evaluations of long-term resource 

needs, and its lack of reliable estimates of the costs of its strengthened 

safeguards activities.

The United States Is the 

Largest Financial 

Contributor to IAEA 

Safeguards

IAEA is heavily dependent on U.S. financial support to meet its safeguards 

obligations, and historically the United States has been IAEA’s primary 

supporter and its largest contributor. For 2004, the United States is 

providing $72.5 million to support IAEA’s strengthened safeguards 

program: $33.0 million in assessed contributions, $12.3 million in voluntary 

cash contributions, and $27.2 million from various U.S. agencies in 

technical support, such as analyzing environmental samples to detect the 

presence of nuclear material.19 Figure 3 provides a breakdown of U.S. 

contributions to IAEA’s safeguards program for 2004 by funding category.

19Roughly $4.1 million of U.S. assessed contributions to IAEA for calendar year 2004 had not 

been provided as of July 2005.
Page 35 GAO-06-93 Nuclear Nonproliferation

Figure 3: U.S. Contributions to IAEA’s Safeguards Program for 2004

For 2004, U.S. assessed and voluntary cash contributions represent over 34 

percent of IAEA’s total safeguards budget. These and other assessed and 

voluntary contributions provided by the United States to IAEA’s safeguards 

budget since 1998 are shown in table 1.

Assessed contributions ($33.0M)

Technical support ($27.2M)

17.0% Voluntary cash contributions ($12.3M)

37.5%

45.5%

Source: GAO analysis of data provided by IAEA, the Departments of Defense, Energy, and State, and the Nuclear Regulatory Commission.
Page 36 GAO-06-93 Nuclear Nonproliferation

Table 1: Contributions to IAEA’s Safeguards Budget from 1998 through 2004

Source: GAO analysis of data provided by IAEA and the Department of State.

Note: Numbers may not add due to rounding.

a

IAEA is one of 10 international organizations that the United States makes payments to on a deferred 

basis. In some cases, U.S. assessed payments to IAEA’s budget are not made in the same year for 

which they are assessed. Table 1 shows U.S. contributions to IAEA’s budget based on the year for 

which they were assessed, not the year in which the funds were actually paid.

b

IAEA’s total safeguards budget is calculated using actual exchange rates, rather than IAEA’s fixed 

exchange rate. As a result, changes in IAEA’s total safeguards budget, reflected in the table, largely 

represent inflationary cost increases and fluctuations in exchange rates rather than an actual change 

in IAEA’s budget. The exception is in 2004, when IAEA received the first part of a 4-year increase to its 

budget.

c

IAEA’s budget includes both dollar and non-dollar contributions. Non-dollar contributions are 

calculated using the annual average exchange rate based on the International Monetary Fund’s 

International Financial Statistics.

d

A portion of the U.S. contribution to IAEA’s budget is made in dollars, while a portion is made in euros. 

Prior to the introduction of the euro in 2002, U.S. non-dollar contributions to IAEA’s budget were made 

in Austrian schillings. The U.S. contribution to IAEA’s budget is calculated using the average monthly 

exchange rate for the month in which the euro/Austrian schilling payment was made to IAEA. 

Exchange rates are based on the International Monetary Fund’s International Financial Statistics.

e

For purposes of this report, U.S. voluntary contributions to IAEA include only cash contributions, and 

do not include technical assistance, which is also provided on a voluntary basis.

Dollars in millions

Yeara

IAEA’s total

safeguards

budgetb

U.S. contributions

to IAEA’s total

safeguards budget

(and percentage of

total)

IAEA’s

assessed

safeguards

budgetc

U.S. assessed

contributions to

IAEA’s

safeguard’s

budgetd

 (and

percentage of

total)

Voluntary cash

contributions to

IAEA’s safeguards

budget

U.S. voluntary cash

contributionse

 (and

percentage of total)

1998 $90.6 $30.8 (34.0%) $80.5 $23.1 (28.7%) $10.2 $7.7 (75.7%)

1999 89.8 29.5 (32.9) 79.3 20.7 (26.2) 10.5 8.8 (83.4)

2000 84.2 29.5 (35.0) 70.9 17.9 (25.3) 13.3 11.6 (86.8)

2001 88.9 35.3 (39.8) 70.1 18.6 (26.6) 18.7 16.7 (89.2)

2002 95.5 37.7 (39.5) 77.9 22.5 (28.9) 17.6 15.2 (86.2)

2003 111.8 42.7 (38.2) 92.9 26.5 (28.6) 19.0 16.1 (85.2)

2004 132.6 45.3 (34.2) 115.2 33.0 (28.6) 17.4 12.3 (71.0)
Page 37 GAO-06-93 Nuclear Nonproliferation

For 2004, the U.S. assessed contribution to IAEA’s safeguards budget is 

about $33.0 million, which IAEA uses to fund safeguards inspections, staff 

salaries, training, and other costs directly related to the operation of IAEA’s 

safeguards program. The U.S. assessment to IAEA’s budget is based on a 

scale used by the United Nations to assess contributions for its members.20

The U.S. assessed safeguards contribution for 2004 is about 35 percent 

more than IAEA’s second largest financial supporter, Japan.

The United States has also been the largest contributor of voluntary funds 

to IAEA’s safeguards program. Our analysis shows that from 1998 through 

2004, U.S. voluntary cash contributions, on average, were 83 percent of the 

total of all such member states’ contributions. Other countries making 

voluntary contributions included Canada, France, Germany, Japan, and the 

United Kingdom. In 2004, the United States provided over $12.3 million in 

voluntary funds to IAEA’s safeguards program. These funds were provided 

by the Department of State and included

• $4.36 million for the purchase of safeguards equipment;

• $4 million for the U.S. Program of Technical Assistance to IAEA 

Safeguards (POTAS)—managed by Brookhaven National Laboratory—

to fund safeguards equipment at a nuclear facility in Japan, and paying 

travel costs for IAEA staff associated with POTAS-funded projects;

• $2 million to assist IAEA in re-engineering the Department of 

Safeguards’ information management system;

• $1.2 million to cover IAEA’s costs of applying safeguards to excess 

nuclear material at U.S. facilities; and

20The U.S. assessment is 25 percent of IAEA’s budget—the maximum assessment for IAEA 

member states. IAEA retained this ceiling despite a United Nations’ decision in 2000 to 

reduce its maximum assessment to 22 percent. However, the United States, along with 31 

other countries, contributes slightly more than 25 percent of the safeguards budget to 

compensate for some countries that are assessed at a lower rate. In July 2003, IAEA’s Board 

of Governors decided to require some countries that pay less to contribute more as of 

January 1, 2006. The remaining countries that pay less will be required to begin contributing 

more as of January 1, 2008.
Page 38 GAO-06-93 Nuclear Nonproliferation

• $770,500 for high priority safeguards projects.21

In addition to U.S. assessed and voluntary safeguards contributions, we 

estimated that, in 2004, the Departments of State, Energy, and Defense and 

the Nuclear Regulatory Commission provided IAEA with $27.2 million in 

technical support. For example:

• DOE spent almost $12.7 million on various activities, including applying 

safeguards at nuclear facilities in other countries, developing 

technologies to detect and characterize the isotopic composition of 

uranium and plutonium, and providing training on nuclear material 

accounting and control;

• the Department of State provided over $9.2 million for POTAS activities 

such as funding U.S. national laboratories to develop and implement 

safeguards technologies and funding Brookhaven National Laboratory 

officials to support IAEA’s safeguards activities, interns and consultants 

to IAEA, and other high priority safeguards projects;

• the Departments of Energy, State, and Defense spent over $5.2 million 

analyzing environmental samples taken by IAEA to detect and 

characterize the types of nuclear material present at selected locations; 

and

• NRC spent $29,500 in staff costs to assist IAEA in developing IAEA 

safeguards procedures and practices.

For 2005, the United States is expected to contribute almost $34.3 million 

to IAEA’s regular safeguards budget, or about 33 percent more than Japan. 

Also, we estimate that for 2005, the Department of State will provide $11.4 

million in voluntary cash contributions to IAEA’s safeguards program, and 

that various U.S. agencies will provide $23.3 million in technical support.

21The U.S. contribution for high priority safeguards projects had not been expended as of 

September 2005.
Page 39 GAO-06-93 Nuclear Nonproliferation

IAEA Will Continue to Rely 

on U.S. Voluntary Support, 

Despite an Increase in Its 

Regular Budget

In 2004, IAEA’s safeguards budget was increased by $11.1 million—the first 

part of a 4-year, $19.4 million increase agreed to by member states. For 

almost two decades prior to 2004, member states generally limited growth 

in IAEA’s budget to adjustments for inflation and staff salaries. Additionally, 

the agency’s ability to increase funding for safeguards activities has been 

limited by some member states’ desire to maintain a balance of funding 

between IAEA’s safeguards and technical cooperation programs. As a 

result, Department of State officials said that a shortfall developed between 

the growing demands on IAEA from strengthened safeguards activities and 

its available budget. For example, IAEA was not able to hire additional staff 

(inspectors and equipment technicians) as its safeguards responsibilities 

increased. To address this shortfall, the United States led a successful 

effort to increase IAEA’s budget.22 According to Department of State and 

IAEA officials, the agency has used its budget increase to hire additional 

staff and purchase new safeguards equipment, such as unattended 

monitoring systems.

Despite the increase in the agency’s safeguards budget, IAEA will continue 

to rely on U.S. voluntary contributions. Department of State officials said 

that even with the budget increase, IAEA’s safeguards program remains 

underfunded because its budget has not kept pace with increases in its 

workload and responsibilities. As part of the U.S.-led effort to increase 

IAEA’s regular budget, a Department of State analysis found that the agency 

would need around $30 million—$10.6 million more than the actual 

increase—to meet its strengthened safeguards responsibilities. 

Brookhaven National Laboratory officials also questioned whether the 

safeguards budget increase will be sufficient to meet future needs because 

of the agency’s growing responsibilities under strengthened safeguards. 

For example, the officials said it is unclear how IAEA will finance 

increased activities stemming from the Additional Protocol, such as 

analyzing environmental samples, or fund improvements to the agency’s 

safeguards information management system.

22Department of State officials said that the department’s policy has been, and continues to 

be, restricted growth in the budgets of international organizations. The department has 

made exceptions for substantive policy reasons, such as security-related interests. However, 

Department of State officials also said that they have tried to maintain pressure on IAEA to 

identify efficiencies to allow the reallocation of resources to high priority activities such as 

safeguards.
Page 40 GAO-06-93 Nuclear Nonproliferation

In addition, IAEA officials said the agency will continue to rely on 

voluntary funding, primarily from the United States, to purchase equipment 

and maintain a research and development program. One IAEA official told 

us that the purpose of the agency’s budget increase was, in part, to ensure 

that the budget covers most of the agency’s equipment needs by 2007. 

However, agency officials responsible for managing and maintaining 

safeguards equipment told us that while the safeguards budget increase 

gave IAEA the ability to meet 70 percent of its equipment needs beginning 

in 2004, the remaining 30 percent will be met almost exclusively using 

voluntary contributions from the United States. Furthermore, additional 

equipment requirements resulting from the implementation of 

strengthened safeguards are likely to increase the agency’s reliance on 

voluntary funds. Finally, IAEA officials stated that the agency cannot 

maintain a research and development program without member states’ 

voluntary support because it does not have the financial resources or 

technical expertise.

Country-specific events could also require increased resource 

commitments by IAEA that may strain the agency’s safeguards budget. 

IAEA officials said that demands on the agency’s budget are driven by 

events in individual countries. For example, IAEA officials said that Japan’s 

new reprocessing plant at Rokkashomura—the largest under agency 

safeguards—will require a significant investment of safeguards resources, 

including an on-site laboratory to analyze nuclear material samples and an 

increase in inspection activity roughly equal to the efforts of 10 

inspectors.23 IAEA indicated that funds for these new inspectors were 

included in the budget increase, as well as $727,000 for the on-site 

laboratory. Further, in the July 2005 agreement between the United States 

and India, India agreed to place its civilian nuclear facilities under IAEA 

safeguards. Department of State officials said that the agreement could 

increase IAEA’s resource commitments because of the additional nuclear 

material that IAEA could be required to safeguard. Also, recent events in 

Iran and Libya have forced IAEA to commit more safeguards resources for 

inspections and analyzing an increased quantity of environmental samples.

23IAEA attempts to quantify the costs of anticipated increased resource commitments in its 

budget. In part, these estimates are presented as core activities for which the agency 

expects to receive voluntary contributions, or for which the agency has not identified a 

funding source.
Page 41 GAO-06-93 Nuclear Nonproliferation

Additionally, according to IAEA, Department of State, and Brookhaven 

National Laboratory officials, a change in the European Atomic Energy 

Community’s (EURATOM) participation in safeguards activities could 

place an additional financial burden on IAEA. In the past, EURATOM has 

shared the costs of safeguards activities by participating in inspections and 

maintaining safeguards equipment at its members’ facilities. However, in 

December 2004, EURATOM informed IAEA of its intention to reduce its 

participation in inspections and the sharing of equipment costs. While 

EURATOM’s decision had not been finalized as of May 2005, an IAEA 

official estimated EURATOM’s withdrawal from safeguards activities could 

require the agency to hire 5 to 9 additional inspectors and 6 or 7 technicians 

to conduct inspections and maintain equipment at European Union nuclear 

facilities. Additionally, Department of State officials said that reduced 

participation in safeguards by EURATOM would require IAEA to replace 

safeguards equipment at European Union facilities, and estimated that this 

would cost around $1.5 million per year over the next 4 to 5 years.

At the same time, cost-savings that IAEA expected to achieve from 

integrated safeguards have not yet materialized. In our 1998 report, we 

questioned IAEA’s assumptions about cost-savings from integrated 

safeguards because at that time, the agency did not know the extent to 

which its new measures would allow it to reduce inspections. Further, we 

stated that savings in cost and inspector effort from applying integrated 

safeguards might not be fully realized. While IAEA has reduced inspection 

activities in some countries where it has applied integrated safeguards, 

there has been an increase in headquarters staff needed to analyze data 

received from unattended monitoring systems installed at nuclear facilities 

and collected from open source information. Moreover, the time it takes for 

IAEA staff to prepare for complementary access is double the preparation 

time for routine inspection activities. For example, IAEA officials 

estimated that complementary access requires 4 days of preparation and 

analysis at headquarters for every day of inspection, as opposed to 2 days 

of preparation and analysis for routine inspections. In addition, even 

though advanced technologies have reduced the need for physical 

inspections at certain facilities, IAEA officials told us that the purchase, 

installation, and maintenance costs of this equipment may exceed savings 

from fewer inspections. Lastly, under integrated safeguards, IAEA may 

increase inspection activities at certain locations to ensure that a country is 

not engaged in clandestine nuclear activities.

IAEA told us that the first few countries where integrated safeguards were 

being applied had small nuclear programs, which limited the potential cost-
Page 42 GAO-06-93 Nuclear Nonproliferation

savings. IAEA officials told us that the agency expects to achieve more 

cost-savings as more countries, such as Canada, Germany, and Japan, apply 

integrated safeguards. However, a former high-ranking Department of 

Safeguards official told us that thus far, the increasing costs of 

complementary access to verify the accuracy and completeness of 

information contained in countries’ declarations, among other factors, have 

offset cost-savings from reduced inspection activities in countries with 

integrated safeguards.

We also found that in some instances, IAEA does not make the most 

efficient use of its safeguards resources. For example:

• Brookhaven National Laboratory officials were concerned that IAEA’s 

use of U.S. voluntary contributions to pay for business class travel, 

instead of taking advantage of economy class fares, is not cost effective. 

One Brookhaven official said that this takes resources away from other 

safeguards priorities such as paying for equipment or training. For 

example, the official said that for trips from Vienna, Austria, to 

Albuquerque, New Mexico (near Los Alamos National Laboratory where 

some training courses are held for IAEA staff), IAEA obtains business 

class tickets costing $3,300 or less. However, the official said that these 

tickets, when purchased in advance at economy class rates, rarely cost 

more than $2,000 and are often less. Further, we estimate that economy 

class rates for these tickets currently average $1,235.24 IAEA officials 

acknowledged that in some cases business class tickets are more costly 

than economy class, but said that most often the difference between 

business class and economy class tickets is paid by IAEA, not by U.S. 

voluntary contributions. In reviewing a draft of this report, IAEA 

officials stated that the agency’s policy is to fly economy class whenever 

practicable. However, the officials said that IAEA’s travel regulations 

allow the agency to use business class travel for trips over 7 hours in 

duration. IAEA officials emphasized that in such cases, the agency tries 

to take advantage of reduced business class fares whenever possible.

• In some cases, IAEA’s restrictive personnel policies cause agency 

resources to be used inefficiently. As was mentioned previously, IAEA 

could not hire an individual as a cost-free expert despite his critical 

24Estimates are from SatoTravel, the leading provider of travel services for the U.S. 

government. Rates are for July through September 2005. The economy class estimate is an 

average of the government and civilian rates.
Page 43 GAO-06-93 Nuclear Nonproliferation

expertise in detecting traces of nuclear material contained in 

environmental samples because he was 62—IAEA’s mandatory 

retirement age. Cost-free experts are hired by IAEA using countries’ 

voluntary contributions to provide short-term skills that IAEA lacks 

among its regular staff. To retain his expertise, the United States hired 

and paid this individual as a consultant to IAEA. However, as a 

consultant, this individual is only working on a part-time basis, and the 

United States is required to pay him $56,000 more than his position 

would cost as a cost-free expert over a 2-year period.

• IAEA’s policy of rotating technical staff causes the agency to incur 

additional costs related to training replacement staff. Although IAEA 

officials could not quantify these costs, they said that the agency’s policy 

of rotating technical staff every 7 years causes many technicians and 

engineers to leave early to pursue careers elsewhere. As a result, IAEA 

is continually faced with having to train new staff to operate and 

maintain its specialized equipment. In addition, because of the difficulty 

it has in maintaining sufficient numbers of trained technical staff, IAEA 

has less time for testing and installing equipment, which increases the 

risk of failures. A former head of IAEA’s unit for unattended monitoring 

systems said that if this equipment fails, IAEA would have to expend a 

significant amount of resources to go back and verify all of the nuclear 

material in that facility.

IAEA Does Not 

Systematically Evaluate 

Long-Term Resource 

Requirements or Reliably 

Estimate Safeguards Costs

IAEA does not have a process in place to systematically evaluate its longterm resource requirements. Given member states’ reluctance over the past 

2 decades to increase IAEA’s budget, future increases may depend upon the 

agency’s ability to make a convincing case that additional resources are 

required to meet safeguards obligations. Good strategic planning practices, 

which would help to make such a case, include describing the relationship 

between long-term goals and budgetary needs. However, while IAEA has 

developed 5-year medium-term strategies for its activities, these plans are 

not linked to longer-term budgetary requirements because IAEA’s budget 

process and research and development plan are only designed to forecast 

resource needs on a 2-year basis. In 2004, a group of safeguards experts 

found that IAEA needed to increase linkages between its medium-term 

strategy, the strategic objectives of the Department of Safeguards, and the 

agency’s program and budget. Department of State officials also stated that 

although IAEA has substantially improved its planning, the agency could 

still have better assessments of its long-term budgetary needs. Additionally, 

Brookhaven National Laboratory officials said that IAEA needs to develop 
Page 44 GAO-06-93 Nuclear Nonproliferation

a long-term plan to better prioritize tasks and tie goals and timeframes to 

financial resources. Furthermore, a February 2005 report by IAEA’s Office 

of Internal Oversight Services that evaluated the agency’s management of 

member states’ voluntary contributions, found that while the Department 

of Safeguards’ biennial research and development plan provides adequate 

planning for activities 2 to 3 years into the future, IAEA lacks an effective 

process for identifying and investigating new safeguards technologies for 

the detection of undeclared nuclear material and activities beyond the 2 to 

3 year-timeframe. As a result, the office recommended that IAEA develop a 

long-term plan for research and development activities.

IAEA has taken steps to improve its short-term budget and planning 

process. For example, IAEA has implemented results-based budgeting that 

links objectives, outcomes, and performance indicators to estimates of 

resource needs in the agency’s biennial budget. Furthermore, IAEA officials 

said that they did detailed resource planning as part of the agency’s efforts 

to negotiate the 2004 budget increase. Specifically, IAEA developed a 

document that identified each project in the safeguards program, provided 

information on the project’s needs over the 2004-2005 budget period, and 

indicated how these needs were reflected in the requested budget increase. 

However, IAEA officials said that this was an effort that required a 

significant amount of planning and negotiating.

Another impediment to systematically evaluating long-term resource 

requirements is that IAEA does not have reliable estimates on the costs of 

all of its strengthened safeguards activities—particularly those costs 

related to increased activity levels at IAEA headquarters, such as analyses 

of countries’ declarations of their nuclear activities. For example, a 2004 

review of the safeguards program by a group of safeguards experts found 

that one measure of costs IAEA used in the past—person days of 

inspection—actually accounted for only 30 percent of the safeguards 

budget in 2003. Therefore, attempting to use this measure to represent the 

costs of all IAEA’s safeguards activities was problematic because the 

majority of safeguards activities are unrelated to the costs of person days 

of inspection. Department of State officials also said that IAEA’s measures 

of safeguards costs are inadequate. In particular, they said that the person 

days of inspection measure does not account for differences in the type of 

inspection performed and the costs of equipment and technologies used. 

Additionally, they said that this measure represents the number of 8-hour 

days spent inspecting a facility. However, even if the inspection lasts less 

than 8 hours, it still counts as a full day of inspection. Furthermore, without 

good measures of the costs of all its safeguards activities, IAEA has 
Page 45 GAO-06-93 Nuclear Nonproliferation

difficulty setting benchmarks, which it could use to measure whether 

alternative approaches to safeguarding nuclear material, such as integrated 

safeguards, actually result in cost-savings. For example, the 2004 review of 

the safeguards program found that IAEA’s lack of accurate cost information 

was an impediment in assessing the efficiency of its operations.

One high-ranking Department of Safeguards official told us that the agency 

has difficulty estimating the costs of safeguards activities. The official 

noted that while IAEA’s Department of Safeguards has introduced a new 

measure—calendar days in the field—which helps to estimate travel and 

labor costs, it still does not capture the costs related to other safeguards 

activities, such as complementary access. The official said that the agency 

has assigned a staff member and requested a French expert to work on 

developing a new methodology to calculate the costs of safeguards 

activities. Additionally, IAEA incorporated a project into its 2004-2005 

budget to use statistical information, including the cost of activities related 

to the Additional Protocol, to achieve more efficient and effective program 

planning, monitoring, and resource management.

According to Department of State officials, Congress authorizes voluntary 

funding for IAEA’s safeguards program to meet requirements that cannot be 

met from its assessed budget. The officials said that the purpose of this 

funding is not to pay for normal agency operating costs. However, without 

adequate measures of the costs of all its strengthened safeguards activities 

and a systematic process to use these measures to identify long-term 

resource needs, IAEA may be unable to convince member states of its 

budgetary needs. As a result, IAEA will continue to rely on some member 

states’ voluntary contributions—provided in large part by the United 

States—for recurring and critical costs. For example:
Page 46 GAO-06-93 Nuclear Nonproliferation

• IAEA’s 2004-2005 budget identified a number of core activities for which 

no budgetary funds were available, including almost 11 percent of the 

costs of safeguarding nuclear material in countries with safeguards 

agreements. IAEA anticipated that member states would provide about 

$10.9 million in voluntary support for these activities. However, IAEA’s 

2004-2005 budget also identified an estimated $5.75 million in potential 

safeguards activities, such as applying safeguards at nuclear facilities in 

North Korea should it agree to resume IAEA inspections, for which the 

agency did not have budgetary funding and did not anticipate receiving 

voluntary support.25

• A 2004 independent review of IAEA’s Safeguards Analytical Laboratory 

found that in some cases, supplies needed for routine maintenance of 

safeguards equipment were not funded by IAEA’s safeguards budget, but 

instead were included in agency requests for voluntary support. As a 

result, some instruments were inoperable for up to a year because 

necessary spare parts were funded through voluntary contributions. The 

review also found that IAEA’s voluntary requests included funding to 

maintain its laboratory facilities, and recommended that routine 

maintenance needs of laboratory equipment and facilities should be 

included in IAEA’s budget. IAEA said that all essential and routine 

equipment needs have been included in the agency’s current budget.

• Department of State officials said that the United States is concerned 

that in some cases IAEA is relying on cost-free experts—many of which 

are funded by U.S. voluntary support—on a long-term basis when it 

should really be creating permanent positions and filling them. 

According to Brookhaven National Laboratory officials, cost-free 

experts are intended to provide short-term specialized skills that are not 

available among IAEA staff. These positions are not intended to be an 

extension of IAEA’s regular staff. As a result, the officials said that the 

United States is generally reluctant to extend funding for cost-free 

experts beyond four years. However, without the cost-free experts 

provided by the United States and other countries, IAEA would have 

difficulty finding staff to perform key strengthened safeguards activities, 

such as analyzing open source information and maintaining unattended 

25These unfunded core activities primarily represent safeguards activities that IAEA was 

unsure of implementing. Other unfunded core activities included applying safeguards at a 

reprocessing plant in India and additional efforts required as a result of EURATOM’s final 

decision.
Page 47 GAO-06-93 Nuclear Nonproliferation

surveillance equipment. IAEA noted that the agency has taken steps, 

such as developing a policy and an approval process, to ensure that costfree experts are not being relied on for routine services.

IAEA Has Increased 

Efforts to Help 

Countries Protect 

Their Nuclear Material 

and Facilities, but 

Reliance on Voluntary 

Contributions Poses a 

Challenge

Following September 11, 2001, IAEA increased its efforts to assist 

countries in protecting their nuclear and radiological materials and 

facilities. To support these activities, IAEA established a Nuclear Security 

Fund to which countries can provide voluntary budget contributions. 

However, IAEA’s heavy reliance on these voluntary contributions creates 

challenges in planning and implementing nuclear security activities. 

Increasing demands on the agency to provide nuclear security assistance 

could provide further challenges as well. Additionally, the United States has 

raised concerns about IAEA’s ability to track the use of nuclear security 

funds and measure the results of its activities in a systematic way. In 

response to these concerns, IAEA developed a system to track the use of 

Nuclear Security Fund contributions. However, the agency still does not 

systematically measure the results of its nuclear security efforts.

IAEA Has Increased Its 

Efforts to Help Countries 

Secure Their Nuclear 

Material and Facilities

In March 2002, IAEA’s Board of Governors approved an action plan to 

increase the agency’s assistance to prevent, detect, and respond to acts of 

terrorism against nuclear and radiological materials and facilities. IAEA’s 

nuclear security action plan consisted of eight areas encompassing efforts 

undertaken by IAEA prior to September 11, 2001, as well as new efforts 

developed in response to countries’ concerns about the potential for 

nuclear terrorism. These areas included enhancing the physical protection 

of nuclear material and facilities, improving countries’ ability to secure 

other types of radioactive material, and ensuring that measures are in place 

to detect and prohibit the illicit trafficking of materials. In order to better 

manage the implementation of its action plan, IAEA created an Office of 

Nuclear Security within a new Department of Nuclear Safety and Security.

IAEA’s nuclear security action plan has guided the agency’s efforts to help 

countries improve their security by, for example, developing guidance, 

facilitating advisory missions, providing training, improving response to 

illicit trafficking and emergencies, and coordinating security assistance. 

Specifically, since September 11, 2001, IAEA has published a variety of 

updated or newly drafted security guidelines and recommendations. For 

example, IAEA developed guidance on securing radioactive materials in 

transport and a handbook on combating illicit trafficking. In addition, in 
Page 48 GAO-06-93 Nuclear Nonproliferation

January 2004, IAEA published a revised Code of Conduct on the Safety and 

Security of Radioactive Sources to guide countries in developing policies, 

laws, and regulations on maintaining the safety and security of radioactive 

sources. The revised code includes, among other things, enhanced 

requirements for securing radioactive sources. As of June 2005, 73 

countries had committed to implementing the code. Further, in September 

2004, IAEA’s Board of Governors and General Conference approved new 

guidance on the import and export of radioactive sources, which is 

designed to help countries ensure that high-risk radioactive sources are 

supplied only to authorized end-users.

Furthermore, IAEA increased the types of advisory missions it offers 

countries upon their request, and facilitated over 100 missions to 43 

countries, including Argentina, Iran, Mexico, Nigeria, and Ukraine, between 

2001 and March 2005. To conduct these advisory missions, IAEA organizes 

teams of international experts to assess and make recommendations for 

improving countries’ nuclear security measures, such as the physical 

protection of their nuclear material and facilities, or their regulatory 

infrastructures. Since 2001, IAEA has also introduced advisory missions 

that go beyond the physical protection of material and facilities to look at 

the security of the entire country—including border controls—and assess 

countries’ systems of accounting and control of nuclear material.

In addition, IAEA provided nuclear security training for countries and 

individual country representatives and conducted almost 80 training 

courses for about 1,500 participants between 2001 and March 2005. IAEA’s 

training courses include instruction on general topics, such as the 

fundamental principles and objectives of physical protection, as well as 

more focused national training opportunities that cover countries’ 

programs and facility-specific needs, such as physical protection system 

design and the use of radiation detection instruments. IAEA targets some 

training on a regional basis to meet specific requirements, such as 

combating illicit trafficking and promoting regional cooperation. IAEA also 

offers training courses for nuclear operators and government and law 

enforcement officials on topics such as nuclear security awareness, 

combating illicit trafficking, and nuclear forensics.

IAEA also increased its efforts to assist countries in improving their 

capabilities to respond to incidents of illicit trafficking in materials and to 

nuclear and radiological emergencies. For example, IAEA encouraged 

countries to contribute data to its Illicit Trafficking Database to help 

identify trends in illicit trafficking through increased information exchange 
Page 49 GAO-06-93 Nuclear Nonproliferation

on incidents involving unauthorized acquisition, provision, possession, use, 

transfer, or disposal of nuclear and other radioactive materials. As a result 

of its outreach efforts, IAEA had increased the number of countries 

participating in the database from 25 to 81, as of June 2005. Furthermore, 

IAEA worked to improve countries’ abilities to respond to nuclear and 

radiological emergencies. In June 2004, IAEA’s Board of Governors 

approved efforts to assist countries to develop an international 

communication system for information on nuclear and radiological 

emergencies, provide international assistance for emergency response, and 

establish a sustainable international response infrastructure.

Finally, IAEA worked to improve coordination with member states that 

provide nuclear security assistance. For example, IAEA began to develop 

country-specific integrated nuclear security support plans to prioritize 

measures the agency identifies as necessary to assist countries to 

strengthen their nuclear security. According to an August 2004 status report 

on IAEA’s nuclear security efforts, these plans will help the agency to 

coordinate assistance provided by other countries—an important part of 

IAEA’s efforts to improve physical protection measures at facilities and 

illicit trafficking detection capabilities at international borders. As of 

December 2004, IAEA was developing integrated nuclear security support 

plans for 16 countries.

Heavy Reliance on 

Voluntary Contributions Has 

Created Challenges for 

IAEA’s Nuclear Security 

Efforts

In 2002, IAEA established a Nuclear Security Fund to support its nuclear 

security program, and countries had voluntarily contributed about $36.7 

million through mid-May 2005. However, IAEA’s heavy reliance on these 

voluntary contributions for about 89 percent of its nuclear security funding 

creates challenges for the agency in planning and implementing its 

activities. For example, the conditions most donors place on the use of 

their funds limit IAEA’s ability to direct resources to meet program needs. 

Given IAEA’s reliance on voluntary contributions, its ability to plan and 

implement nuclear security activities could be further challenged by, for 

instance, changes in the scope of an international security agreement that 

could increase countries’ requests for assistance.
Page 50 GAO-06-93 Nuclear Nonproliferation

IAEA Established the Nuclear 

Security Fund to Support Its 

Efforts

To implement its nuclear security action plan, in 2002, IAEA created the 

Nuclear Security Fund to which countries could provide voluntary 

contributions for the agency’s nuclear security activities. From 2002 

through mid-May 2005, 26 countries, the European Union, and one 

nongovernmental organization made voluntary contributions totaling about 

$36.7 million.26 In addition, a number of countries have contributed to 

IAEA’s nuclear security efforts by providing services, equipment, and the 

use of facilities.

The United States has made significant contributions to the Nuclear 

Security Fund. From 2002 through 2004, as shown in table 2, the U.S. 

Departments of State and Energy contributed approximately $21.6 

million—almost 61 percent of all contributions—to the Nuclear Security 

Fund. For example:

• DOE provided $9.95 million for radioactive material security;

• the Department of State provided $2.1 million to support advisory 

missions, training courses, and other efforts to improve the physical 

protection of nuclear materials;

• the Department of State contributed around $2.25 million to support 

illicit trafficking advisory missions, training courses, and other efforts to 

detect malicious activities involving nuclear and radiological materials;

• the Department of State provided $1.6 million to improve the 

coordination and management of nuclear security information by, for 

example, increasing the utility of IAEA’s Illicit Trafficking Database; and

• the Department of State also contributed $5.65 million for such efforts 

as improving countries’ systems of nuclear material accounting and 

control, providing a cost-free expert, and establishing a reserve fund for 

unanticipated expenses.

26Countries contributing to the Nuclear Security Fund included Australia, Austria, Bulgaria, 

Canada, the Czech Republic, Finland, France, Germany, Greece, Hungary, Iran, Ireland, 

Israel, Italy, Japan, the Republic of Korea, the Netherlands, New Zealand, Norway, Romania, 

Slovenia, Spain, Sweden, Ukraine, the United Kingdom, and the United States. The 

nongovernmental organization was the Nuclear Threat Initiative.
Page 51 GAO-06-93 Nuclear Nonproliferation

Table 2: U.S. Nuclear Security Fund Contributions, 2002–2004

Source: GAO presentation of IAEA data.

a

This total does not include interest on U.S. contributions to the Nuclear Security Fund. Also, it does 

not include $1.7 million pledged to the fund in 2003, but which IAEA did not receive before December 

31, 2004.

The Department of State estimated that it would provide $4.2 million to the 

Nuclear Security Fund in 2005, while DOE officials indicated that the 

Department will not provide direct contributions to the fund in 2005.

Furthermore, in 2004, DOE and NRC provided an estimated $3.3 million of 

other technical support for IAEA’s nuclear security activities. For example, 

DOE provided about $1.4 million for nuclear security experts to participate 

in IAEA’s advisory missions to improve the physical protection of nuclear 

materials and facilities, and $1.8 million for training courses for foreign 

nationals on the physical protection and accounting and control of nuclear 

materials. In addition, NRC contributed $59,000 in staff costs to assist IAEA 

with enhancing radioactive material security and the physical protection of 

nuclear materials in transit. For 2005, U.S. agencies estimated that they will 

provide $2.89 million in technical support for IAEA’s nuclear security 

activities.

IAEA’s Heavy Reliance on 

Voluntary Funding Creates 

Challenges

IAEA depends on voluntary contributions for about 89 percent of its 

nuclear security funding, which creates challenges for planning and 

implementing nuclear security activities because almost all donors place 

conditions on how their Nuclear Security Fund contributions are to be 

spent. In 2002 and 2003, respectively, only 2 and 5 percent of the 

contributions to the fund were provided without conditions. For example, a 

number of countries contribute to the fund specifically to help secure 

nuclear and radioactive materials in Russia and other countries of the 

former Soviet Union. IAEA does not have the flexibility to shift these funds 

to support activities in other regions with nuclear security concerns and for 

which limited resources are available, such as Southeast Asia and Latin 

America. IAEA officials said that as a result, some activity areas have 

received funding well in excess of levels proposed in the 2002 nuclear 

security action plan, while other areas have remained under-funded. 

Source of contribution 2002 2003 2004 Total

Department of State $3,199,700 $4,200,300 $4,200,000 $11,600,000

Department of Energy 3,001,209 2,500,000 4,450,000 9,951,209

Total $6,200,909 $6,700,300 $8,650,000 $21,551,209a
Page 52 GAO-06-93 Nuclear Nonproliferation

According to IAEA’s August 2004 report on the status of its nuclear security 

efforts, this may hamper the comprehensive approach necessary for 

effective nuclear security.

Another challenge related to IAEA’s heavy reliance on voluntary 

contributions is its restricted ability to recruit and maintain sufficient staff 

to meet growing obligations. While donors have increased funding for 

nuclear security activities, IAEA has limited budgetary funds to pay for 

staff to meet its increased obligations. Only about 11 percent of IAEA’s 

nuclear security resources, or $1.35 million, comes from its budget. 

However, DOE officials told us that the agency’s financial regulations 

prohibit voluntary funds from being used to pay for permanent staff costs. 

The officials said that while these voluntary funds could be used to pay for 

cost-free experts, this increases IAEA’s reliance on cost-free experts, which 

are funded primarily by the United States. IAEA officials acknowledged 

that the agency’s inability to use voluntary funds to pay for staff costs has 

been the largest administrative challenge to implementing its nuclear 

security program. However, according to IAEA’s August 2004 nuclear 

security status report, the agency’s administrative procedures are not 

designed for programs where the majority of funds come from voluntary 

contributions.

Further, IAEA indicated that the agency has not received sufficient funding 

to meet the needs of all of its nuclear security efforts. In April 2002, IAEA 

estimated that annual funding needs for its nuclear security program would 

be about $32 million—$12 million to support advisory missions and other 

program activities, and $20 million for security equipment procurements 

and upgrades such as installing radiation detection equipment at countries’ 

borders. However, IAEA’s Board of Governors only approved voluntary 

funding for the advisory missions and other program activities, not for 

equipment procurements and upgrades. As a result, IAEA indicated that it 

has had to ask other countries for assistance in order to provide equipment 

urgently needed to respond to security problems identified through the 

agency’s advisory missions. IAEA officials said that coordinating assistance 

between countries has been one of the challenges the agency has faced in 

improving states’ nuclear security because some countries have been 

unwilling to share information with IAEA regarding the assistance they 

have received from, or given to, other countries. However, according to 

DOE officials, the U.S. position is that assistance to procure and upgrade 

security equipment should be provided on a bilateral basis, not by IAEA. 

Further, they questioned whether IAEA, through the development of 
Page 53 GAO-06-93 Nuclear Nonproliferation

integrated nuclear security support plans and other initiatives, has 

effectively coordinated this assistance.

Finally, according to IAEA’s 2004 nuclear security report and Department of 

State officials, unpredictable voluntary contributions by member states 

restrict the agency’s ability to plan nuclear security activities. For example, 

IAEA data on Nuclear Security Fund pledges and receipts from 2002 

through 2004 showed that 30 percent of the funds pledged to the agency 

were not provided in the same year they were pledged.27 Furthermore, data 

for 2002 and 2003 indicated that funds were often not provided until later in 

the year. However, IAEA’s financial regulations do not allow it to make 

expenditures based on pledges and, thus, contributions must be received 

before expenditures can be approved. One IAEA official said that this 

restriction prevents the agency from implementing certain activities 

according to its plan. The official told us that if nuclear security funding 

were more predictable and received in a more timely fashion, IAEA could 

hire staff sooner, and that activities such as conducting advisory missions 

and providing border monitoring equipment could be better planned and 

delivered. Further, participants at a December 2003 coordination meeting 

of Nuclear Security Fund donors recognized that IAEA faces a challenge in 

managing its nuclear security program without predictable resource levels. 

In an effort to ensure a more systematic approach, IAEA officials said that 

the agency develops multi-year activity plans as a basis for requesting 

contributions to the Nuclear Security Fund. However, the officials said that 

the timing of voluntary contributions still presents a challenge to 

implementing the nuclear security program.

Increased Assistance Demands 

Could Further Challenge IAEA’s 

Ability to Plan and Implement 

Nuclear Security Activities

Future increases in demands for IAEA to provide assistance could further 

challenge the agency’s ability to plan and implement nuclear security 

activities. For example, in July 2005, 88 countries and EURATOM adopted 

amendments to the Convention on the Physical Protection of Nuclear 

Material,28 which could increase requests for IAEA assistance to enhance 

the security of countries’ nuclear material and facilities. The existing 

convention requires countries who are party to it to protect nuclear 

27The United States was more timely with its contributions than other Nuclear Security Fund 

donors, with almost 74 percent of U.S. contributions arriving in the same year they were 

pledged, as opposed to about 63 percent of non-U.S. contributions.

28The IAEA Director General, the depositary of the convention, was responsible for 

convening the group of experts that drafted the amendments and for coordinating the 

conference for countries to consider the amendments.
Page 54 GAO-06-93 Nuclear Nonproliferation

material used for peaceful purposes while in international transport, and to 

criminalize certain acts involving nuclear material. When in force, the 

adopted amendments will, among other things, expand the scope of the 

convention to include requirements for securing nuclear materials in 

peaceful domestic use, storage, and transport and for protecting domestic 

nuclear facilities against acts of sabotage. IAEA officials stated that the 

agency may experience a significant increase in requests for security 

assistance, particularly for advisory missions to assess the vulnerability of 

countries’ material and facilities as a result of the amendments to the 

convention. Also, according to a Department of State official, IAEA will be 

responsible for providing leadership, training, and technical assistance, 

such as guidance in establishing legislative and regulatory infrastructures, 

to help countries to comply with their obligations under the amended 

convention. However, IAEA officials questioned whether the agency is 

planning sufficiently for the potential increase in its activities. Moreover, 

the officials stated that Nuclear Security Fund resources would be 

inadequate to meet countries’ additional requests for advisory missions and 

for associated preparatory and follow-up actions.

In addition, IAEA could experience an increase in demand for its nuclear 

security assistance as a result of agency plans to implement a more 

comprehensive nuclear security program. According to IAEA’s August 2004 

nuclear security status report, the agency is developing a new plan of 

activities to be presented to the Board of Governors for approval in 2005. A 

primary objective of the plan would be the worldwide application of the 

agency’s services and assistance to comprehensively improve countries’ 

nuclear security. However, IAEA’s reliance on voluntary contributions to 

fund its nuclear security program could create challenges in implementing 

this plan. For example, countries’ conditions on the use of their funds could 

make it difficult for IAEA to achieve worldwide application of its 

comprehensive nuclear security approach. Further, IAEA’s Deputy Director 

General of the Department of Nuclear Safety and Security said that for 

IAEA to meet its nuclear security goals, higher and more predictable 

resource levels will be required in the future.

IAEA Does Not 

Systematically Measure the 

Results of Its Nuclear 

Security Efforts

In addition to the challenges resulting from the agency’s reliance on 

voluntary contributions, the United States has raised concerns about 

IAEA’s ability to track the use of nuclear security funds and measure results 

in a systematic way. For example, according to Department of State 

officials, as a result of concerns over the planning and coordination of 

IAEA’s nuclear security efforts, the United States requested that the Office 
Page 55 GAO-06-93 Nuclear Nonproliferation

of Nuclear Security provide more results-oriented reporting on a 

systematic basis. In response, the agency created an information 

management system to track projects financed by the Nuclear Security 

Fund. According to IAEA officials, this system became operational at the 

beginning of 2004 and allows IAEA to report to donors on the use of their 

contributions. A Department of State official said that the United States 

received its first report in March 2005, and that this report contained 

adequate information on the use of U.S. contributions to the fund.

However, IAEA still does not systematically measure the results of its 

nuclear security activities. For example, while the agency is required to 

report periodically to the Board of Governors and the General Conference 

on its progress in implementing nuclear security activities, these reports do 

not indicate the extent to which the agency’s efforts have helped to 

improve the security of nuclear material and facilities. For example, IAEA’s 

2004 nuclear security status report provided information on the countries 

for which it conducted physical protection advisory missions since July 

2003 but did not report on the extent to which these missions actually 

improved security at nuclear facilities. Similarly, IAEA reported on its 

efforts to train member state representatives involved in combating illicit 

trafficking in materials. However, IAEA’s report did not include an 

assessment of the extent to which the detection capabilities of personnel 

who attended these training sessions had increased.

Furthermore, while IAEA’s 2004-2005 budget identified program objectives, 

outcomes, and performance indicators for the agency’s nuclear security 

activities, the 2004 nuclear security status report did not always use these 

performance indicators to measure the agency’s results. For example, two 

performance indicators identified in IAEA’s 2004-2005 budget for meeting 

outcomes related to improving nuclear security and the capability of 

countries to detect and respond to malicious acts were (1) the number of 

people trained in agency-sponsored training courses and (2) the number of 

countries implementing agency-developed nuclear security guidelines and 

recommendations. However, the 2004 nuclear security report did not 

provide information on the numbers of country representatives trained, or 

countries implementing agency-developed guidelines and 

recommendations. IAEA officials said that the agency will soon begin work 

to assess program results based on the performance indicators identified in 

the budget, and that information on the number of country representatives 

trained will be included in a report to the Board of Governors in September 

2005.
Page 56 GAO-06-93 Nuclear Nonproliferation

IAEA officials said that it is difficult for the agency to link nuclear security 

efforts, such as recommendations stemming from advisory missions, to 

results, such as whether recommendations were implemented. Other IAEA 

officials attributed this difficulty to the agency’s limited advisory role, 

noting that states are not obligated to follow its guidelines or implement its 

recommendations. Moreover, IAEA officials said that while follow-up 

advisory missions can help to identify whether previous recommendations 

were implemented, IAEA has focused on generating new requests for 

advisory missions, not following up on past activities.

A DOE official who is responsible for developing and tracking nuclear 

security performance measures stated that it is possible to measure the 

performance of security activities even where explicit authority to require 

action does not exist. DOE and other U.S. agencies have implemented 

programs to improve the security of nuclear material both in the United 

States and in other countries. For example, DOE’s National Nuclear 

Security Administration directs efforts to secure international borders 

against illicit trafficking, assist countries in improving the physical 

protection of their nuclear material and facilities, and enhance the security 

of radioactive material. The DOE official said that a first step to measure 

performance would be to develop data on output measures that IAEA can 

influence and that affect the achievement of outcomes. Such output 

measures could include the number of facilities where advisory missions 

are conducted, the number of people trained, or the amount of equipment 

provided. Subsequently, outcome-oriented measures could be created, such 

as the percentage of facilities IAEA assessed as having adequate security 

arrangements based on international standards.

Conclusions IAEA is being called upon by its member states to assume a greater role in 

reducing the risks of nuclear proliferation. However, as its responsibilities 

continue to expand, IAEA faces a broad array of challenges that hamper its 

ability to fully implement strengthened safeguards measures and nuclear 

security activities. In order to maximize the impact and effectiveness of 

strengthened safeguards, most experts we talked to believe that universal 

compliance with and adherence to the Additional Protocol is needed. 

Although the United States is in the process of bringing the Protocol into 

force, the fact that it has not yet done so may provide other countries with 

an excuse not to do so as well. Progress towards increasing the number of 

countries that have brought the Additional Protocol into force should 

increase the political pressure on the remaining countries to do so and 

could make it more difficult to hide proliferation activities.
Page 57 GAO-06-93 Nuclear Nonproliferation

Even with the Additional Protocol in force, IAEA’s ability to verify 

compliance with safeguards is limited in 76 countries that have small 

quantities of nuclear material. The small quantities protocols that IAEA’s 

Board of Governors approves for these countries may increase the risk that 

nuclear proliferation activities could go undetected. Moreover, IAEA’s 

human capital practices reduce the agency’s effectiveness because, in some 

cases, they are rigidly applied regardless of the agency’s overall needs. In 

light of the looming human capital crisis resulting from the upcoming 

turnover of senior safeguards staff and a shrinking pool of nuclear experts, 

ensuring that the agency hires, trains, and retains the most talented staff is 

critical to meet growing strengthened safeguards requirements. 

Further, IAEA’s system for funding its safeguards and nuclear security 

programs faces a number of challenges. Although the agency’s recent 

emergence from a zero real growth budget for its safeguards system is a 

positive step, it may not be adequate to meet future needs. To make a 

convincing case to member states of its future resource requirements and 

ensure that its safeguards budget keeps pace with its changing workload, 

IAEA will need reliable cost estimates that are linked to resource needs for 

all its strengthened safeguards activities and a process to systematically 

evaluate these costs and resources over the long term. In addition, even 

with IAEA’s recent safeguards budget increase, the agency will continue to 

rely heavily on voluntary contributions, particularly from the United States. 

While U.S. funding is essential for the program’s continued viability, 

supporting safeguards is a shared responsibility, and the financial burden 

should be distributed more equitably among as many IAEA member states 

as possible. At the same time, we are concerned that the agency’s reliance 

on countries’ yearly voluntary contributions for the nuclear security 

program does not provide enough flexibility to effectively plan and 

implement nuclear security activities. While we recognize that this program 

is still evolving, member states may need to consider a different approach 

to funding these efforts so that the agency can plan its activities in a more 

systematic manner and meet its highest priority needs. Finally, we are 

concerned that in some instances IAEA may not be using safeguards 

resources in the most efficient manner given the agency’s limited funds and 

growing responsibilities. 

Another major challenge facing IAEA is its limited ability to assess the 

effectiveness of its strengthened safeguards system and nuclear security 

activities. The agency does not have systems in place to measure the 

impact of its strengthened safeguards or nuclear security activities. For 

example, IAEA reports on the number of inspections performed and the 
Page 58 GAO-06-93 Nuclear Nonproliferation

countries where nuclear security advisory missions are conducted. While 

these measures are useful in reporting on IAEA’s efforts, they do not assess 

the impact and effectiveness of its safeguards and nuclear security 

activities. As a result, the agency cannot provide member states assurance 

that its activities are detecting clandestine nuclear weapons programs or 

helping to secure nuclear and radioactive materials against sabotage and 

terrorist threats.

Recommendations for 

Executive Action

Because safeguards are a cornerstone of U.S. nonproliferation efforts, it is 

important that strengthened safeguards measures be applied in as many 

countries as possible. Therefore, we recommend that the Secretary of 

State, working with IAEA and its member states through the agency’s 

Board of Governors, consider eliminating, or at a minimum, reducing the 

number of agreements that limit IAEA’s authority to implement 

strengthened safeguards activities in countries with small quantities of 

nuclear material.

To help ensure that IAEA’s safeguards and nuclear security programs are 

effective, the agency needs to systematically evaluate the results of its 

efforts. Therefore, we also recommend that the Secretary of State, working 

with IAEA and its member states through the agency’s Board of Governors, 

consider developing clear and meaningful measures to better evaluate the 

effectiveness of IAEA’s strengthened safeguards program and nuclear 

security activities.

Furthermore, to improve IAEA’s personnel practices and its ability to 

determine resource requirements over the long term, we also recommend 

that the Secretary of State, working with IAEA and its member states 

through the agency’s Board of Governors, consider:

• rectifying human capital practices that negatively impact IAEA’s ability 

to recruit and retain the critical staff needed to implement strengthened 

safeguards and make changes as appropriate;

• developing a systematic process that forecasts safeguards budgetary 

requirements for the long term—beyond the current 2-year cycle;

• increasing efforts to encourage more member states to provide 

voluntary contributions to support IAEA’s safeguards activities; and 
Page 59 GAO-06-93 Nuclear Nonproliferation

• determining whether the nuclear security program receives adequate 

regular budget funds, and ensure that voluntary contributions are 

provided with enough flexibility to plan and accomplish priority 

program objectives.

Finally, to maximize the benefits for safeguards-related activities, we 

recommend that the Secretary of State, in consultation with the managers 

of the U.S. safeguards technical support program, work with IAEA to 

consider ways to ensure that safeguards resources are allocated and spent 

in the most efficient manner. In particular, these efforts should focus on, 

among other things, encouraging IAEA to use the most cost effective 

means of travel, whenever possible.

Agency Comments and 

Our Evaluation

We provided the Department of State and IAEA with draft copies of this 

report for their review and comment. IAEA provided technical comments, 

which we incorporated as appropriate. The Department of State provided 

written comments, which are presented as appendix III. State also provided 

technical comments, which we incorporated in the report. The Department 

of State generally agreed with our findings, conclusions, and 

recommendations and noted that our recommendations offered reasonable 

ways that the administration can continue to work with IAEA to improve 

its effectiveness. The department also noted that the draft report fairly 

recognized the significant progress IAEA has made, with support from the 

United States and other member states, in strengthening the safeguards 

system and in supporting international efforts to improve the physical 

protection and security of nuclear materials.

In its written comments, the Department of State noted that countries with 

small quantities of nuclear material and countries without comprehensive 

safeguards agreements have very limited nuclear activities and therefore 

they are unlikely to compromise the effectiveness of the safeguards 

system. In addition, while agreeing that IAEA has a limited ability to 

measure the effectiveness of its strengthened safeguards activities, State 

indicated that the problem cannot be fully solved because of the difficulty 

in detecting undeclared activities. State also noted that our conclusion that 

IAEA cannot provide member states assurance that its activities are 

detecting undeclared nuclear weapons programs or helping secure nuclear 

and radioactive material is not fully consistent with the report’s contents, 

which depict IAEA’s successes in uncovering undeclared nuclear activities 

and the extent of its work in advising states on nuclear security. 
Page 60 GAO-06-93 Nuclear Nonproliferation

In our view, the report provides an accurate and reasonable view of the 

challenges facing IAEA’s safeguards program, including the challenges 

posed by countries that have small quantities of nuclear material and are 

subject to limited safeguards measures as well as countries that are outside 

of the safeguards system entirely. A goal of the safeguards program is to 

ensure that all countries comply with and adhere to their safeguards 

obligations. By not applying the full scope of safeguards measures to over 

100 countries IAEA’s ability to detect secret nuclear activities is 

significantly limited. In fact, in response to IAEA’s concerns regarding 

countries with small quantities of nuclear material, the agency’s Board of 

Governors took the first steps to strengthen safeguards measures in 

countries with small quantities of nuclear material in September 2005. 

IAEA’s Director General noted that these recent actions address some 

important limitations in the safeguards system. 

We concur with the Department of State’s belief that IAEA’s limited ability 

to measure the impact of strengthened safeguards cannot be fully solved. 

In our report, we recognize the difficulty in developing performance 

measures for IAEA’s strengthened safeguards activities, but we believe that 

it is important that IAEA continue to develop and refine such measures. 

Assessing the effectiveness of strengthened safeguards in detecting 

clandestine nuclear weapons programs is an essential element in 

evaluating the agency’s overall performance. 

Finally, the Department of State commented that our conclusion—that 

IAEA cannot provide assurance that it is detecting clandestine nuclear 

weapons programs or helping to secure nuclear and radioactive 

materials—is not fully consistent with the body of the report. We noted in 

the report that IAEA has achieved success in disclosing clandestine nuclear 

activities in certain countries, particularly in Iran, South Korea, and Egypt. 

We also noted that IAEA has increased its efforts to help countries secure 

their nuclear material. However, since IAEA has not developed a 

systematic approach to measure the impact and effectiveness of its 

strengthened safeguards and nuclear security programs, the agency cannot 

track its progress in improving its ability to detect clandestine nuclear 

programs or ensuring that the nuclear security of member states’ nuclear 

material has improved. A systematic approach to measuring performance 

would add a greater degree of transparency to IAEA’s safeguards and 

nuclear security programs, and would also provide member states’ with a 

clearer understanding of how the agency reaches conclusions about 

countries’ compliance with their safeguards obligations.
Page 61 GAO-06-93 Nuclear Nonproliferation

As agreed with your offices, unless you publicly release the contents of this 

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

date. We will then send copies of this report to the Secretary of Energy; the 

Administrator, National Nuclear Security Administration; the Secretary of 

State; the Secretary of Defense; the Chairman, Nuclear Regulatory 

Commission; the Director, Office of Management and Budget; and 

interested congressional committees. We are also providing IAEA’s Deputy 

Directors General for Safeguards and Nuclear Safety and Security with 

copies of this report. We will also make copies available to others upon 

request. In addition, this report will be available at no charge on the GAO 

Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, I can be 

reached at 202-512-3841 or aloisee@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix IV. 

Gene Aloise

Director, Natural Resources 

and Environment 
Page 62 GAO-06-93 Nuclear Nonproliferation

Appendix I

Scope and Methodology ApApenednxidexiIs

To identify the steps IAEA has taken to strengthen its safeguards system 

and assess the challenges IAEA faces in implementing strengthened 

safeguards, we obtained and analyzed documentation on IAEA’s 

strengthened safeguards activities, including reports to IAEA’s Board of 

Governors, such as the agency’s annual reports on safeguards 

implementation, strategic planning documents, and internal briefings. In 

December 2004 and March 2005 we visited IAEA Headquarters in Vienna, 

Austria, to meet with IAEA officials from the Department of Safeguards, 

including the Deputy Director General and the directors and staff 

responsible for managing inspection activities, collecting and analyzing 

satellite imagery and open source information, and purchasing safeguards 

equipment, and from the Office of External Relations. We observed a 

demonstration of remote monitoring and other surveillance equipment at 

IAEA Headquarters, and we toured IAEA’s Seibersdorf Analytical and Clean 

Laboratories, where environmental samples are analyzed. Further, we 

obtained the views of officials from the U.S. Mission to the U.N. System 

Organizations in Vienna on the progress IAEA had made in implementing 

strengthened safeguards measures since we last reported on safeguards in 

1998. While in Vienna, we also conducted structured interviews with a 

nonprobability sample1

 of representatives from IAEA member states in 

March 2005 to obtain their views on IAEA’s strengthened safeguards system 

and nuclear security activities.

We developed the structured interview guide for interviewing 

representatives from IAEA member states by identifying the issues related 

to the effectiveness and progress of IAEA’s safeguards and nuclear security 

programs and drafting questions to address these issues. Because the 

practical difficulties of developing and administering a structured interview 

guide may introduce errors—resulting from how a particular question is 

interpreted, for example, or from differences in the sources of information 

available to respondents in answering a question—we included steps in the 

development and administration of the structured interview guide for the 

purpose of minimizing such errors. After initial drafting, internal GAO 

review, and pretesting and modification of the structured interview guide, 

we further modified the structured interview protocol on the basis of 

pretesting and comments from two Department of State officials with 

extensive experience with IAEA’s safeguards and nuclear security 

1

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample.
Appendix I

Scope and Methodology

Page 63 GAO-06-93 Nuclear Nonproliferation

activities. We finalized the structured interview guide after conducting 

pretests with a member of the U.S. Mission and an IAEA representative 

from the Czech Republic.

We identified a nonprobability sample of 25 IAEA member states to 

respond to our structured interview guide, designed to ensure the inclusion 

of a range of views across different types of member states. Our sample 

included states that belong to IAEA’s 35-member Board of Governors, 

which provides overall policy direction and oversight to IAEA; both nuclear 

and non-nuclear weapons states; states that differ with respect to bringing 

into force new strengthened safeguards measures; states that do not belong 

to the Board of Governors, but offer valuable insights into the challenges 

IAEA faces in detecting undeclared activities and strengthening its 

safeguards program; and states with special safeguards agreements with 

IAEA. Of the 25 IAEA member states selected for interviews, we completed 

interviews with representatives from 9 member states. We completed inperson interviews with Canada, China, Germany, Hungary, Israel, Russia, 

the United Kingdom, and the United States. We obtained written responses 

to the structured interview guide from Japan. We were unable to complete 

interviews with the other 16 member states because representatives from 

those countries were unwilling to respond to our questions in the absence 

of official government approval of their responses. However, the nine 

responses we received reflect a broad range of views of member state 

representatives from the selection categories listed above, including states 

that differ with respect to bringing into force new strengthened safeguards 

measures and states with special safeguards agreement with IAEA.

In addition, to assess IAEA’s progress in strengthening safeguards and the 

challenges it faces, we met with and gathered data from U.S. officials from 

the Department of State’s Office of Multilateral Nuclear Affairs, the 

Department of Energy’s Office of International Safeguards, the Department 

of Defense’s Air Force Technical Applications Center, the Department of 

Commerce in Washington, D.C.; the Nuclear Regulatory Commission in 

Rockville, Maryland; Brookhaven National Laboratory in New York; and 

Sandia and Los Alamos National Laboratories in New Mexico. We also 

obtained independent assessments and reports on IAEA safeguards from 

the Departments of State and Energy. Further, we met with experts 

knowledgeable about safeguards and nonproliferation issues, including 

from the Monterey Institute of International Studies and the Massachusetts 

Institute of Technology. We also interviewed former IAEA inspectors, costfree experts, and the head of IAEA’s unattended remote monitoring systems 

unit to discuss the agency’s personnel policies. Lastly, we met with 
Appendix I

Scope and Methodology

Page 64 GAO-06-93 Nuclear Nonproliferation

representatives from Aquila Technologies, which provides IAEA with the 

majority of its surveillance equipment, and toured its production facility.

To identify the extent of IAEA’s reliance on the United States to finance 

safeguards activities, we met with officials from IAEA’s Departments of 

Management and Safeguards, including the Director of the Division for 

Budget and Finance and other staff involved in safeguards budgeting, and 

the Departments of State, Energy, and Defense and the Nuclear Regulatory 

Commission, and Brookhaven, Los Alamos, and Sandia National 

Laboratories. We gathered financial data from these sources on U.S. and 

other member states’ assessed, voluntary, and technical support 

contributions to IAEA’s safeguards program from 1998 through 2004. We 

chose 1998 as the starting year for our analysis to continue the data 

presented in our 1998 report on U.S. contributions to IAEA’s safeguards 

program. While 2004 was the last year for which complete data on IAEA’s 

safeguards budget and U.S. contributions were available, we present some 

2005 estimates where possible. Based on our discussions with U.S. and 

IAEA officials, we defined voluntary contributions as cash contributions to 

IAEA, while technical support contributions are defined as funding used to 

assist IAEA’s efforts but not directly provided to IAEA. Further, we 

analyzed documentation, such as reports from the Office of Internal 

Oversight Services, an independent group of safeguards experts, and 

IAEA’s Board of Governors, as well as budget and strategic planning 

documents. We also held discussions with IAEA and U.S. officials to 

determine the extent to which IAEA evaluates long-term resource 

requirements.

In our analysis of assessed, voluntary, and technical support contributions 

to IAEA’s safeguards budget we used (1) IAEA data on its assessed 

safeguards budget; (2) IAEA data on U.S. payments towards its safeguards 

assessment; (3) IAEA data on voluntary contributions from countries other 

than the United States; (4) Department of State data on U.S. voluntary 

contributions to IAEA’s safeguards program; and (5) data from the 

Departments of State, Energy, and Defense and the Nuclear Regulatory 

Commission to estimate U.S. technical support to IAEA’s safeguards 

program. Since a portion of member states’ assessed contributions to 

IAEA’s budget is made in euros (prior to 2002 non-dollar contributions were 

made in Austrian schillings), we used exchange rates based on the 

International Monetary Fund’s International Financial Statistics to show 

the dollar value of the non-dollar portion of IAEA’s assessed safeguards 

budget and U.S. contributions. We calculated the non-dollar portion of 

IAEA’s assessed safeguards budget using an average annual exchange rate. 
Appendix I

Scope and Methodology

Page 65 GAO-06-93 Nuclear Nonproliferation

We calculated the non-dollar portion of U.S. payments towards its 

safeguards assessment using an average monthly exchange rate for the 

month in which the payments were made to IAEA.2

 Also, we used the 

average monthly exchange rates from January through July 2005 to 

estimate the dollar value of the non-dollar portions of the 2005 IAEA 

safeguards budget and U.S. safeguards assessment. Additionally, IAEA data 

on U.S. payments did not indicate the portion applicable to safeguards 

versus other IAEA programs. To identify the safeguards portion of U.S. nondollar payments, we used the percentage of the total U.S. non-dollar 

assessment for each year that IAEA data indicated was for safeguards. 

Finally, in some cases it was not possible to obtain a complete breakdown 

of U.S. support that was provided as voluntary contributions versus 

technical support. In such instances, we characterized U.S. support as 

voluntary contributions for purposes of consistency. 

To describe how IAEA is helping its member states better secure their 

nuclear material and facilities from nuclear terrorism and identify 

impediments to implementing the program, we collected and analyzed 

documentation, including IAEA’s yearly reports to its Board of Governors 

on its nuclear security program. We also met with officials from IAEA’s 

Offices of Nuclear Security and Legal Affairs, and the Departments of State 

and Energy, the Nuclear Regulatory Commission, and Sandia National 

Laboratory. Moreover, we also toured IAEA’s Nuclear Security Equipment 

Laboratory at IAEA Headquarters and observed a demonstration of hand 

held radiation detection equipment. We obtained IAEA, Department of 

State, and Department of Energy financial data on contributions to the 

Nuclear Security Fund in order to describe the extent to which IAEA relies 

on U.S. support for its nuclear security program, and to analyze the timing 

of contributions to the fund.3

 Further, we gathered data from the 

Department of Energy and the Nuclear Regulatory Commission to estimate 

U.S. technical support to IAEA’s nuclear security program. Similar to our 

2

U.S. assessed payments to IAEA’s budget are not always made in the same year for which 

they are assessed. Our analysis used exchange rates at the actual time of payment to identify 

the dollar value of these contributions. However, we present U.S. contributions according to 

the year for which they were assessed, not the year in which they were actually paid. 

Additionally, in some cases, previous years’ surpluses are credited to member states’ 

assessed contribution balances. We calculated the value of the non-dollar portion of these 

credits using an average of the September and October exchange rates because an IAEA 

official indicated that cash surpluses are made available to member states to credit towards 

their budget assessment during these months.

3

We did not include interest paid on Nuclear Security Fund contributions in our analysis.
Appendix I

Scope and Methodology

Page 66 GAO-06-93 Nuclear Nonproliferation

analysis of contributions to IAEA’s safeguards program, we defined 

technical support as funding used to assist IAEA’s efforts but not directly 

provided to IAEA. 

To assess the reliability of all these data we received—the safeguards and 

nuclear security budget and contribution data—we met with IAEA and U.S. 

officials to discuss these data in detail, and we compared data from 

different sources to identify any discrepancies. We also obtained and 

reviewed responses from key officials with IAEA and each of the U.S. 

agencies to a series of data reliability questions that addressed such areas 

as data entry, data access, quality control procedures, and data accuracy 

and completeness. Follow-up questions were added as necessary. In 

addition, we obtained written responses from the Department of 

Safeguards and U.S. officials to clarify discrepancies in the data we 

received. Based on this work, we determined that the data were sufficiently 

reliable for the purposes of this report.

We conducted our review from October 2004 through August 2005 in 

accordance with generally accepted government auditing standards.
Page 67 GAO-06-93 Nuclear Nonproliferation

Appendix II

Countries’ Safeguards Agreements with IAEA 

That Are In Force, as of July 2005 ApendxiI

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards

Non-nuclear weapons states

Afghanistan X X X

Albania X

Algeria X

Andorra

Angola

Antigua and Barbuda X X

Argentina X

Armenia X X

Australia X X X

Austria X X

Azerbaijan X X X

Bahamas X X

Bahrain

Bangladesh X X

Barbados X X

Belarus X

Belgium X X

Belize X X

Benin

Bhutan X X

Bolivia X X

Bosnia and Herzegovina X

Botswana

Brazil X

Brunei Darussalam X X

Bulgaria X X X

Burkina Faso X X X

Burundi

Cambodia X X

Cameroon X X

Canada X X

Cape Verde

Central African Republic
Appendix II

Countries’ Safeguards Agreements with 

IAEA That Are In Force, as of July 2005

Page 68 GAO-06-93 Nuclear Nonproliferation

Chad

Chile X X

Colombia X

Comoros

Congo, Republic of the

Cost Rica X X

Cote d’Ivoire X

Croatia X X X

Cuba X X

Cyprus X X X

Czech Republic X X

Democratic People’s 

Republic of Koreaa

X

Democratic Republic of 

the Congo

X X

Denmark X X

Djibouti

Dominica X X

Dominican Republic X X

Ecuador X X X

Egypt X

El Salvador X X X

Equatorial Guinea

Eritrea

Estonia X X

Ethiopia X X

Fiji X X

Finland X X

Gabon

Gambia X X

Georgia X X

Germany X X

Ghana X X

Greece X X

Grenada X X

Guatemala X X

Guinea

(Continued From Previous Page)

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards
Appendix II

Countries’ Safeguards Agreements with 

IAEA That Are In Force, as of July 2005

Page 69 GAO-06-93 Nuclear Nonproliferation

Guinea-Bissau

Guyana X X

Haiti

Holy See X X X

Honduras X X

Hungary X X X

Iceland X X X

Indonesia X X X

Iranb X

Iraq X

Ireland X X

Italy X X

Jamaica X X

Japan X X X

Jordan X X X

Kazakhstan X

Kenya

Kiribati X X

Korea, Republic of X X

Kuwait X X X

Kyrgyzstan X X

Laos X X

Latvia X X

Lebanon X X

Lesotho X X

Liberia

Libyac X

Liechtenstein X

Lithuania X X

Luxembourg X X

Madagascar X X X

Malawi X X

Malaysia X

Maldives X X

Mali X X X

Malta X X X

(Continued From Previous Page)

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards
Appendix II

Countries’ Safeguards Agreements with 

IAEA That Are In Force, as of July 2005

Page 70 GAO-06-93 Nuclear Nonproliferation

Marshall Islands X X

Mauritania

Mauritius X X

Mexico X

Micronesia

Monaco X X X

Mongolia X X X

Morocco X X

Mozambique

Myanmar X X

Namibia X X

Nauru X X

Nepal X X

Netherlands X X

New Zealand X X X

Nicaragua X X X

Niger

Nigeria X

Norway X X X

Oman

Palau X X

Panama X X X

Papua New Guinea X X

Paraguay X X X

Peru X X X

Philippines X

Poland X X

Portugal X X

Qatar

Republic of Molodova

Romania X X

Rwanda

St. Kitts and Nevis X X

St. Lucia X X

St. Vincent and the 

Grenadines

X X

Samoa X X

(Continued From Previous Page)

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards
Appendix II

Countries’ Safeguards Agreements with 

IAEA That Are In Force, as of July 2005

Page 71 GAO-06-93 Nuclear Nonproliferation

San Marino X X

Sao Tome and Principe

Saudi Arabia

Senegal X X

Serbia and Montenegro X

Seychelles X X X

Sierra Leone

Singapore X X

Slovakia X

Slovenia X X

Solomon Islands X X

Somalia

South Africa X X

Spain X X

Sri Lanka X

Sudan X X

Suriname X X

Swaziland X X

Sweden X X

Switzerland X X

Syria X

Tajikistan X X X

Thailand X

The Former Yugoslav 

Republic of Macedonia

X X

Timor-Leste

Togo

Tonga X X

Trinidad and Tobago X X

Tunisia X

Turkey X X

Turkmenistan

Tuvalu X X

Uganda

Ukraine X

United Arab Emirates X X

(Continued From Previous Page)

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards
Appendix II

Countries’ Safeguards Agreements with 

IAEA That Are In Force, as of July 2005

Page 72 GAO-06-93 Nuclear Nonproliferation

Source: GAO analysis of IAEA data.

a

Although North Korea concluded a comprehensive safeguards agreement with IAEA in 1992, it 

announced its withdrawal from the NPT in January 2003. 

b

Although Iran has not ratified the Additional Protocol, it is acting as if the Additional Protocol was in 

force.

c

Although Libya has not ratified the Additional Protocol, it is acting as if the Additional Protocol was in 

force.

United Republic of 

Tanzania

X XX

Uruguay X X

Uzbekistan X X X

Vanuatu

Venezuela X

Vietnam X

Yemen X X

Zambia X X

Zimbabwe X X

Nuclear weapons states with voluntary safeguards agreements in force

China X X

France X X

Russia Federation X

United Kingdom X X

United States X

States with special safeguards agreements

India

Israel

Pakistan

(Continued From Previous Page)

State

Comprehensive 

safeguards agreement Additional protocol 

Small quantities 

protocol Integrated safeguards
Page 73 GAO-06-93 Nuclear Nonproliferation

Appendix III

Comments from the Department of State ApendxiI
Appendix III

Comments from the Department of State

Page 74 GAO-06-93 Nuclear Nonproliferation
Appendix III

Comments from the Department of State

Page 75 GAO-06-93 Nuclear Nonproliferation
Appendix III

Comments from the Department of State

Page 76 GAO-06-93 Nuclear Nonproliferation
Appendix III

Comments from the Department of State

Page 77 GAO-06-93 Nuclear Nonproliferation
Appendix III

Comments from the Department of State

Page 78 GAO-06-93 Nuclear Nonproliferation
Page 79 GAO-06-93 Nuclear Nonproliferation

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Gene Aloise (202) 512-3841

Staff 

Acknowledgments

In addition to the contact named above, Virginia Chanley; Leland Cogliani; 

Nancy Crothers; Glen Levis; Christopher Murray; Judy Pagano; Keith 

Rhodes (GAO’s Chief Technologist); and F. James Shafer, Jr., made key 

contributions to this report.

(360518)
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