EN    EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 24.6.2009 
SEC(2009) 790 
  
COMMISSION STAFF WORKING DOCUMENT 
 
Accompanying document to the 
COMMUNICATION FROM THE COMMISSION  TO THE EUROPEAN PARLIAMENT 
AND THE COUNCIL 
 
on Strengthening Chemical, Biol ogical, Radiological and Nuclear Security in the European 
Union – an EU CRBN Action Plan  
 
IMPACT ASSESSMENT  
   
{COM(2009) 273 final} 
{SEC(2009) 791} 
 
EN 2   EN 1. Introduction................................................................................................................ .. 4 
2. Procedural issues and consulta tion of interested parties.............................................. 4 
2.1. Organisation and timing............................................................................................... 4 2.2. The Impact Assessment Board..................................................................................... 5 2.3. Consultation process .................................................................................................... 5 3. Problem definition........................................................................................................ 7 3.1. The overall level of threat a ssociated with CBRN materials ....................................... 7 
3.2. The potential costs of CBRN attacks ........................................................................... 9 3.3. Problem definition...................................................................................................... 10  
3.4. Scope of the problem ................................................................................................. 13 3.4.1. The chemical industry................................................................................................ 14 3.4.2. The biological market ................................................................................................ 14 3.4.3. The Radiological a nd Nuclear industry...................................................................... 14 
3.5. Status quo, existing gaps............................................................................................ 15 3.6. Subsidiarity and proportionality principles................................................................ 20 4. Policy Objectives ....................................................................................................... 22 5. Policy options and their Assessment.......................................................................... 22 5.1. Baseline scenario or status quo .................................................................................. 24 
5.2. Detailed assessment of the selected actions............................................................... 27 
5.2.1. CBRN prevention....................................................................................................... 41  
5.2.2. CBRN Detection ........................................................................................................ 67  
5.2.3. CBRN preparedness and response ............................................................................. 77 6. Preferred Policy Option (CBRN Action Plan)........................................................... 87 6.1. Summary of relevance, feasib ility and expected impacts .......................................... 89 
6.2. Assessment of the EU added value .......................................................................... 104 7. Monitoring and evaluation ....................................................................................... 107 Annex 1: CBRN glossary....................................................................................................... 10 9 
Annex 2: Examples of incidents, military a nd terrorist attacks involving CBRN materials . 114 
 
EN 3   EN Annex 3: Non-exhaustive list of internati onal and European legi slation and non-binding 
frameworks currently in place.................................................................................. 128 
Annex 4: First screening of identifie d CBRN actions to be undertaken................................ 131 
 
EN 4   EN 1. INTRODUCTION  
In accordance with the December 2007 Council Conclusions  on addressing chemical, 
biological, radiological  and nuclear (CBRN)1 risks and on bio-preparedness2, which 
invited the Commission to continue its work  in the CBRN field and agreed with its 
intention to propose relevant policy measures in 2009, the Commission intends to adopt a 
package of proposals on CBRN in June 2009. 
The overall objectives of the CBRN policy package are to fight terrorism through 
complementing relevant measures that are bei ng taken at Member State level, to address 
gaps in the field and to promote the shar ing of information and exchanges of best 
practices between Member States. The po licy package should also assist in the 
identification of measures to reduce the terrorist threat that apply horizontally, as well as individually across the chemi cal, biological, radiological an d nuclear domains. The focus 
of the package will be on tangible deliverab les within the "prevent , protect and respond" 
strands of the EU Counter-terrorism St rategy adopted by the Council on 1 December 
2005.
3 
2. PROCEDURAL ISSUES AND CONSULTA TION OF INTERESTED PARTIES  
2.1. Organisation and timing 
The EU has already taken numerous measures to help protect the populations of its 
Member States against accidents, pande mics or natural events involving CBRN 
substances. The Ghent European Council in 2001 instigated the first steps at the EU level 
in countering the CBRN threat.4 The Ghent conclusions were followed by the adoption of 
the "Programme to improve cooperation in  the European Union for preventing and 
limiting the consequences of chemical, biol ogical, radiological or nuclear terrorist 
threats" in December 20025. The 2004 progress report on this Programme6 confirmed that 
the threat of CBRN terrorism justifie d continued attention at EU level . The Programme 
was superseded by the Council and Commi ssion's EU Solidarity Programme of 3 
December 2004 on the consequences of terrorist  threats and attacks that widened, revised 
and replaced the 2002 CBRN-Programme.7 The relevant elements of the Solidarity 
Programme were included in the overa ll Strategy and Action Plan on Combating 
Terrorism established in 2005 after the London attacks.8 
                                                 
1 A CBRN glossary can be found in Annex 1. 
2 16589/07, of 17 December 2007 
3 15708/03. 
4 SN 4292/01 REV 2. 
5 14627/02. 
6 8988/05. 
7 15480/04. 
8 14469/4/05, paras 20 and 31. 
 
EN 5   EN Tackling terrorist access to CBRN material is currently considered a key priority under 
both the European Union Counter-Terrorism  Strategy and the EU Strategy against 
proliferation of weapons of mass destru ction and their means of delivery (WMD) 
adopted by the European Council on 12 December 20039. More specifically, the JHA 
Council Conclusions of 6 December 2007 on "addressing Chemical, biological, 
radiological and nuclear risks and  on bio-preparedness" provide the most recent EU-level 
overview of the ongoing activities. 
2.2. The Impact Assessment Board 
On 3 April 2009, the Impact Assessment Bo ard of the European Commission (IAB) 
delivered its opinion regarding a preliminary version of this Impact Assessment report. 
The Board stressed that although the Impact a ssessment report is a long document, this is 
understandable due to th e complexity of the subject rais ed. Furthermore, the IAB stressed 
the positive aspect of the thorough consultation process. 
The Board further stated that: 
• the types of actions proposed should be better categorised in terms of type of 
instrument, priority and responsible actors; 
• the expected take-up by Member States and their support to the Action plan should be 
better explained; 
• the costs and economic impacts of identi fies actions should be assessed not only 
qualitatively but al so quantitatively. 
In addition the IAB stated that the IA re port would be usefully complemented by 
including a more thorough anal ysis of those actions that might result in high costs or 
explaining whether these actions will be subject  to further feasibility studies or impact 
assessments.  
The present version of the Impact Assessmen t report has been revi sed with a view to 
taking these recommendations into account. Additional information and modifications 
have been introduced to this end in all relevant sections. 
2.3. Consultation process 
The development of the CBRN policy package was supported by a long and extensive 
consultation process. Initially, two green papers, on Detection10 in 2006 and on Bio-
preparedness11 in 2007 were issued. More than 120 replies from Member States' 
authorities, third countries, re presentatives of regional author ities, the private sector, and 
research and academia were received. A synthesi s of the replies to both green papers has 
                                                 
9 SN 400/03, no 68. See also infra, para 6. 
10 COM(2006) 474 final. 
11 COM(2007) 399 final. 
 
EN 6   EN been published in 2008.12 The results of the consultation on the green papers were used 
as the departing point for further di scussions in the CBRN Task force. 
The main driving force behind the formula tion of the specific CBRN activities to be 
undertaken has been the CBRN Ta sk force. The Task force,  which was established in 
February 2008, consisted of more than 200 members that arrived from national 
authorities and organisations, ra nging from many different Mi nistries such as Internal 
Affairs, Justice, Defence and Health, to representatives of national response 
organisations, civil defence and other first re sponders, as well as forensic institutes and 
nuclear safeguards authorities. Representa tives of the private sector, academia and 
international organisations also participate d, in particular Eur opol and Eurojust. The 
participation demonstrated the strong interest  of many stakeholders in being involved in 
the development of further policy m easures at the European level. 
Furthermore, several Commission services have been actively involved in the work of the 
CBRN Task force. Among all the DGs involve d in this exercise , DG ENTR, DG SANCO 
and DG TREN/JRC played a particularly activ e role in the chemical, biological and 
radiological/nuclear fields, respectively. 
Under the auspices of the CBRN Task Force, a series of meetings was organised within 
each sub-group addressing di fferent CBRN strands: 
• The biological sub-group held a series of  meetings between April and September 2008 
which focused on four main components of  bio-preparedness: threats to humans, 
threats to animals, and food and feed for an imals, threats to crops, food and feed and 
biological detection; 
• The radiological/nuclear sub-group held  a series of seminars and workshops 
throughout 2008 dedicated to ra diological/nuclear preventio n, detection and response; 
• The chemical sub-group held a series of  seminars and workshops throughout 2008 
dedicated to chemical preventi on, detection and response issues. 
The work of all groups was based on di scussion documents put forward by the 
Commission, which included possible recommendations to improve the existing 
situation. These documents were adapted throug h an interactive process. The final report 
of the Task Force was published in Janua ry 2009 and discussed at a comprehensive 
conference in Prague that offi cially concluded the work of  the CBRN Task Force, held 
under the auspices of the Czech Presidency  of the EU. The final report contains 264 
separate recommendations, confir ming not only that there is stil l a lot of work  to be done, 
but also that there is a str ong consensus amongst experts on how the existing issues could 
best be tackled. 
In addition, 6 meetings of th e CBRN Inter-service group meetin gs have been held within 
the Commission, starting in November 2008 and concluding in March 2009. The 
                                                 
12 SEC(2008)1957 and SEC(2008)2373. 
 
EN 7   EN Commission services which participated regularly at the Inter-service consultations and 
contributed to the development of actions to be undertaken are:  SANCO, ENTR, TREN, 
JRC, ENV, TRADE, TAXUD, a nd SG. Their opinions have been taken on board already 
at the preparation phase of the CBRN packag e. This broad consultation process and its 
input form the basis for this Impact Assessm ent, as well as for the CBRN Package itself. 
3. PROBLEM DEFINITION  
When defining the CBRN related problem in th e EU, a series a variables, including the 
overall level of the CBRN thre at and the potential cost of using CBRN materials have to 
be taken into consideration. 
3.1. The overall level of threat asso ciated with CBRN materials 
Historically, most terrorist activities have been conducted using conventional explosives 
and arms.13 While prior to the 9/11 attacks, a wide consensus amongst experts existed 
that terrorists were far less likely to re sort to such weapons of mass destruction,14 these 
arguments were revised after evidence on effo rts from terrorist or ganisations, notably Al-
Qaeda , to use CBRN materials came to light.15 
The range of possibilities for terrorist attack s involving CBRN materi als is wide. Possible 
scenarios include for example: 
• introducing toxic chemical or biological agents into the human food chain: infecting 
crops and animals; poisoning food or liquids  during manufacturing, in storage or in 
retail stores with toxic chem icals or biological agents; 
• spreading chemical or biological agents on surfaces to poison via skin contact; 
• releasing gaseous chemicals, vaporised biol ogical agents or radiological sources in 
buildings or public transport infrastructure; 
                                                 
13 Only a fraction of over 36,000 terrorist incidents between 1972 and 2008 recorded in RAND 
Worldwide Terrorism Incident Database concerned the actual use or serious attempts to use 
CBRN material in terrorist attacks: http://w ww.rand.org/ise/projects/terrorismdatabase/. 
14 E.g. Brian Michael Jenkins, “International Terror ism: A New Mode of Conflict” in: International 
Terrorism and World Security (London, 1975), or Walter Laqueur, “Terrorism” (London, 1977) - 
cited in: Bruce Hoffman, “ CBRN Terrorism Post-9/11” 
(http://fletcher.tufts.edu/jebsencenter/resear chbriefs/JCCTS_Hoffma n_CBRN_01-2007.pdf). 
15 In a recent report from the UK Cabinet Office on its proposed new external borders organisation 
(“Security in a Global Hub: Establishing the UK’s New Border Arrang ements”) of November 
2007, it is said that “the UK f aces threats, such as from organi sed crime and terrorism, of an 
unprecedented level of virulence,  sophistication and variety. Th e determination and capability of 
such groups are greater th an ever before and the potential consequences more 
serious.”http://www.cabinetoffice.gov.uk/media/cab inetoffice/corp/assets/publications/reports/bor
der_review.pdf. 
 
EN 8   EN • releasing large quantities of  high-risk substances (gas eous or liquid) into the 
environment via an attack on a producti on plant, a facility where dangerous 
substances are stored and/or used, or on a transport of chemical, biological or 
radiological/nuclear material; 
• exposing population to radiati on by hiding unsealed radioactiv e or nuclear material in 
public places (passive dispersion); 
• contaminating areas with radioactive mate rial by using an expl osive radiological 
dispersion device (RDD, or ‘dirty bomb’); 
• triggering a nuclear explosion by using a (s tolen) nuclear weapon or an improvised 
nuclear device (IND)16. 
Incidents involving the use of  CBRN materials for malici ous purposes have already 
occurred in Europe and in third countries. One example for each of the three strands of 
CBRN materials is given in Table 1.17 
Table 1: Examples of malicious use of CBRN materials 
C On 20 March 1995, probes of the chemical weapon Sarin (NATO designation: ‘GB’) 
were released at different locations with in the Tokyo underground system by five 
members of the Aum Shinrikyo cult. The Sarin was contained in plastic bags which were 
punctured with umbrellas to release the evaporated toxin. 12 people died and over five thousand were injured as a result of the attack. 
B In October 2001, envelopes containing bacillus anthracis  (anthrax) spores were 
dispatched through the US post al system to the US Senate as well as to New York media 
offices. The spores, upon opening the letters, infected 22 people, 5 of whom died. Dozens of buildings had to be cleaned up, putting huge costs on the government.  
The incident caused great public turmoil; about 300 additional locations were tested and 
thousands were treated as precautionary meas ure. Some harmless hoax ‘anthrax letters’ 
were sent to government and private persons in the aftermath, inflicting panic and 
disruption of day-to-day work. 
RN On 1 November 2006, the former Russian secret service agent Alexander Litvinenko who lived in London was killed by poisoning his tea with the highly radioactive isotope 
Polonium-210. 
The use of radioactive material caused fear amongst the public. Several locations and 
vehicles through which the material travelle d had to be temporarily closed down and 
decontaminated. According to British health officials, some 128 people were discovered 
to have had "probable contact" with the material.  
                                                 
16 The latter may or may not achieve nuclear yield. To build an IND, one would require parts of a 
nuclear weapon or at least a critical mass of we apon-grade nuclear material (HEU or plutonium) 
and a very sophisticated explosive device to trigger the fission. If nuclear yield is not achieved, the 
effects would be the same as for RDDs: the disper sal of nuclear material would render the public 
space a “no go” area for a considerable amount of time 
17 A non-exhaustive list of more incidents involving CBRN material can be found in Annex 2. 
 
EN 9   EN 3.2. The potential costs of CBRN attacks 
Whilst the occurrence and probability of CBR N attacks might be limited, the social, 
environmental and economic costs incurred in case of an incident would be severe and 
would persist over several year s, especially if major transport nodes (such as ports or 
airports) or centres of economic activity are targeted (financial a nd commercial centres). 
The main cost factors in case of  a major incident are usually: 
• the value of loss of life and temporary or pe rsistent health conditions leading to lower 
employability and a lower quality of life; 
• effects of the disruption of economic activiti es and destruction and/or contamination 
of infrastructure; 
• social disruption and an overa ll public perception of be ing unsafe, also having an 
effect on overall public  health and wellbeing. 
Many analyses examined the costs of simulate d terrorist CBRN events. A review of these 
studies dimensioning the costs of one single incident led to  estimates ranging from 4.6 
billion EUR to up to 7.4 trillion EUR.18 It is also worth menti oning that such estimates 
                                                 
18 For a detailed analysis, see for example: 
Kaufmann, Arnold F. et al., “The Economic Imp act of a Bioterrorist A ttack: Are Pr evention and 
Post-attack Intervention Programs Justifiable?” (Analysis of large scale aerosol releases of 
Bacillus anthracis, Brucella melitensis, and Fran cisella tularensis in a suburb of a major city. 
Costs calculated range from approx. $500 million to approx. $25 billion per 100,000 persons 
exposed)In: Emerging Infectious Diseases, Vol. 3, No. 2, April–June 1997, 
http://www.cdc.gov/ncidod/eid/vol3no2/kaufman.htm; Abt, Clark C. et al., “The Economic Impacts of Bioterrorist Attacks on Freight Transport Systems 
in an Age of Seaport Vulnerability”. The analysis  of the clandestine release of aerosols of 
weaponised deadly contagious disease (smallpox, plague) in crowded air, sea, rail, or subway terminals arrived to an estimated cost of 153 b illion EUR to 9.6 trillion EUR (value of loss of life: 
$90-9,000 billion; property damage: $1-10 billion;  trade disruption: $20-200 billion; indirect 
costs: $42-420. billionhttp://abt associates.com/reports/ES-
Economic_Impacts_of_Bioterrorist_Attacks.pdf; 
Fields, Gary, “An Ominous Outcome—Outcome of Dirty Bomb Scenario Is an Economic Catastrophe”. Press report estimating that the us e of a radiological we apon to close shipping 
facilities would produce a loss of approximately $60 billion. Wall Street Journal, December 4, 
2002, p. A4; ICF Consulting, “Measuring the Economic Costs of  Terrorist Attacks” Simulations of attacks on 
the state of California’s electrical  power grid and the deliberate release of foot and mouth disease 
in the state of Iowa: calculated total economic costs of approx. $18 billion and $6 billion, respectively. http://www.icfi.com/Markets/Home land-Security/doc_files/costs_terrorist.pdf  
United States Center for Homeland Security a nd Defence (CDHS). Acco rding to estimates, a 
terrorist attack on a major port could result in losses of $1.5-2.7 billion per day for the first few days, $5 billion a day for the next two weeks, and could then rise exponentially thereafter. Cited in 
the NATO Special Report “Chemical, biological, radiological or nuclear (CBRN) detection: A 
technological overview” (http://www.europarl.europa.eu/meetdocs/2004_2 009/documents/dv/nato_report_2005_/nato_rep
ort_2005_en.pdf; 
Brookings Institution (Michael E. O’Hanlon, et . al.), “Protecting the American Homeland: A 
Preliminary Analysis”The paper estimated that a su ccessful terrorist attack with a weapon of mass 
 
EN 10   EN generally focus on very larg e scale CBRN incidents. Cons equently, estimates at the 
upper end of the spectrum may not adequately  reflect the economic effects of a small-
scale, yet more likely, CBRN incident. 
3.3. Problem definition 
The CBRN problem assessment focuses on specifi c problems in a four-tier structure: 1) 
Horizontal issues; 2) Prevention issues; 3) Detection issues; and 4) Preparedness and 
response issues. 
The general problem is the insufficient cap acity of the EU to respond to the CBRN 
threats with regard to preven tion, detection and response.  
Table 2 sets out the main problems, with a s ynthesis of key issues identified specific to 
C, B, or RN areas.  
Table 2: Main problems and a synthesis of key i ssues identified specific to C, B, or RN areas 
Specific problems Key issues 
1) Horizontal issues  
There is a body of international and EU le gislation which overall appears to focus 
more on safety than security (with the exception of nuclear materials, where the 
security aspect is ade quately addressed by international legislation and 
conventions). In addition, international and EU legislation only rarely uses a 
comprehensive approach to  all CBRN materials. Problem 1.1: A wealth of international and EU 
legislation and agreements in place but differences 
in implementation 
A pool of legislation and international conventions 
cover CBRN materials, setting out rules and 
requirements at diffe rent detail for their production, 
storage, transport and trade. Some Member States have 
better approaches and mechanisms (e.g. medical 
intelligence cooperation, personnel security, detection) 
in place to enhance the security of CBRN materials 
than others. There are differences in national transpos ition and implementation of international 
and EU legislation, in terms of quality , elaboration and coverage, as well as 
operational and functional a rrangements in place. Terro rists and criminals could 
take advantage of less develope d and secure national contexts. 
There are many different formal and info rmal, ad-hoc, cooperation and information 
sharing instruments and initiatives focusing on CBRN and it is difficult to take stock 
of each to avoid duplication and identify synergies and gaps. 
The current mechanisms and initiatives are no t sufficiently known to all relevant 
stakeholders. In addition, not  all relevant CBRN areas are covered, hence showing 
gaps. 
Member States’ positions at international forums on CBRN issues and the fight again 
terrorism are not systematically or fully  coordinated. Common EU positions are not 
elaborated and communicated. Problem 1.2: Gaps and duplications in current information sharing and cooperation initiatives 
Multiple information sharing and cooperation 
initiatives exist at the EU and at international level, but 
these tend to be fragmented and do not involve all 
relevant actors. This may l ead to information gaps and 
lack of opportunities for effective early warning. 
There is no adequate early warning mechani sm covering the whole EU that would 
enable Member States to share information on lost or stolen sources or suspicious 
                                                                                                                                                 
destruction smuggled into the country in a sh ipping container could amount to $1 trillion if 
subsequent draconian security measures were adopted  that impeded trade. An efficient release of a 
biological agent in a major urban area could inflict costs of up to $750 billion. http://www.brook.edu/fp/projects/homeland/chapter1.pdf. 
 
EN 11   EN Specific problems Key issues 
transaction, especially in the ch emical and biological fields.  
The national capacities and capabilities of  certain Member States concerning 
prevention, detection and response are limited. The potential of joint training 
initiatives and other cooperative capacity building activities is not fully exploited. 
Mutual recognition of forensic evidence is  not ensured within the EU. Moreover, 
regulations, standards and practical arr angements concerning procedures and rules 
on dealing with forensic evidence in case of CBRN events vary significantly. 
Criminal legislation and penalisation of illicit access to, or trafficking of CBRN materials (and consequently also the nature of investigative and penal actions and 
the level cooperation with Europol, Euroju st) differs between the Member States. Problem 1.3: Constraints due to differences in 
practical and legal arrangements in the Member 
States 
There are various legal and practical constraints to EU 
cooperation to combating CBRN  terrorist threats.  
Most security clearances and background checks undertaken in one Member State 
are not recognised in other Member States. 
Not all personnel which may handle or have access to CBRN materials is adequately 
checked. There may also be potential personne l security issues in  facilities where 
dangerous agents and toxins are handled on an occasional basis. Problem 1.4: Problems with regard to personnel 
security 
Standards with regard to personnel security differ 
between Member States, which have different 
procedures related to background checks and personnel 
vetting.  Whilst some Member States have elaborate vetting procedures in place, others apply 
much lower standards. Given the sheer num ber of persons having access to or 
handling CBRN materials across the entire s upply chain (especially in the chemical 
sector), there is a need for a graduated approach. 
A number of research needs has been identi fied at the EU level in the field of 
prevention, detection, response and technology research. Problem 1.5: Insufficient research and development to prevent, detect, prepare and respond to CBRN 
incidents 
Whilst in some areas, a lot of research is undertaken, a 
number of research needs are currently not adequately 
addressed. While some Member States have develope d significant research programmes in the 
security area, corresponding activ ities are at low levels in  other Member States. In 
addition, as there is no clear overview of which research is being undertaken, this 
could lead to a duplication of efforts. 
The public dissemination of certain findings  from research constitutes a potential 
risk as terrorists and criminals might use these findings to pr oduce CBRN weapons. 
The risk is particularly significant in the biological area. Problem 1.6: Publication and funding programmes 
do not sufficiently take security issues into account 
The open-source publication of scientific findings and 
research funding practices do not sufficiently take into 
account security issues. Organisations funding research do not sufficie ntly consider the potential risks of 
misuse in their decisions to finance projects. 
2) Prevention issues  
The extent to which various type of CBRN material is available and used in Europe 
differs, but the overall scale of use of ch emical, biological, radiological and nuclear 
material is large. A huge number of ec onomic actors and individuals have access to 
these. European competitiv eness depends to a great ex tent on CBRN materials. Problem 2.1: Access and availability of CBRN 
materials 
A lot of CBRN materials, which is relatively easy to 
obtain, can be weaponised. This relates predominantly 
to chemical substances and to a lesser extent to 
biological agents and radiol ogical sources. Provided 
one has the means and the knowledge, it is also 
relatively easy to establish ‘private’ laboratories or find 
other ways to manipulate CBRN agents. A number of CBRN materials can be tu rned into weapons by terrorists and 
criminals. There is often no need for well-equipped laboratories to handle and/or 
prepare highly toxic chemic al compounds, improvised radiological dispersion 
devices (RDDs) or to manipu late biological agents and toxins. There is also the 
growing issue of new, genetica lly modified micro-organisms. 
Problem 2.2 Monitoring and control over CBRN 
materials, approaches and standards vary between 
the MS The mapping of facilities and of all potenti ally dangerous materials in some Member 
States remains insufficient, thus rendering the coordinated control of CBRN markets 
difficult. 
 
EN 12   EN Specific problems Key issues 
Licensing requirements and the quality of follow-up monitoring and control 
arrangements are less develope d in some Member States. 
Member States have different  procedures for tracking CB RN materials and activities 
and reporting thefts/losses. Electronic tr acking systems for high-risk sources 
(including cross-border transport) have not b een introduced. There is also an overall 
lack of awareness of suspicious transac tions and behaviour for personnel working 
with CBRN materials. Tracking biological s ubstances can prove d ifficult as these are 
living organisms that can easily in crease or reduce in numbers. 
There is a lack of dialogue between law enfo rcement and fac ilities (and their security 
managers) notably in the chemical and radi ological/nuclear field in some Member 
States. There is insufficient coordinated control of the markets 
for CBRN materials and Memb er States have varying 
approaches and standards with regard to the monitoring 
and surveillance of CBRN ma terials and transactions 
The level of awareness of the dangers of CBRN 
substances also varies across the production and supply 
chain.  
There is a lack of security awareness am ongst users of CBRN materials (including 
equipment with radiological sources) in  certain Member States. Education and 
training curricula do often not address these issues sufficiently. 
3) Detection issues  
There are gaps amongst European stakehol ders (national agencies, emergency 
services, industry actors) in understandi ng current CBRN threats and risks and 
defining on that basis concre te detection requirements. 
Currently, technologies and tools are insuff iciently developed and applied to ensure 
swift detection and identification of CBRN materials and/or incidents. Also, the 
potential of already existing technologies and tools may not be fully exploited in 
Europe. 
Overall, there is a genera l lack of overview across la w enforcement bodies and other 
relevant actors of good methods and equipm ent. Information sharing arrangements 
are not in place or not working efficiently . A scope for duplication exists in research 
efforts. Problem 3.1: Weaknesses in detection 
There are marked differences in the level of national 
detection capabilities and preparedness. Some Member 
States facing a limited terro rist threat do not have 
adequate technical res ources and staff in CBRN 
detection. They also have only limited access to state-
of-the-art equipment and know-how. Also, the 
knowledge and awareness of frontline officers to 
recognise CBRN materials/th reat is not adequate 
everywhere in Europe. 
There are certain gaps in the CBRN awar eness and preparedness of police, border 
guards and other professionals who might be the first to identify a CBRN attack. 
Relevant professionals should be generally better inform ed on the current level of 
threat, especially on current trends and concrete risks. 
A common set of minimum CBRN detecti on requirements, bas ed on performance 
tested (trialled) under real life circumstan ces, would be needed to ensure a minimum 
level of safety for citizens across the EU. Performance requirements should be 
defined by building upon a scenario approach. Problem 3.2: Duplication of efforts in standards, 
testing trialling and certification 
There are no harmonised mini mum detection standards 
on which Member States could build and no European testing and trialling and certification scheme exists yet. 
The effectiveness of detec tion equipment procured (in 
combination with systems setup and training) may be 
inadequate. Linked to the lack of a European system of standards for detection equipment and 
systems, there is also no European testin g, trialling and certifi cation of detection 
systems and equipment. 
4) Preparedness and response issues  
When available, response and emergency plans in Member States do not sufficiently 
take account of the EU or international di mension of an incident. Similarly, they do 
not take account of the possible terrorist  and intentional nature of the incident. Problem 4.1: Mechanisms and procedures to deal 
with incidents are not in place or not effective 
There are significant differences across Member States 
in the quality of national CBRN emergency and 
response plans of supply chain actors, high-risk sites or Response planning at national or local level is  not always taking into consideration 
all relevant security aspects, including the need for forensic investigation. 
 
EN 13   EN Specific problems Key issues 
When available, response and emergency plans  in Member States do not include pre-
defined protocols which set out informati on flows and ensure liaison with security-
related authorities. 
When available, response and emergency plans  in Member States do not involve all 
necessary stakeholders, or these are not always aware of them. critical infrastructure operators. The security aspects 
are often not explicit or not well integrated in the plans. 
Not all high-risk locations (critical infr astructure, public transport companies) or 
operators handling high-risk CBRN material s have response plans in place that 
would cover all CBRN issues, and even if they have, their quality is varied. 
When available in Member States, traini ng schemes and relevant guidance for first 
responders do not always take into account the likelihood of a terrorist attack. Even 
when they do, the specific effects of  an intentional release and the related 
requirements (e.g. forensic investigation and decontamination) are not well known 
or understood by first responders. 
There is a lack of training schemes focu sing on cross-border issues and cooperation 
in the event of a CBRN event. Problem 4.2: Gaps in the training of first responders, including lack of awareness of forensic 
and cross-border issues 
There are significant gaps in the training of first 
responders to react to CBRN events in Member States. 
Precautions with regard to forensic investigation or 
decontamination are too often not taken into account. 
With regard to training within facilit ies dealing with/producing biological 
substances, very few Member States have developed specific training as a first 
response to security issues. This is less true for chemical and radiological/nuclear 
facilities where the focus of  training for first response has placed more focus on 
security. 
With regard to biological threats, not all Member States have vaccine 
stockpiles/banks and manipulated agents and toxins are of  great concern. 
Having appropriate countermeasures in pla ce in case of intentional disease is 
challenging, as it is virtually impossible to protect or treat the population against 
every possible threat (in particular due to the broad spectrum of biological threats 
especially when taking into account th e possibility of manipulated pathogens and 
toxins). The enormous costs of such measures make it also impossible for Member 
States to continuously invest in  their countermeasure capacity. 
Some rapid licensing procedures exist, but these are not sufficiently developed and 
they may not be able to generate sufficient  production capacity in the case of large-
scale incidents. Problem 4.3: Not all Member States have adequate medical countermeasures in place 
The extent and coverage of medical countermeasures in 
place varies between the Member States.  
Many Member States would not have suffici ent decontamination capacity, especially 
in the case of release of nuclear or radi ological materials, wh ich requires isolation 
of victims. 
3.4. Scope of the problem 
The threat from CBRN materials affect s everybody in the EU, the Member States' 
governments and business, both directly and indirectly. 
The extent to which different stakeholders  are affected by existing problems differs. 
Nevertheless it is clear that the overall scale of legitimate use of CBRN materials across the private and public se ctor is substantial. 
 
EN 14   EN 3.4.1.  The chemical industry 
Chemical substances can be found all over modern society, with over 100,000 chemical 
compounds in use throughout academia, industry, agriculture and society at large. The 
turnover of the EU chemicals industry was € 476 billion in 2006, accounting for 29% of total world sales. In the same year, the ch emicals industry cont ributed 2% of total 
economy GDP
19. 
The geographical location of th e EU chemicals industry is ma inly concentrated in four 
countries20. Germany is the largest European producing country (26.1%), followed by 
France (13.0%), Italy (12.5%) and the Un ited Kingdom (11.7%). The EU chemicals 
industry in 2004 comprised 27,000 enterprises21 which collectively employed 
approximately 1.2 million people22. 
3.4.2.  The biological market 
Nearly all biological agents an d substances exist freely in nature. Viruses, fungi and 
toxins, can be found in different places in the world. In this respect, biological substances 
differ drastically from radiological and nucl ear, and chemical substances, which need to 
be produced. Most biological substances are used and grown for legitimate reasons. They are handled in the industrial world, incl uding the agro–industry, the pharmaceutical 
industry and in the medical  sector in general. 
Some biological substances ca n cause significant or even lethal harm. They can have 
direct, potentially lethal effect on human  health. These substances are handled by 
laboratories with specific containment facilit ies, usually referred  as to P3 and P4.
23 While 
highly harmful animal substances and harmfu l human substances can  be handled in P3 
laboratories, substances causing highly harmfu l human diseases can be handled only in 
P4 laboratories. Biosafety-Europe24, a project funded by th e Commission, conducted a 
survey of all P3 and P4 laboratories in th e EU, and found 310 of such laboratories in 
total. While P4 laboratories are exclusively part of government funded research centres, 
some of the P3 laboratories are also private research centres, or to a limited extent, owned by the pharmaceutical industry.  
3.4.3.  The Radiological and Nuclear industry 
Many industrial sectors use radi oactive materials, such as: 
                                                
 
19 CEFIC (2005), Facts & Figures: The European Chemical Industry in a Worldwide Perspective. 
20 Ibid 
21 Commission Staff Working Paper: REACH – An Extended Impact Assessment 
22 CEFIC (2008) The European chemical industry A global leader in innovation, supporting growth 
and well-being in Europe. 
23 As referred to in Council directive 200/54/EC. It  is worth noting that in the European Union there 
is a very large array of codification/terminology used for defining those laboratories (see: 
http://www.biosafety-europe.eu/index.html) 
24 http://www.biosafety-europe.eu/  
 
EN 15   EN • accelerators used in research (subatomic res earch, production of radioactive material, 
studying effects of radioactivity); 
• industry (sterilisation, production of radioactive material); 
• food irradiation and sterilisation; 
• industrial uses such as  affecting materials with radiat ion (e.g. radiographs, locating or 
controlling hidden levels of solids and liqui ds), tracing materials through radiation 
(test wear, to locate leaks, to trace fluid flow, to evaluate detergent efficiency) and 
using radiation to produce heat and power  (e.g. electrical generators for unmanned 
weather stations and buoys, power devices fo r thrusters in the space program, heat for 
diving suits); 
• medical use: diagnostic imaging: includes diagnostic x- ray and computed tomography. 
Magnetic resonance imaging and ultrasound are also included in diagnostic imaging, 
but do not use ionizing radiation;  
• nuclear medicine and radiation therapy; 
• consumer products such as luminous dials, gauges and signs, navigational lights and 
smoke detectors. 
3.5. Status quo, existing gaps 
Initially, it needs to be stressed that were the status quo  to continue, a c oherent approach 
towards the security of CBRN materials in the EU would be missing, and the EU 
capacity to fight the cross-border CBRN threat  would remain fragmented across different 
strands. 
An important body of legislation and voluntary agreements both at international and EU 
level regulating the handling of CBRN materi als does already exist. In the biological 
field, whilst there are some legislative instruments specifically focusing on security (potential terrorist threat), the bulk of intern ational and EU legislat ion is safety driven. 
The only exception is the nuclear field, wher e there already exists a strong focus on 
security. 
Table 3: Non-exhaustive list of key EU  legislation and no n-binding frameworks25 
European legislation 
C Council Directive 96/82/EC of 9 December 1 996 on the control of major-accident 
hazards involving dangerous substances (Seveso II) aims at mitigating the 
consequences of accidents. It focuses on safe ty, the formulation of emergency plans, and 
information exchange in case of incident. 
                                                 
25 For a comprehensive list of legislation and non- binding frameworks currently in place, see Annex 
3.  
 
EN 16   EN Council Directive 98/24/EC of 7 April 1998 on the protection of the health and safety 
of workers from the risks related  to chemical agents at work lays down the 
requirements for the protection of workers from ri sks to their safety and health arising, or 
likely to arise, from the effects of chemical ag ents that are present at  the workplace or as a 
result of any work activity involving chemical agents  
The 2006 Regulation concerning the registration, evaluation, authorisation and 
restriction of chemicals (REACH) proposes the regulation of the production of 
chemicals in such a way to  avoid chemical contamination of air, water, soil and the human 
environment in order to preserve biodiversity and to safeguard workers' and citizens' 
health and safety. 
The Standing Committee of Experts on Precursors addresses the risks posed by 
chemical precursors. The standing committee has been meeting since the beginning of 
2008. 
B Directive 2000/54/EC  purpose is to guarantee a better standard of safety and health for 
workers exposed to biological agents at work (risk group 3 & 4). The key rationale of this 
Directive is safety based and it does not cover security issues. 
Council Directive 82/894/EEC  on the notification of animal diseases, tackles the issue of 
animal health and its impact on humans. As  required by the Directive, Member States 
have to notify the Commission of the appearance and subsequent eradication of certain 
contagious diseases in order to prevent their spread in Community livestock.  
Council Directive 2000/29/EC  of 8 May 200026 on protective measures against the 
introduction into the Community of organisms harmful to plants or plant products and 
against their spread within the Community: this  directive lists all pests and diseases which 
are injurious for plants, whilst setting up a notification system for outbreaks.  
Directive 2000/54/EC of the European Parliament and of the Council of 18 September 
2000 on the protection of workers from risks related to exposure to biological agents at 
work.  
RN Council Directive 2003/122/Euratom of 22 December 2003 on the control of high-
activity sealed radioactive sources  and orphan sources (HASS Directive)  aims at 
improving the traceability of nu clear materials and thereby enhancing the security of 
sources to reduce the risk of ra dioactive sources being misused. 
Council Directive 96/29/Euratom of 13 May 1996 laying down basic safety standards 
for the protection of the health of workers and the general public against the dangers 
arising from ionizing radiation ("Basic Sa fety Standards” Directive / BSS Directive) 
lays down basic safety standards for the protection of the health of workers and the 
general public against the dangers arising from ionising radiation.  
Council Directive 89/618/Euratom of 27 November 1989 on informing the general 
public about the health protection measures  to be applied and steps to be taken in the 
event of a radiological emergency. 
                                                 
26 This directive creates a compulso ry notification system: when an outbreak occurs, Member States 
have to notify the Commission. Member States ha ve also to notify the Commission when there is 
an interception at the customs on imported/exported goods, http://europa.eu/scadplus/leg/en/lvb/f85001.htm 
 
EN 17   EN Directive 2004/37/EC of the European Parliament and th e Council of 29 April 2004 
on the protection of workers from the risk s related to exposure to carcinogens or 
mutagens at work.  This Directive sets out the minimum requirements for protecting 
workers who have been exposed to carcinogens and mutagens. 
Council Directive 2006/127/Euratom of 20 November 2006 on the supervision and 
control of shipments  of radioactive waste and spent fuel  provides for a compulsory and 
common system of notification and a standard control document for the shipment of radioactive waste and spent fuel. 
The European Programme for Critical Infrastructure Protection (EPCIP)  provides a 
framework for exchanging good practices and raising capability in a number of sectors, including the energy and nuclear s ectors, in all EU Member States. 
 
In addition to current legislation focusing pr imarily on safety issues, a number of other 
relevant gaps would continue to exist. Among the most important ones, the following 
need to be mentioned: 
• Significant differences in national tr ansposition and implementation of 
international and EU legislation , in terms of quality, elaboration and coverage. 
Terrorists and criminals could take adva ntage of less secure national contexts;27  
• Weaknesses in the regulatory framework : most current legislation and conventions 
cover certain CBRN materials only, rather  than assuming a package approach. The 
overall regulatory approach is fragmented and uneven across the different sources of 
threats. Consequently, planners of prev ention, detection and re sponse actions at 
different levels (national, regi onal, local), operators  of critical infrastructure and first 
responders have to comply with a variety of rules and systems; 
• Insufficient awareness of informat ion exchange mechanisms amongst 
stakeholders.  Especially , the involvement of private sect or stakeholders is rather 
limited;28  
                                                 
27 Overall, as concerns the implementation of the le gislation, there appear to  be different categories 
of Member States: - a group of Member States, including France , Germany, the UK, Italy, Spain have well-
developed and well-implemented legislative frameworks; 
- Nordic countries also show a good record in enhancing the security of biological agents and 
fostering mutual cooperation; 
- Other ‘Member States, such as Luxembourg and Belgium have implemented the legislative 
instruments, but this is not accompanied by a substantial institutional and operational framework; 
- new Member States: in a majority of these countries the regulatory framework may both show 
important legislative gaps and an insufficient level of implementation.  
Nevertheless, it needs to be stressed that existing gaps do not always apply to the same groups of Member States (e.g. a Member State might have good practices in ensuring facility security, but 
might lack good communication strategies with the general public). Targeting specific actions to 
specific groups of Member States would be a very difficult task to envisage and almost impossible to monitor. 
 
EN 18   EN • Insufficient early warning capacity . Several early warning systems exist in the EU 
to cover CBRN emergencies.29 However, there is no EU-wide system specifically 
dedicated to linking-up  the law enforcement community with a view to exchanging 
information on thefts, loss and suspicious tr ansactions. As a consequence, emergency 
responders and anti-terror coordinators do not have single au tomatic access to 
information on incidents and stolen or lo st CBRN materials in other EU Member 
States; 
• Personnel security.  Whilst some Member States have  elaborated vetting procedures 
in place, others apply much lower-level  procedures. High-risk CBRN materials, 
especially hazardous chemicals (such as hi ghly concentrated acids) and radiological 
sources (at a significant activity level) is relatively widely used  in construction and 
industry, the medical sector and research. As a consequence, the number of persons 
who handle or may have access to such mate rial is considerable. This includes 
researchers and research students, doctors  and X-ray assistants, as well as a high 
number of engineers and blue-collar workers in the chemical industry; 
• Access to and availability of CBRN materials . There is potentially a significant 
quantity of CBRN materials re latively easily available that could be weaponised. 
Provided one has the means and the knowledge, it is also relatively easy to establish 
‘private’ laboratories or find other ways  to manipulate CBRN agents. The most 
                                                                                                                                                 
28 Only 15% of all EU initiatives specifically mention the involvement of industry stakeholders. 
Although there are certain cooperation mechanisms in  place (in the chemical field CEFIC; in the 
biological field: Europa Public Health, the European Group on Ethics in Sciences and New 
Technologies, Europa-bio and EBSA; in the radiological and nuclear field: the European Atomic 
Forum FORATOM, the European  Society for Radiology, th e European Association for 
Radiology, the European Coordination Committee of The Radiological and Electromedical 
Industries) which can constitute examples of good practice at EU level, the number of these 
initiatives remains limited. Private sector stakeholders thus have limited opportunity to communicate their concerns, to comment on the feasibility of certain public decision-making and 
policies and to provide feedback on the potential impacts of some initiatives on industry. 
29 The Rapid Alert System for Biological, Chemical  and Chemical Terrorist Events (RAS BICHAT) 
for example is the rapid alert sy stem used for exchanging information on health threats due to 
deliberate release of chemical, bi ological and radio-nuclear agents (notification of confirmed or 
suspected events, exchange of information and coordination of measures among partners. More 
precisely in the biological field, the Early Warn ing and Response System is a system aiming at 
ensuring a rapid and effective response in case of incident related to communicable disease. A 
similar system was developed more specifically  for chemical accidents with the Rapid Alert 
System for Chemicals (RAS-CHEM). The system is meant to link the various poison centres of 
the European Union and the Ministries of Health for the exchange of information on incidents including chemical agents relevant to terrorism a nd other events leading to release of chemicals, 
and consultation and coordination of counter-measur es. In the radiological and nuclear field, the 
ECURIE system (European Community Urgent Radiological Information Exchange) is a radiological emergency notification and information exchange system. The system notifies the 
national Competent authorities of the participating States (currently EU Member States, Croatia 
and Switzerland, IAEA and the European Commission) in case of a major nuclear accident or radiological emergency. During an emergency the system also provides an  information exchange 
platform for the participating Stat es in order to inform about the current and foreseeable status of 
the accident, radiological status of the envi ronment, meteorological conditions, national 
countermeasures taken, etc.  
 
EN 19   EN dangerous of these materials could potentially be used in terrorist attacks for their very 
harmful properties. This would require access to the material itself, access to 
knowledge on how to transform or weaponise the material and finally, and access to 
the equipment required for such manipulation; 
• Security of facilities producing, st oring or distributing CBRN materials . Whilst 
safety standards for facilities handling CBRN materials, especially those that could 
potentially be very dangerous, are cove red by international agreements and EU 
legislation on public health, infrastructure protection, etc, the protection of facilities 
for security purposes is mainly a national affair. Member States have taken very 
divergent approaches to facility security, fo r example with regard to overall security 
plans for facilities and the appointment of security mana gers; security procedures 
within facilities and communi cation between relevant stak eholders (e.g. between law 
enforcement and facilities);  
• The use of priority lists to identify which CBRN materials pose safety and 
security challenges. Today,  there are a number of ‘prior ity substance lists’ which 
have been created at national, EU and in ternational levels. Table 4 below provides 
several examples of such lists.  
Table 4: Examples of priority lists 
List Level  Purpose Type of 
CBRN 
Chemical Weapons Conven tion International Prohibit use for warfare C 
NATO's International Task Force 25 (ITF-25) list of 
hazardous chemicals International Prohibit use for warfare C 
Biological and Toxin Weapons Convention (BTWC)  International Prohibit use for warfare B 
Australia Group International Export CB 
World Organisation for Animal H ealth International Safety B 
The IAEA Code of Conduct on the Safety and Security of 
Radioactive Sources International Safety RN 
International Air Transport Associ ation International Transport CBRN 
International Carriage of Dangerous Goods by Road 
(ADR) International Transport CBRN 
Regulation EC 1334/2000 on setting up a Community 
regime for the control of exports of dual-use items and 
technology European Export CBRN 
(products and 
technologies) 
Common Military List of the European Union European Export CBRN 
(weapons) 
Council Directive 2008/68/EC on the inland transport of 
dangerous goods European Transport CBRN 
 
EN 20   EN Council Directive 96/82/EC (Seves o II) European Public health C 
Regulation EC 1907/2006 (REACH) European Safety C 
Council Directive 2000/54/EC (protection of workers 
from risks related to exposur e to biological agents at 
work) European Safety B 
Council Directive 2000/29/EC (protective measures 
against the introduction into the Community of organisms 
harmful to plants or plan t products and against their 
spread within the Community) European Safety B 
Matrix currently under development by DG SANCO European Security B 
Council Directive 2003/122/Euratom (on the Control of 
High Activity Sealed Radioactive Sources) European Safety RN 
Centre for Disease Control and Preven tion (USA) National Bioterrorism  B 
Schedule 5 pathogens and toxins  (UK) National Security  B 
Dutch priority list (under preparation) (Netherlands) National  Security  CBRN 
Biological Materi als Ordinance of 27 Jan 1999 as 
amended (Germany) National Safety  B 
Foreign Trade and Payments Act of 28 Apr 1961; 
Foreign Trade and Payments Ordinance Of 18 Dec 1986 
(Germany) National Export B 
List of War Weapons Control Act, § 20(Germany) National Security  B 
Protection against Infection Act of 20 Jul 2000 
(Germany) National Public health B 
 
The existence of such a high number of different  lists, each requiring different levels of 
actions and covering different areas, makes compliance a complicated affair for large and 
multinational companies, such as major pharmaceutical companies or chemical industry. In addition, practically none  of the lists are specifi cally aimed at security. 
3.6. Subsidiarity and propor tionality principles 
The subsidiarity principle
 is satisfied as the measures  being undertaken through the 
CBRN package cannot be achieved by any single  EU Member State and must therefore 
be addressed at EU level. Although security issues are to a large extent a national 
competence, there are several reasons why some  of them need to be tackled at the EU 
level: 
• the root of the problem is  evidently an in ternational phenomenon and many of the 
existing security initiatives and legisl ation are internati onal in character; 
 
EN 21   EN • a number of problems related to CBRN ma terials are equally international in 
character. These include fo r example the exchange of  information among Member 
States, cooperation between Member  States and transport security; 
• a variety of security measures currently ex ist in Member States. Potentially, since no 
internal borders exist, lower standards of security in one Member States might allow the malicious use of CBRN materials in another one;
30 
• there are potential economies of scale to be generated through the identification and 
dissemination of good practice at  the international and EU levels. In particular, good 
practice related to the implementation and en forcement of EU legislation needs to be 
tackled at the EU level. 
Cooperation is especially needed if the EU Member States wish to improve their level of 
capability in countering CBRN threats either at  national or European level. Terrorism is 
international in character, and so would be  the consequences of a potential CBRN 
incident – the EU can therefore only be as secure as its weakest link. In this sense, 
activities at EU level and an EU co-ordinated  approach is needed and beneficial to all 
relevant stakeholders. 
The EU is well placed to lead and to act as a catalyst for th is cooperation, and activities 
in the CBRN field are in accordance with the s ubsidiarity principle, especially insofar as 
they help reinforce the channels for bilateral and multilateral cooperation between Member States. At the same time interna tional cooperation need s to extend beyond the 
EU and in specific cases focus also on third countries. 
The assessment of proportionality
 of a policy to combat terrorism is extremely difficult. 
The arbitrary and apparently irrational nature of terrorism means that its threat and 
consequences are difficult to predict. The f ear generated is strong and induces indirect 
damage to well-being way beyond the loss of lif e, injury and propert y. The reactions of 
security agencies to terrorism may themse lves induce negative effects on citizens.  
On the other hand, the poten tial negative effects of a te rrorist attack using CBRN 
materials are significant, in terms of  financial losses, longer-term economic 
consequences, losses of life and casualties a nd social disruption and overall well-being. 
Well targeted and relevant action in this fiel d to prevent such att acks from happening, to 
identify planned attacks and to appropriately de al with the consequences of an attack is 
therefore justified. In these circumstances EU  activities in the protection against potential 
CBRN incidents, especially taking into consid eration the existing security gaps, the fact 
that a difference needs to be made be tween high-risk CBRN materials and CBRN 
materials in general, and the f act that a CBRN incident within the EU is a real possibility, 
are proportionate. 
                                                 
30 In general, experience has demonstrated that terrorists will use those materials which they can 
most easily obtain to commit their attacks. The most  telling example is the explosives used in the 
Madrid attacks, which were stolen in France, po ssibly reflecting the fact that the measures taken 
to protect explosives in Spain are st ricter than those taken in France.  
 
EN 22   EN 4. POLICY OBJECTIVES  
As a reflection of the problems identified, the objectives of the CBRN package focus 
mainly on the areas defined in Table 5. 
Table 5: Problem structure a nd related policy objectives 
General horizontal objective 
1. To improve the EU's capacity to counter CBRN threats 
Specific horizontal objectives 
1.1 To increase 
effective international 
cooperation, 
coordination and dialogue on CBRN 1.2 To raise 
awareness and increase 
knowledge and 
information sharing on CBRN 1.3 To reduce, 
where possible, judicial, legal, 
jurisdictional 
barriers and constraints 1.4 To improve 
personnel security 1.5 To 
strengthen and prioritise 
research on 
CBRN 1.6 To increase 
awareness of security 
implications in 
funding decisions 1.7 To increase 
awareness of security aspects 
in publishing 
Objectives - Prevention  Objectives - Detection Objectives – Preparedness and 
response  
General  Specific  General  Specific  General  Specific  
4.1 To improve 
response and 
emergency 
planning and 
protocols, also at 
the EU level 2.1 To prevent 
access to 
legitimately 
produced and used 
CBRN materials by 
terrorists or other 
criminals  3.1 To improve 
detection and 
identification 
capacity and 
capability 
4.2 To develop an 
EU approach 
towards response 
and emergency 
planning 
2.2 To improve 
monitoring and 
control over CBRN 
materials  4.3 To ensure 
ongoing 
information flows 
in case of CBRN 
emergencies 
4.4 To increase the 
chances of finding 
and prosecuting 
terrorist and other 
criminals 2. To increase the 
security of CBRN 
materials and the 
safety of citizens 
and possible 
targets   
2.3 To improve 
overall awareness 
of the potential 
dangers and risks, 
contributing to a 
high 'security 
culture' 3. To increase the 
chances of 
detection and 
identification of 
CBRN materials 
before and after 
terrorist 
incidents 
3.2 To develop an 
EU approach 
towards detection 
and identification 4. To reduce to a 
minimum the 
effects of terrorist 
incidents 
involving CBRN 
materials   
4.5 To enhance 
national and EU 
countermeasures 
and on-the-ground 
response capacity 
5. POLICY OPTIONS AND THEIR ASSESSMENT  
The below assessment of available policy opti ons differs slightly from the standard 
impact assessment structure with the aim of conducting a streamlined assessment. The 
specific impact assessment approach focuses on two main policy options: 
 
EN 23   EN • the assessment of the status quo, i.e. the baseline scenario; 
• the assessment of relevant CBRN actions.  
Due to the complexity and horizontal nature of the topic to be analysed, and the 
significant number of actions identified in the course of the stakeholders consultation, the 
relevant CBRN actions are identified on the basi s of the first screeni ng of all identified 
actions that can be found in Annex 4. Th e purpose of the first screening was to 
determine: 
– which actions do not require a thorough assessment, as they are considered acceptable, 
feasible and non-controversial. Th e screening crit eria include: 
1. stakeholders' support through cons ultation of the Task Force; 
2. positive or at least no negative economic, social and environmental 
impacts and effects on fundamental rights; 
3. limited financial costs; 4. high EU value added, strong EU rationale; 5. no issues in relation to s ubsidiarity and proportionality. 
– which actions do require a thorough assessment because they do not meet the criteria 
outlined above (e.g. they are considered very costly, politically difficult to agree and / or with negative effects on fundamental rights, etc); 
On this basis, the first screening categorised the actions as follows: 
– uncontroversial actions considered overall acc eptable and meeting at least 4 screening 
criteria. 
– controversial actions possibly ra ising concerns as to their feasibility or cost, meeting 
fewer than 4 of the screening criteria identified above. 
The results of the screening exercise are as follows: 
• A total of 99 actions  are considered uncontroversial and will be included in the 
preferred policy option (CBRN Action plan); 
• A total of 48 actions  are considered potentially cont roversial and will be further 
assessed in section 5.2. 
Table of symbols; " -" for negative impacts and "+" for positive impacts 
Assessment of achievement of policy objectives 
 
EN 24   EN 0 1 2 3 4 5 
Baseline/No 
impact Very small 
impact Small 
impact Medium 
impact Significant 
impact Very 
significant impact 
Assessment of financial costs31 
1 2 3 
Low costs: <1 million EUR Medium costs: between 1 
million EUR - 5 million EUR High costs: > 5 million 
EUR 
Assessment of economic impacts 
-- - 0 + ++ 
Negative impact Small negative 
impact Neutral / no 
impact Small positive 
impact Positive impact 
 
5.1. Baseline scenario or status quo 
Table 6: Status Quo 
Assessment Criteria Rating 
(from -, 0 
- 5) Motivation of the rating and aspects of the policy action necessary to achieve the impact 
Relevance 
1.1 To increase effective 
international cooperation, 
coordination and dialogue on 
CBRN 0 Current international, cooperation an d dialogue would be continued. As 
elaborated in the problem assessme nt, this would continue to suffer 
from inefficiencies and possible dup lication of efforts. It would not 
involve all Member States and it would lack a common EU position in 
some cases whether this would be st rongly beneficial. The current lack 
of effectiveness would also impact  on the EU’s early warning capacity 
and its capacity to set up effective public communication in case of a CBRN incident. 
1.2 To raise awareness and 
increase knowledge and 
information sharing on CBRN 0 Under the status quo , a great deal of stakeholde rs would continue to be 
unaware of at least part  of the cooperation stru ctures and information 
sharing mechanisms which exist. Communication levels between 
                                                 
31 The criteria for assessing the costs in are based on the fact that the costs of implementation will be 
subdivided among a number of actors, e.g. 27 Member States or the Commission (existing financial programmes),and will occur across the several years' implementation period. 
 
EN 25   EN Assessment Criteria Rating 
(from -, 0 
- 5) Motivation of the rating and aspects of the policy action necessary to achieve the impact 
Member States would not improve, even though some good bilateral 
and sometimes multilateral contacts would be further developed. People having access to or handling CBRN materials will not be sufficiently aware of the dangers th at such materials may represent. 
1.3 To reduce, where possible, 
judicial, legal, jurisdictional 
barriers and constraints 0 Differences in practices and legisla tion would continue to exist. There 
would therefore be no mutual recognition of for example forensic evidence or of vetting procedures. In  addition, in some Member State 
criminal law may not cover all C BRN acts or may not cover these 
adequately, with the pote ntial of legal loopholes. 
1.4 To improve personnel 
security 0 Current arrangements in the Member States with regard to personnel 
security would continue to exist. Some Member States would keep their 
well-developed background checks a nd vetting procedures, whilst in 
other countries no such screening wo uld exist or only for persons which 
require a very high level of security  clearance (e.g. in P4 laboratories). 
This will lead to important differe nces which terrorists could use to 
gain access to CBRN materials. 
1.5 To strengthen and prioritise 
research on CBRN 0 Current research efforts would cont inue. This includes national-level 
research projects as well as research  undertaken as part  of the Research 
and Development Framework Progr ammes funded by the European 
Commission. In addition to current funding availability not being sufficient, Member States would also not have a clear picture on what kind of research is alr eady being undertaken in other national contexts, 
and what the upcoming research needs would be. 
1.6 To increase awareness of 
security implications in funding decisions 0 
No changes would occur, some fundi ng organisations, especially those 
based in the US, would review s ecurity implications whilst other 
organisations will not pay attention to such issues. 
1.7 To increase awareness of 
security aspects in publishing 0 No changes would occur. The pub lication of research through open-
source literature would continue. So me publishers, for example in the 
US, would discuss possible security i ssues with authors whilst in other 
countries no such check would take place. 
2.1 To prevent access to 
legitimately produced and used 
CBRN materials by terrorists or other criminals  0 
CBRN materials would conti nue to be relatively available. This would 
be particular the case for chemicals, as a number of substances can be acquired in shops and through the internet. CBRN facilities, and in particular possibly smaller outfits, will not always have appropriate 
security management in place. 
2.2 To improve monitoring and 
control over CBRN materials  0 Monitoring and control of CBRN ma terials would remain problematic 
in some countries, for some types of  material (e.g. radioactive sources) 
or in some points of the supply chain (mainly at the level of end users). 
 
EN 26   EN Assessment Criteria Rating 
(from -, 0 
- 5) Motivation of the rating and aspects of the policy action necessary to achieve the impact 
The opportunity for losses and thef ts would remain the same unless 
Member States would launch improvements, with a real danger of further losses and thefts. In additi on, if a theft or loss would occur, 
many stakeholders would not know to wh om they were to report this to. 
2.3 To improve overall 
awareness of the potential 
dangers and risks, contributing to 
a high 'security culture' 0 The low levels of awareness and unde rstanding of the potential dangers 
and risks of CBRN materials would pe rsist and could deter people from 
noting and reporting suspicious behavi our and transactions. Insufficient 
education, training and other measur es to inform staff and other 
stakeholders of dangers and risks in some countries could lead to 
terrorists and criminals actively attempting to obtain these materials where these are least protected.  
3.1 To improve detection and 
identification capacity and 
capability 0 Current detection capacity and capabili ty would continue to be low in 
some Member States, with a very  low chance that certain CBRN 
materials are detected. Detection sy stems and equipment would not be 
used in a targeted way and may not be placed in all relevant locations. 
3.2 To develop and EU approach 
towards detection and 
identification 0 The differences in the standards fo r detection systems and equipment, 
as well as different ways of testi ng, trialling and certifying these would 
remain. In addition to the supply of such systems and equipment not meeting the specific needs of clients,  industry would also continue to 
incur costs for having to comply with  27 different sets of standards and 
other requirements. 
4.1 To improve response and 
emergency planning and 
protocols, also at the EU level 0 Differences in CBRN emergency planning would continue to exist in 
the Member States and, in some  national contexts, would take 
insufficient account of intentional re leases and the potential use of 
CBRN materials for a terrorist attack. This would also mean that first responders and other stakeholders involved in emergency situations 
would not know what steps to take  and who to involve in crucial 
moments. 
4.2 To develop an EU approach 
towards response and emergency 
planning 0 Response and emergency planning w ould continue to be a strictly 
national affair (with some intern ational guidance and cooperation), 
insufficiently taking into account th e likely cross-border effects of 
CBRN incidents. 
4.3 To ensure ongoing 
information flows in case of 
CBRN emergencies 0 The current levels of information exchanges as well as information 
protocols would continue to exist.  These may be insufficient in a 
number of national contexts, not ad equately reaching the stakeholders 
required and / or not envisaging th e need to involve neighbouring and 
other countries. 
4.4 To increase the chances of 
finding and prosecuting terrorist 0 Not all Member States will have incorporated criminal and forensic 
 
EN 27   EN Assessment Criteria Rating 
(from -, 0 
- 5) Motivation of the rating and aspects of the policy action necessary to achieve the impact 
and other criminals investigations into emergency response plans, especially if the latter do 
not sufficiently take account of malic ious intent. This  could lead to 
important evidence being lost or spoiled. 
4.5 To enhance national and EU 
countermeasure capacity 0 Some Member States will have good medical countermeasures (in 
terms of drugs, vaccines and therap eutic capacity) and decontamination 
capacity whilst others may not prio ritise such measures or lack 
resources to put these in place. It is unlikely that any of the Member 
States are fully prepared for all type s of CBRN material s that could be 
used in a terrorist attack. In the event of a large-scale incident, the 
different capacities can lead to important cross-border movements of 
the population. 
Expected impacts  
Financial and economic impacts 0 The current level of costs would be maintained, with differing levels of 
investments between the Member States as well as cost-inefficiencies due to a lack of harmonisation betw een the countries. In case of an 
incident, the economic impact c ould be severe, see section 3.2 
Social impacts 0 Without improving the overall approach  to achieving a higher security 
of CBRN materials, the potential of preventing CBRN incidents from 
occurring would not be improved. In case of such an incident actually 
occurring, the social impacts in terms of public health and safety as well as the security of citizens (in terms of potential casualties) would 
be severe.  
Environmental impacts 0 If the status quo was to continue, the long term environmental impacts 
might be negative. As there woul d be no activities towards better 
prevention, protection and response of /to CBRN incidents, the risk of 
such incidents occurrin g (with serious environm ental impacts such as 
for example contamination of specifi c areas) would not be reduced.  
Impacts on fundamental rights 0 The continuation of the status quo would have no particular effects on 
fundamental rights 
5.2. Detailed assessment of the selected actions 
Following the first screening exercise presente d in Annex 4, a total of 48 policy actions 
require a further assessment, based on the following assessment criteria: 
• a rating as to the extent to which the action is expected to meet the relevant objectives; 
• the financial and economic effects of each act ion. Where possible, an estimation of the 
costs of each action has been provided; 
 
EN 28   EN • where relevant, a description of the potenti al social and environmental impacts, as 
well as effects on fundamental rights. With respect to environmental impacts, it is 
worth mentioning that only direct envir onmental impacts of a specific action are 
considered in the below assessment. It need s to be stressed how ever that indirect 
positive effects of preventing CBRN incidents are significant and certainly add to the 
positive environmental effect concerning ai r quality, water quality, soil quality, land 
use, animal and plant health and food and feed safety in general; 
• the EU added value and rationale for EU intervention; 
• the need to change or develop EU legislation in the years to come. 
It also needs to be stressed initially, that , due to the sheer number  of actions described, 
their assessment can only touch upon the mo st relevant impacts with the purpose of 
making the assessment as focused as possible. Nevertheless, in most relevant cases, where the assessed action can be considered as  particularly sensitive, a more detailed 
description of its impacts and consequences is included. In ad dition, all actions that might 
result in separate legislative proposals or hi gh costs in term of resources at EU and/or 
national level will be subject  to separate impact assessm ents or feasibility studies. 
The chosen approach addresses the difficul ties associated with providing an impact 
assessment of a wide-ranging Action Plan , and aims to focus the assessment on those  
actions for which the possible impact is th e biggest in terms of costs or possibly 
controversial political choices  to be made. The approach tr ies to combine and look for 
commonalities in more than 260 actions that ha ve been identified as necessary through 
the work of the CBRN Task force. Issues such  as cost-effectiveness,  overlaps, synergies, 
duplications with already ex isting measures have been discussed during this long 
consultation phase, and are al ready taken into considera tion when narrowing down the 
necessary actions to the ones assessed below.  
The numbering of the actions assessed below corresponds to the list of actions included 
in Annex 4. Actions identified with the lett er H (for Horizontal ) are common to all 
CBRN strands (i.e. chemical, bi ological and radiological/nuclea r), actions identified with 
the letters C, B and RN are applicab le to the chemical, biological and 
radiological/nuclear st rands respectively.  
Action B.0 (Implementing the Action Plan) 
The EBN (European Bio-Network) should be created in order to support the 
implementation of the Action Plan. EBN would be a structure which would pull together 
European expertise on bio-preparedness from  different sectors – research community, 
private sector and public sector (including the security and inte lligence community). Its 
role would be to de velop guidelines and codes of conduc ts for researchers concerning 
materials and resources for education about e ffective and secure bio-standards and best 
practices. The Network would pr omote and support developmen t of bio-standards at EU 
level. 
Achievement of (relevant) policy objectives  
 
EN 29   EN 1.1 To increase 
effective international cooperation, coordination and dialogue on CBRN 1.2 To raise 
awareness and increase knowledge and information sharing on CBRN 2.3 To improve 
overall awareness of the potential dangers and risks, contributing to a high 'security culture' 4.1 To improve 
response and emergency planning and protocols, also at the EU level 
3 4 2 1 
Assessment of relevant effects  
Economic impacts : the costs for this action would be  medium, depending on the structure 
and size of a network. A network with a central coordinating body could involve an 
investment of approximately 3 million EUR/year.  
Financial costs Economic impacts 
2 0 
Legal effects : the establishment of the network is likely to requ ire a legislative proposal. 
Assessment of EU added value  
The added value of this action would be  low and it would raise a number of 
proportionality and subsidiarity issues. Firs tly, establishing a formal and permanent body 
at the EU level might duplicate existing stru ctures. Secondly, the actions received little 
support from relevant stakehol ders. Thirdly, most of the act ions foreseen within this 
network would fall under Member States' resp onsibility. Fourthly, the network in its 
envisaged form, would focus onl y on the biological side, rath er than have a horizontal 
approach.  
Due to these factors, Action B0 is considered unfeasible. 
Action H.08 (Develop improved in formation tools for CBRN security) 
The Member States and the Commission s hould establish a law enforcement Early 
Warning System (EWS) for CBRN related inci dents, taking account of existing systems 
and experiences and based on established comm on European lists of the most high-risk 
CBRN materials. Such a mech anism would include inform ation on immediate threats, 
losses/thefts, and suspicious tr ansactions and would in any ca se need to be accessible to 
the law enforcement authorities and relevant emergency responders of  the Member States 
and to Europol. As a first step, the extension of the existing G6 system should be 
considered. The system should be without prej udice to the exchange of information on 
public health issues. 
Achievement of (relevant) policy objectives  
 
EN 30   EN 1.1 To increase effective international 
cooperation, coordination and dialogue on CBRN 1.2 To raise awareness and increase 
knowledge and information sharing on CBRN 
3 4 
As a concept, the establishment of an EU-wide Early Warning System which would 
combine C, B and RN would be  beneficial, as it would im prove information exchanges 
and allow Member States to take the necessary precautions and other steps when threats, losses, thefts and suspicious transactions are reported. Neverthele ss, there are several 
issues to take into account. Fi rstly, several separate systems already exist, such as the 
existing system functioning betw een the G6 states or Ecurie, the radiological emergency 
notification and information exchange system . Secondly, it is very important to avoid 
system overloads, which is for example occurring in some Member States with regard to the European Arrest Warrant (EAW). To this  end, clear protocols should be established. 
The system should have two levels: incidents and threat/suspicions. It  would need to be 
highly secured. 
Assessment of (relevant) effects
 
Economic impacts: The costs of this action are potential ly very high, as it would require 
a sophisticated system linki ng all Member States, which should be able to process 
substantial information up- and downloads. Se veral countries outside  the G6 cooperation 
countries (DE, ES, FR, IT, PL, UK) alrea dy have early warning systems operating for 
individual CBRN materials an d related threats (for exam ple Austria or the Nordic 
countries). Interlinking and extending thes e would be less burdens ome than setting up 
entirely new systems. The action would al so require, at national and EU levels, 
continuous and updated inputs. The financ ial costs may range between hundreds and 
millions EUR, depending on the adequacy of the existing systems, the number of users and security requirements. On the longer term, however, having a combined system 
would lead to some important economies of scale. 
Financial costs Economic impacts 
3 ++ 
Social impacts: The action would have a positive effect on Governance, as it would help 
improve communication and cooperation betwee n the Member States. The action would 
also improve Public health and safety, given that an early warning system could directly 
help to prevent deaths  and injuries. Furthermore, the action would contri bute to fighting 
crime and terrorism and increasing securit y, by improving the exchange of information 
within the law enforcement community. 
Assessment of EU-added value  
 
EN 31   EN High added value. CBRN incidents and thre ats have an international dimension. 
Incidents can have pan-European effects and a loss / theft of a substance in one Member 
State can have serious effects on another Member State. 
Action C.03 (Improve training) 
The Member States should organise regular ex ercises concerning the security of chemical 
facilities in order to test preparedness meas ures in place and raise awareness among staff. 
Achievement of (relevant) policy objectives  
1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.3 To improve overall 
awareness of the potential dangers and risks, contributing to a high 'security culture' 
4 1 4 
The organisation of regular exercises is of great importance to ensure that chemical facilities are prepared against terrorist or criminal threats and know how to respond. Staff 
awareness is particularly important in this re gard. The coverage and scale of the action is 
significant, especially when taking into accoun t the number of chemical facilities in the 
EU – it may thus be advisable to focus on providing ‘train-the -trainer’ programmes 
instead. It would in addition be important that  the Member States followed some kind of 
common EU guidelines for developing an d providing the training, to ensure a 
harmonised approach to preparedness overall.  This may require a mapping of current 
training provided and the identification and ex changes of good practices in this regard (as 
proposed for the biological threats under action B.3). 
Assessment of (relevant) effects
 
Economic impacts: Depending on the type of chemical facilities addressed (e.g. all or 
only those dealing with chemical s that would be included in the EU priority substances 
list), this action could be costly particular ly for those Member States which do not yet 
have such training programmes in place. A si ngle training session could run from around 
200 – 500 EUR per half-day. 
Financial costs Economic impacts 
2 - 
Social impacts: The action would help to improve Pub lic health and safety, as staff in 
chemical facilities would be be tter prepared to deal with chem ical incidents. Better staff 
preparedness would contribute  positively to crime and terr orism prevention and increase 
security. The action would also improve the St andards and rights rela ted to job quality, as 
it would improve the workers' access to continuous training. 
 
EN 32   EN Assessment of EU-added value  
Putting in place a requirement for Member Stat es to provide training is important to 
ensure that in all countries staff in chemical  facilities is sufficiently prepared. However, 
without common guidelines or standards for such training there may still be great 
differences in the quality and content of su ch training, thus reducing the EU added value 
of this action. 
Action B.03 (Improve training) 
Member States and the Commissi on should consider and develop: 
– Guidelines at the EU level for mini mum training requirements for persons 
working with, having access to, or ha ndling biological agents and toxins; 
– In conjunction with universities a nd professional associations, minimal 
requirements for academic training on biosafety, potential misuse of 
information and biological agents and toxins and bio-ethics for 
undergraduate, graduate a nd postgraduate students. 
 
EN 33   EN Achievement of (relevant) policy objectives  
1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.3 To improve overall 
awareness of the potential dangers and risks, contributing to a high 'security culture' 
4 2 4 
Developing minimum training requirements wo uld ensure increased awareness of people 
working with or having access to  biological agents and toxins on specific security issues. 
Indeed some Member States will have deve loped guidelines or appr oaches that can be 
applied in other countr ies. It would also us eful to develop some minimal requirements for 
certain types of academic training, including on  the dual use of agents and toxins. This 
would ensure a more harmonised approach in the EU Member States and enable counties 
with little experience in this ar ea to learn from their peers.  
Assessment of (relevant) effects  
Economic impacts: The development of minimum training requirements requires 
medium investments, depending on their nature and scale. A mapping study to put 
forward guidelines or approaches to be used  and promoted at EU level could amount to 
approximately 200,000 EUR. Around the same co sts would be incurred for a study to 
identify good practices, should this also be included. 
Financial costs Economic impacts 
1 0 
Social impacts: On the one hand, the action may nega tively affect Pub lic health and 
safety, as spreading information to gradua te and undergraduate students may create a 
perception of unsafety. On the other hand, the action would also positively affect Public 
health and security as it might raise the mi nimum training standards in the weakest links. 
The action could also increase security, and reduce the possibility of crime and terrorism 
involving biological agents and toxins.  
Assessment of EU-added value  
There is a strong EU rationale for this act ion, as ensuring a common set of guidelines 
would ensure an EU wide 'interpretati on' of minimum training requirements. 
Action H.12 (Strengtheni ng personnel security)  
The Member States and the Commission should develop and introduce common 
graduated criteria for background checks and vetting requireme nts in relation to 
personnel having access to high-risk CBRN  materials along the whole chain of 
production, storage, distribution and use. This should be don e based on the establishment 
 
EN 34   EN of a common European list of the most high-risk CBRN materials. These common 
criteria should be based on a graduated ap proach. In the course of the recruitment 
process, the recruiting organi sation should ensure that the credentials of the candidates 
are properly checked and a ssessed. The Commission should  launch a study concerning 
existing background check procedures and requirements within the CBRN industry. 
Achievement of (relevant) policy objectives  
1.4 To improve personnel security 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  
4 4 
Launching a study on existing background check procedures (and vetting processes) 
would be very beneficial in identifying gaps and good practices, which would help to 
formulate common criteria that are realistic a nd acceptable. Limiting this to the European 
common list is equally benefici al. The length of the list (i .e. the number of materials 
covered) will determine the coverage of this option: whilst a short list of highly dangerous materials will most likely cover those sectors in which background checks and 
vetting processes are already being applied, a long list (in particul ar with regard to 
chemical substances) could substantially e xpand the elements of the chain of production, 
storage, distribution and use to be covere d. An important additi onal factor to be 
considered would be the abilit y of the individual Member Stat e to carry out and maintain 
such background checks, vetting processes and levels 
Assessment of (relevant) effects
 
Economic impacts.  According to available indications , costs for a ‘simple’ background 
check could amount to 100-200 EUR, whilst a full- blown vetting is likely to cost up to 
5,000 EUR per person. Some Member States w ith less developed background checks and 
vetting processes will face costs to meet th e EU criteria that will be put forward. The 
financial inputs required will also vary depe nding on the length of the EU list of most 
high-risk materials. A graduated appro ach based upon access to the most dangerous 
substances would prove far more feasible financially. 
Financial costs Economic impacts 
1 0 
Social impacts : Depending on the number of people to be affected, the action could 
reduce privacy of individuals. On the other hand, the action increase s security as it 
reduces the possibility of unauthorised access to  high-risk CBRN materials, and thus the 
possibility of crime and terrorism involving high-risk CBRN materials. 
Fundamental rights: Background checks and vetting requir ements establish conditions 
for access to employment in certain areas of  the labour market. Thus, an impact on the 
 
EN 35   EN freedom to choose an occupation and the right to engage in work can be expected. Such 
background checks require the processing of personal data . The personal data protection 
principles apply to all pro cessing of personal data by an y person whose activities are 
governed by Community law. Any collection of , or access to personal data by officials of 
the State about an individual mu st be duly justified, in line w ith the law and necessary in 
a democratic society in pursuit of one or more  of the legitimate aims listed in Article 8 
para  2 of the European Conven tion on Human Rights (ECHR). 
Legal effects:  The common criteria may require a le gislative instrument at EU level. 
Assessment of EU-added value  
Establishing common gra duated criteria for background checks and vetting would 
provide a high added value, as  it would improve overall secu rity standards and levels 
across the EU and help Member States wi th less developed approaches to make 
improvements. The action would also increa se the trust between the Member States, 
which would be beneficial to further enhance the mutual recognition of  vetting processes. 
It would be important to ensure that a bala nced approach is taken, involving vetting for 
only a limited number of people and if necessary good quality background checks for 
those who are not in direct contact, or onl y rarely, with high-risk  materials. Mutual 
recognition of vetting processes would also be nefit the individual workers that make use 
of their right to engage in occupation in other Member Stat es. It would reduce costs for 
businesses and administrations as Member Stat es would be able to  recognise the vetting 
processes conducted by other Member States. 
Action H.13 (Strengtheni ng personnel security) 
The Member States and the Commission should identify and exchange good practices on 
approaches to security of non-EU visiting st aff and students; Memb er States should aim 
at common procedures across the EU. 
Achievement of (relevant) policy objectives  
1.3 To reduce, where 
possible, judicial, legal, jurisdictional barriers and constraints 1.4 To improve 
personnel security 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  
4 2 3 
Assessment of (relevant) effects  
Economic impacts: The costs for identifying good pract ices would be low, involving a 
mapping study to identify good practices, their validation and organisi ng the exchanges. 
The costs of the subsequent establishment of an EU procedure to deal with the screening 
of visiting staff from outside the EU would also be low to medium, again depending on 
the type of background checks or vetting a pplied. The action coul d however have the 
 
EN 36   EN negative economic effect of inhibiting excellenc e and talents to come to work in the EU, 
thus reducing overall competitiveness. 
Financial costs Economic impacts 
2 - (if a procedure is applied) 
Social impacts: The action could negatively affect th e right to private life and personal 
data protection of the individuals involved, eq uality of treatment and opportunities. On 
the other hand, since common procedures at EU  level help improving security standards 
within the weakest links, the action increases security, and contributes to the prevention 
of crime and terrorism involving high-risk CBRN materials. 
Fundamental rights : Depending on the form of the co mmon procedures, the action could 
have a negative effect on the Non-discrimina tion principle. Also, any collection of, or 
access to personal data by officials of the Stat e about an individual must be duly justified, 
in line with the law and necessary in a democrat ic society in pursuit of one or more of the 
legitimate aims listed in Article 8 para  2 of the European Convention on Human Rights 
(ECHR). The measure could also entail negative effects on academic freedom. 
Legal effects: The EU common procedure may require a legislative instrument at EU 
level. 
Assessment of EU-added value  
The EU has a strong role to play in this ar ea, as it is responsible for overall migration 
policy. There are known cases of attempts to in filtrate universities and research institutes. 
Not all Member States apply background ch ecks which would enable at least the 
identification of suspicious applications - this is a pan-European problem justifying common action in this field. 
Action B.04 (Strengthening personnel security) 
Member States should ensure that Each Memb er State and/or organisation has a secure 
registry of personnel having access to or info rmation on biological agents and toxins on 
the EU biosecurity list (along the whole ch ain of production, storag e, distribution and 
use). Law enforcement should have access to such a registry.  
Achievement of (relevant) policy objectives  
1.3 To reduce, where 
possible, judicial, legal, jurisdictional barriers and constraints 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.2 To improve 
monitoring and control over CBRN materials  
1 3 3 
 
EN 37   EN Maintaining a registry of persons worki ng, handing and/or having access to biological 
agents and toxins in diagnostic  facilities is beneficial as  it would speed up any control 
activity in case of a suspicious activity or behaviour. There would be benefit in agreeing 
on some common elements to be included in the registry, or the overall format of the 
latter, at EU level. 
Assessment of (relevant) effects  
Economic impacts: Some Member States already have re gistries in place. For those that 
will have to set this up, the financial cost s will strongly depend on the length of the EU 
biosecurity list. If all res earchers, visiting staff and st udents who might have access to 
some material will fall under the scope of th is register, this would include more than 
10,000 individuals in Europe. 
Financial costs Economic impacts 
2 0 
Social impacts: The action could have a negative eff ect on private life and personal data 
protection, especially if a high number of people are affected a nd if access to the registry 
within the law-enforcement authorities woul d not be properly limited. On the other hand, 
the action increases security, and reduces th e possibility of unau thorised access to high-
risk CBRN materials, and t hus crime and terrorism. 
Fundamental rights: The Protection of personal data could be affected if personal 
information is not sufficiently protected and secured, and if access to  the registry by the 
law-enforcement authorities would not be properly limited. The personal data protection 
principles apply to all pro cessing of personal data by an y person whose activities are 
governed by Community law. Furthermore, a ny collection of, or access to personal data 
by officials of the State about an individual must be duly justified and in line with the 
law. Only interferences which are in accordan ce with law and necessary in a democratic 
society in pursuit of one or more of the legitimate aims listed in Article 8 para  2 of the 
ECHR. 
Assessment of EU-added value  
The EU has a role to play in ensuring that security standards are harmonised in the 
Member States, to avoid that terrorists or criminals concentrate on countries with less 
developed approaches. A registry would be pa rt of the overall ‘package’ to improve the 
overall security level playing field. 
Action H.18 (Strengthen and prioritise research) 
The Member States and the Commission shoul d encourage funding organisations (be it 
public or private) to take security asp ects of proposed research projects and other 
publications into account, as well as the suitability of th e funds receiver (from both a 
safety and a security perspective) to work on the research the rece iver is proposing. Best 
 
EN 38   EN practices of funding organisa tions should be identified an d exchanged across Member 
States. 
Achievement of (relevant) policy objectives  
1.5 To strengthen and 
prioritise research on CBRN 1.6 To increase awareness 
of security implications in funding decisions 1.7 To increase awareness 
of security aspects in publishing 
2 4 2 
Assessment of (relevant) effects  
Economic impacts: It is difficult to estimate th e costs of this action, as funding 
organisations could be encour aged through several actions su ch as the pr eparation of 
guidance material, checklists, detailed inform ation on security issues, training, events, 
etc. Overall, costs are expected to be low.  Preparing guidance material should cost less 
than 200,000 EUR with translations. However, th e action could have negative effects in a 
scenario where funding for research presen ting security risks would be reduced, for 
example because, as a result of additional checks required on the status and security 
arrangements of funding app licants, funding orga nisations would decide to finance 
projects outside the EU. This could affect  the overall competitiveness of the EU. 
Financial costs Economic impacts 
1 0 (- if funding would be reduced) 
Social impacts:  This action may, if funding applican ts presenting secu rity risks would 
have limited chances of receiving grants, ha rm equality of treatment and opportunities. 
On the other hand, it could contribute to increas ed security and be a step forward towards 
reducing the possibility of crime an d terrorism involving CBRN materials. 
Assessment of EU-added value  
There is scope for EU action in  this area, as a common mess age would raise awareness in 
all Member States as well as at the international level. 
Action B.06a (Strengthen and prioritise research) 
All scientific publications should be assessed by peer reviewers be fore their publication 
Achievement of (relevant) policy objectives  
1.6 To increase awaren ess of security 
implications in funding decisions 1.7 To increase awaren ess of security 
aspects in publishing 
2 3 
Assessment of relevant effects  
 
EN 39   EN Economic impacts : the action might have a negative imp act on research. If researchers do 
not have assurances on the publ ication of their studies, thei r interest in research might 
decrease (or be undertaken outside the EU). This could influence the competitiveness of the EU. Appropriate education and training of all peer reviewers on security issues seem 
to be unfeasible, given the high numbers of re searchers. Also, many of the peer reviewers 
are not citizens of the EU, which means that  the EU's legislative powers would be very 
limited. 
Financial costs Economic impacts 
1 - 
Effects on fundamental rights : This kind of peer review might raise concerns as to its 
compatibility with fundamental rights such  as freedom of science and speech by 
preventing researchers to publish their findings.  
 
EN 40   EN Assessment of EU added value  
The rationale for EU intervention is weak: the role of the EU would not be to interfere 
with freedom of expression and with nationa l arrangements in place in relation to the 
publication of research. Furthermore, there might be a detrimental long-term effect on research and public health.  
Due to the above reasons, this ac tion is considered unfeasible.  
Action B.06b (Strengthen and prioritise research) 
Publications of studies with sensitive biological dual-use res earch in two versions (public 
and restricted version) 
Achievement of (relevant) policy objectives  
1.6 To increase awareness of security 
implications in funding decisions 1.7 To increase awareness of security 
aspects in publishing 
2 2 
Assessment of relevant effects  
Economic impacts : the costs of this action strongly  depend on its implementation. Setting 
up an EU body to assess which studies would require to be published in two versions is 
potentially very costly. The extra efforts re quired to publish two ve rsions also require 
additional inputs and hence cost s. It may significantly delay publications and would thus 
hinder the European research. 
Financial costs Economic impacts 
3 0 
Effects on fundamental rights : This action might also raise concerns as to its 
compatibility with fundamental rights, such as freedom of speech and access to information.  
Assessment of EU added value
 
The action could raise issues of subsidiari ty, as it would interf ere with national 
arrangements in place in relation to the pub lication of research. The action would also 
lead to increased inputs from  researchers to provide two different versions of their 
publications. 
As the action raises questions in relation to subsidiarity, and it has also received very 
little stakeholders' support, it  is considered unfeasible. 
 
EN 41   EN 5.2.1.  CBRN prevention 
Action H.20 (Develop EU lists of hi gh-risk CBRN materials and risk-based 
approaches to security) 
The Member States and the Commission shoul d establish and regularly update EU lists 
of high-risk chemical agents; biological agents and toxins (biosecurity list); and high-risk 
radioactive sources of sp ecial security concern. 
These lists should be developed based on a ri sk assessment analysis . This process should 
include the following steps: 
– Identifying and analysing re levant CBRN materials; 
– Assessing its potential for bei ng used for malicious purposes; 
– Selecting the most dangerous material in  terms of its potential for being used 
for malicious purposes;  
– Assessing its vulnerability in terms of theft/loss (ease of obtaining them); 
– Establishing possible preventive measures: physical / technical and 
administrative; 
– Carrying out a cost / benefit st udy on these possible measures.  
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.1 To prevent access to legitimately 
produced and used CBRN materials by terrorists or other criminals  
5 1 
The development of a common list would ensu re harmonisation at EU level. Member 
States should be offered the possibility to a dopt the list but add ma terials which are of 
specific national concern. The latter is particular  relevant with regard to biological agents 
and toxins, as their presence strongly depe nds on contextual, geographical and climatic 
differences of the EU27. 
The list would need ongoing updati ng. The criteria used for th e selection of the materials 
to be included would need to be agreed  between the Member States. The use of a 
common list would be particularly useful to improve detection and identification 
methodologies and tools, as research and pr ivate sector solutions could focus on the 
prioritised materials. It will also be highly im portant to ensure that the lists take account 
of recent developments, for example of the possibility of geneti c manipulation in the 
biosecurity list. 
Assessment of (relevant) effects
 
 
EN 42   EN Economic impacts: In terms of financial costs, several meetings between the 
Commission, the Member States and relevant Agencies would be required to take the 
process forward and prepare the lists. These could be facilitated by key experts in the 
field. Per meeting, around 15 days at 500 EUR would be required, totalling 7,500 EUR. 
Logistics for meetings: (e.g. travel, subsiste nce, conference rooms): would approximately 
amount to 1,000 EUR per person. When estima ting the participation of 40 persons per 
meeting, taking part in around 5 meetings, th is would amount to  200,000 EUR. Expert 
fees to support the proce ss (e.g. assessment of potential to be used for malicious 
purposes, vulnerability assessment, etc) may amount to around 100,000 EUR per type of 
material. Additional costs would be incurr ed for the cost-benefit study on possible 
preventive measures, which could add an additional 20 – 30,000 EUR per Member State. 
Financial costs Economic impacts 
1 0 
Legal effects: The common EU lists may require a legislative instrument setting out, for 
example, the assessment criteria for including materials on the list. 
Assessment of EU-added value  
There is a strong rationale for EU interventi on, as it would help to harmonise an area 
characterised by great national and international differences, thus ensuring an approach 
based on similar methods and criteria. Furthe rmore, identifying a number of high risk 
CBRN materials at EU level could certainly provide co mmon EU ground for balanced 
approach to activities at EU level and repr esent a cornerstone for the implementation of 
the entire Action plan. Broad av ailability of CBRN materials in the modern world means 
that it would not be possible to implement st rict security measures concerning all such 
materials. A certain prioritisation is need ed so that public authorities and private 
operators concentrate resour ces on securing on ly a certain group of high-risk CBRN 
materials. Such an approach would allow th e EU and the Member States to concentrate 
on those issues which are of highest concern. 
Action H.22 (Enhance the security of CBRN materials and facilities) 
The Member States and the Commission shoul d develop criteria on assessing security 
arrangements at high-risk CBRN  facilities. This should be done in the form of a good 
practice document. 
Achievement of (relevant) policy objectives  
2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or 
other criminals  2.2 To improve monitoring and 
control over CBRN materials  
4 2 
 
EN 43   EN Assessment of (relevant) effects  
Economic impacts: The action in itself would require lo w financial inputs, as it would 
mainly concern a mapping exercise, identifi cation of good practices and the preparation 
of a document. Based on sim ilar studies, the mapping exercise of existing criteria would 
amount to around 100,000 EUR per type of materi al. Additional costs would be required 
for the publication of the docum ent in all the languages of the EU. If the assessment 
criteria would become compulsory, the fina ncial implications may be high for some 
Member States and relevant i ndustry to ensure compliance. 
 
EN 44   EN Financial costs Economic impacts 
1 0 (- if the assessment criteria would 
become compulsory) 
Social impacts : Developing criteria on assessing s ecurity arrangements at high-risk 
CBRN facilities would positively affect the secu rity of CBRN facilities as it might help 
to identify gaps in exis ting protection measures. 
Assessment of EU-added value  
The rationale for EU interv ention is strong, as evidence suggest s that security 
arrangements in some facilities may be in sufficient to ensure protection against the 
malicious intent to obtain CBRN materials.  It would thus be important to further 
encourage harmonisation of the extent to  which Member States assess security 
arrangements in their facilities.  
Action C.07 (Enhance the security of CBRN materials and facilities) 
The Member States should ensure that security  plans/security management systems are in 
place in high-risk chemical facilities. The security plans should provide for graduated 
levels of security based on the existing threat  level. Member State authorities should be 
involved in assessing whethe r these security pl ans satisfy the necessary level of 
protection requirements. 
Achievement of (relevant) policy objectives  
2.1 To prevent access to legitimately 
produced and used CBRN materials by terrorists or other criminals  2.2 To improve monitoring and 
control over CBRN materials  
4 3 
Improving the security plans a nd security management syst ems in facilities handling 
high-risk chemicals, involving Member State authorities in checking whether such plans 
satisfy the necessary level of protection requirements, is bene ficial, as it would ensure 
that any potential threat is ta ken into account. The option is in line with the European 
Programme for Critical Infrastructure Protect ion, which aims to improve the protection 
of critical infrastructure in the EU th rough a package of measures including the 
identification and designation of European critical infrastructure and accompanying 
financial measures. This addresses critical infr astructure which, if di srupted or destroyed, 
would significantly affect two or more Member States.  
The option would also require  close links to the Seveso  II Directive on the major-
accident hazards of certain indus trial activities, which looks at  protection of facilities and 
plans from a safety perspective. The option would benefit from ac tion in the field of 
developing criteria for assessing security ar rangements in CBRN facilities and exchanges 
of good practices, as put forward under H.22. 
 
EN 45   EN Assessment of (relevant) effects  
Economic impacts: The financial costs of this action are very high, given the number of 
chemical plants that could be affected which would have to establis h or further elaborate 
their security plans and management systems, in particular in Member States with less 
advanced approaches in place. To mitigate th is, it would be useful if more developed 
Member States would provide assistance, advi ce and expertise. High costs would also be 
incurred by national authorities to verify th e compliance of these plans and systems with 
protection requirements. It is  likely that such costs will have economic impacts, as 
chemical plants could increase their prices to  cover these additional costs. Small facilities 
in particular may not be able to cope with such additional costs. There is a potential for 
the action to affect EU competitivene ss and to lead to market distortion. 
Financial costs Economic impacts 
3 - 
Legal effects : The action may require legislation which goes beyond the Seveso II 
Directive, as it would need to cover specific security concerns. 
Assessment of EU-added value  
The action may raise issues of  subsidiarity and proportionali ty, as security plans and 
management systems are a national responsibi lity of owners, operato rs and authorities. 
However, insufficient security plans and manage ment systems could lead to thefts, losses 
and incidents which could affect other Member States and are therefore a European concern. 
Action C.09a (Enhance the security of CBRN materials and facilities) 
The Commission should investigate gaps with regard to the delivery documentation 
mechanism established under the Responsible Care programme.32 
                                                 
32 The Responsible Care programme  is an (voluntary) initiative of the chemical industry which 
addresses issues such as health, safety and e nvironmental performance, and communication with 
stakeholders. As part of the programme, par ticipating chemical comp anies are obliged to 
document all their deliveries. The Responsible Care programme is an initiative of the chemical 
industry which addresses issues such as hea lth, safety and environmental performance, and 
communication with stakeholders about products and processes 
 
EN 46   EN Achievement of (relevant) policy objectives  
2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.2 To improve 
monitoring and control over CBRN materials  2.3 To improve overall 
awareness of the potential dangers and risks, contributing to a high 'security culture' 
1 2 1 
 
EN 47   EN Assessment of relevant effects  
Economic impacts : whilst the costs for a similar investigation would be relatively low, 
any changes proposed to the programme coul d require additional investments by the 
companies that are participating in the Res ponsible Care Programme. As a result of this 
action, participants may also de cide to leave the programme. 
Financial costs Economic impacts 
1 - 
Assessment of EU added value  
The rationale for EU intervention is rather low. The investigation of the Responsible 
Care programme would not be highly rele vant, given that the programme does not 
include all relevant stakeholde rs. In addition, if the investig ation would show a need for 
changes to the programme, the Commission coul d not ‘enforce’ such changes. Several 
stakeholders doubted the useful ness of a similar investiga tion. The action al so received 
very little support from relevant stakehol ders and is thus considered unfeasible. 
Action C.10 (Enhance the security of CBRN materials and facilities) 
The Member States and the Commission s hould develop a high level approach to 
chemical facility security which identifies ke y objectives and steps to be taken in order to 
increase security, based on nati onal risk assessment approaches. 
Achievement of (relevant) policy objectives  
2.1 To prevent access to legitimately 
produced and used CBRN materials by terrorists or other criminals  2.2 To improve monitoring and 
control over CBRN materials  
3 3 
Assessment of (relevant) effects  
Economic impacts: The financial implications of devel oping an EU high level approach 
are difficult to estimate without more detailed  information as to wh at kind of activities 
this would include. As a minimum, Member  States and the Comm ission are likely to 
incur costs for meetings to agree on the comm on objectives and steps.  Further costs could 
be incurred for the preparation of a do cument setting out the high level approach. 
Financial costs Economic impacts 
1 0 
 
EN 48   EN Social impacts : Developing a high level approach to the security arrangements of 
chemical facilities would positiv ely affect the security of CBRN facilities as it might help 
to identify gaps in existing prot ection and other safety measures. 
Legal effects : The action may require a legislative instrument, or an EU recommendation 
or communication to set out  the high level approach. 
Assessment of EU-added value  
The action may raise issues of subsidiarity  and proportionality, as  chemical facility 
security is a national responsibility of ow ners, operators and au thorities. However, 
insufficient facility security could lead to thefts, losses and incidents which could affect 
other Member States and are therefore a European concern. 
Action B.08 (Enhance the security of CBRN materials and facilities) 
The Member States should establish: 
– A secure registry of facilities posse ssing any of the biological agents and 
toxins on the EU biosecurity list within each Member State while allowing 
access to law enforcement;  
– A process to verify and if necessary to enhance security arrangements of 
facilities, including diagnos tic laboratories handli ng and possessing any of 
the biological agents and toxins  on the EU biosecurity list.  
– A mechanism within facilities storing biological agents and toxins on the EU 
biosecurity list to regularly review th e need of such biological agents and 
toxins while keeping a good r ecord of stored materials; 
Most Member States have an overview of re levant facilities but some do not have a 
centralised list of all relevant ones. Developi ng secure registries is beneficial and in 
particular would assist in enabling local la w enforcement and security officials to pay 
closer attention to facilitie s containing particularly haza rdous biological agents and 
toxins. The registries would en able countries to monitor such  facilities and to quickly 
follow-up any suspicious activity. The joint ex perience of the Member States could serve 
as a very useful basis for enhancing the s ecurity arrangements facilities. Whilst some 
Member States face less of an immediate secur ity risk, the concern is that terrorists or 
criminals might take advantage of that lower level of security to obtain biological agents 
for use against another Member State. Good record-keeping and regular checking of such 
substances is essential to enable their monitoring. For some Member States which do not have secure registries in place, their development may prove time consuming, costly and difficult. Access to the registries sh ould be clearly defined and limited.  
Achievement of (relevant) policy objectives
 
2.1 To prevent access to legitimately 
produced and used CBRN materials 2.2 To improve monitoring and 
control over CBRN materials  
 
EN 49   EN by terrorists or other criminals  
4 4 
Assessment of (relevant) effects  
Economic impacts: The action, in its entirety, is poten tially very costly especially for 
Member States which have less developed system s in place (for example, if they face less 
criminal or terrorist threats). Particularly resource-intensive activities relate to the development and maintenance of registri es (securing, updati ng, checking, etc), the 
creation of the mechanism and the developm ent of a process to verify and enhance 
security arrangements. The introduction of  the action could have negative economic 
impacts on some Member States who may refr ain from handling certa in biological agents 
and toxins. The financial costs and economic effects will strongly depend on the length 
of the EU biosecurity list. However, the number of facilities dealing with biological 
agents and toxins is relatively low and he nce the economic effects will also be of a 
smaller scale. This could make the investme nts required more acceptable and justifiable. 
Financial costs Economic impacts 
2 -  
Environmental impacts: Possible positive effects, if the action would lead to a reduction 
of facilities possessing and handling dange rous biological agents and toxins. 
Legal effects : The process to verify security arra ngements and the mechanism to review 
the need for such biological agents and t oxins may need to be supported by further 
legislation. 
Assessment of EU-added value  
The rationale for EU interv ention is strong, as evidence suggest s that security 
arrangements in some facilities may be in sufficient to ensure protection against the 
malicious intent to obtain agents and toxins . It would be important to further harmonise 
the security of facilities to ensure an equal level of protection across the EU.  
Action B.08a (Enhance the security of CBRN materials and facilities) 
The Member States should introduce the system  of accreditation of a specific and limited 
number of laboratories, health  institutions, and production es tablishments on the basis of 
compliance with minimum security standards. 
Achievement of (relevant) policy objectives  
2.1 To prevent access to legitimately 
produced and used CBRN materials by terrorists or other criminals  2.2 To improve monitoring and 
control over CBRN materials  
4 4 
 
EN 50   EN Assessment of relevant effects  
Economic impacts: There are relatively high costs a ssociated with accreditation in 
general. The action could have negative eff ects on industry in some Member States as 
some institutions and laboratories may no longer be allowed to handle biological 
substances or may decide not to handle th em as the accreditation (and complying with 
the minimum security standards) would be too costly. Setting out the legislative basis for 
accreditation, developing the criteria and proces ses and setting up the system would also 
need considerable time to be completed. 
 
EN 51   EN Financial costs Economic impacts 
3 - 
Assessment of EU added value  
The EU added value is rather low, as a num ber of Member States already have national 
licensing and authorisation procedures in place  which also include security standards. 
Stakeholders considered that the action w ould constitute an unnecessary duplication of 
efforts.  
Due to these reasons, the action is considered unfeasible. 
Action RN.03a (Enhance the security of CBRN materials and facilities) 
The Commission should bring toge ther relevant authorities from the Member States in 
order to identify good practices concerning the physical protection of various categories 
of sources. Based on this work, the Commission should develop a good practice 
guideline addressing such issues as:  
1. The responsibility of an au thority to assess the secur ity measures in place for 
various types sources;  
2. Linking the results of the above mentioned security assessment to the 
licensing/registration procedure;  
3. Creating varying levels of security measures adapted to the risk posed by 
particular radioactive sour ces, amounts of certain sour ces or combinations of 
sources. These security measures shoul d address inter alia: background checks 
for personnel, physical security meas ures and information security.  
Achievement of (relevant) policy objectives  
1.4 To improve personnel 
security 2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.2 To improve 
monitoring and control over CBRN materials  
3 3 1 
Assessment of relevant effects  
Economic impacts: The costs for developing a good pract ice guideline are low and would 
mainly relate to the identification and se lection of good practices, meetings between 
Member States, the preparation of the guideline and its dissemination. 
Financial costs Economic impacts 
 
EN 52   EN 1 0 
Assessment of EU added value  
The EU added value of this action would be low with a high potential for duplication of 
efforts, as the IAEA has alre ady developed a set of very useful guidelines on which any 
further work could be based. There are, in addi tion, some subsidiarity issues as it is up to 
the Member States to put in place arrangements for assessing the security of radiological 
and nuclear facilities and materials and to de termine whether these should be linked to 
licensing/registration procedures.  
Due to these factors and low stakeholder' s upport, the action is c onsidered unfeasible. 
Action RN.06 (Enhance control over CBRN substances) 
The Member States should launch recovery programmes for disuse d high-risk sources. 
The launch of a source recovery programme could be coupled with the creation of a 
source exchange system among the Member St ates, so that recovered sources can be 
made available to those states that need them (rather than manufacturing new sources). 
Achievement of (relevant) policy objectives  
2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or 
other criminals  2.2 To improve monitoring and 
control over CBRN materials  
3 4 
Evidence suggests that, even though  most Member States have registries in place of high-
risk sources, in some countries such regi stration is insufficiently controlled. Knowing 
where disused high-risk sources are, and in w hose possession, is essential to prevent their 
use for malicious purposes (the materials coul d potentially be used in a “dirty bomb”) 
and to ensure appropriate safety levels. Th ere have been cases of orphan sources as a 
result of bankruptcy of companies or due  to unexplained losses of equipment and 
material. Even when sources are not lost, but simply disused, it would be highly beneficial to recover them rather than leav ing them in a possibly insecure location or 
circumstances. The option envisages a recovery programme to be launched by the Member States, which would in particular benefit from an exchange system to allow recovered sources to be used by countries that  need them. It is important to take into 
account of existing initiatives in this area, e.g. as part of Council Directive 
2003/122/Euratom on the control of high-activit y sealed radioactive sources and orphan 
sources and IAEA guidance in this field. 
Assessment of (relevant) effects
 
Economic impacts: The action is potentially very costly . It is also likely that ‘poorer’ 
Member States, which are most likely to have such insecure materials, will have to incur 
 
EN 53   EN higher costs.  However, important financial gain s could be achieved through the 
development of the source exchange programme among Member States, which would allow for the sources to be used again, ra ther than manufacturing new sources. The 
exchange programme itself would require low financial investments, in relation to the 
establishment of a database or similar tool to  log on requests and av ailability, as well as 
costs for transport. 
Financial costs Economic impacts 
3 ++ 
Social impacts : The action would greatly improve public  health and safety, as the launch 
of recovery programmes would reduce the risk  of disused sources falling in the wrong 
hands and, in general, affecting the health of the population if opened or poorly sealed. 
Assessment of EU-added value  
The EU has a strong role in encouraging th e launch of recovery programmes, based on 
early Euratom agreements and legislation. Th e exchange programme would in particular 
require an EU-wide approach. 
Action RN.13 (Contribute to the development of a high security culture of staff) 
The Member States and the Commission should engage with research stakeholders to 
raise awareness of security issues and fac ilitate the exchange of good practices on dealing 
with security threats. Particular atte ntion should be given to background check 
requirements for visiting researchers/students. This work should lead to an increased 
security culture within the research sector. 
Achievement of (relevant) policy objectives  
1.4 To improve personnel 
security 1.6 To increase awareness 
of security implications in funding decisions 1.7 To increase awareness 
of security aspects in publishing 
3 2 4 
Assessment of (relevant) effects  
Economic impacts: The costs for identifying good pract ices would be low, involving a 
mapping study to identify good practices, their validation and organisi ng the exchanges. 
A study to identify good prac tices would amount to a pproximately 200,000 EUR. The 
costs for the dissemination and exchanges of  the good practices are more difficult to 
estimate, as this could be undertaken in many different ways, e.g. through events with 
relevant Member State authorities, by comp iling the good practices in an online forum or 
in a publication, etc. 
Financial costs Economic impacts 
 
EN 54   EN 1-2 -  
Social impacts: The action could negatively aff ect equality of treatment and 
opportunities, as well as non-discrimination if  third country nationals would need to 
undergo more rigid forms of screening. If the same level of stringent security checks could be applied to all researchers with access to high risk material, regardless of being 
from a Member State or a th ird country, this would negate  much of the concern over 
discrimination.  
Fundamental rights : similar to the social issues raised, the action could negatively affect 
the non-discrimination principle is the same level of security checks for everybody would 
not be ensured. The measure could also entail negative effects on academic freedom. 
Legal effects: The EU common procedure may requi re a legislative instrument. 
Assessment of EU-added value
 
The EU has a strong role to play in this ar ea, as it is responsible for overall migration 
policy. There are known cases of attempts to in filtrate universities and research institutes. 
Not all Member States apply background ch ecks which would enable at least the 
identification of suspicious applications - this is a pan-European problem justifying common action in this field. 
Action RN.13a (Contribute to the development of a high security culture of staff) 
The Commission should launch a study on the imp lementation in the EU Member States 
of the IAEA Code of Conduct on the Safety  and Security of Radioactive Sources. 
Achievement of (relevant) policy objectives  
1.4 To improve personnel security 2.3 To improve overall awareness of 
the potential dangers and risks, contributing to a high 'security culture' 
2 2 
Assessment of relevant effects  
Economic impacts: The costs for undertaking a study on the implementation of the IAEA 
guideline would be low, in the order of 200,000 euro. 
Financial costs Economic impacts 
1 0 
Assessment of EU added value  
 
EN 55   EN The rationale for EU intervention is weak . Stakeholders stressed that sufficient 
information was already available at this st age on the implementation of the IAEA Code 
of Conduct and that undertaking a study woul d thus not bring any added value.  
The action is therefore considered unfeasible. 
Action H.25 (Improve the identification and reporting of suspicious transactions) 
Member States and th e Commission should:  
– Identify and exchange good practices on the reporting of suspicious 
transactions in relation to CBRN materi als used by private and public entities 
(e.g. industry, medical sector, research). 
– Establish modalities for reporting loss or suspicious transactions while 
enhancing awareness of relevant stake holders about suspicious transactions 
and encourage stakeholders to report such transactions to law-enforcement 
authorities 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness of 
the potential dangers and risks, contributing to a high 'security culture' 
4 4 
Assessment of (relevant) effects  
Economic impacts: The costs of this action are medium. The identification and selection 
of good practices would require a mapping st udy in the approximate amount of 200.000 
EUR. 
Financial costs Economic impacts 
1 0 
Social impacts: The action could interfere with the righ t to private life and protection of 
personal data, depending on the specific personal  data that needs to be reported to law 
enforcement authorities, on the exact purpos es and how this information would be 
processed, and which safeguards for indivi duals are provided. Th e action could also 
increase the public perception of un-safet y. On the other hand, the action increases 
security, and improves the co ntrol over high-risk CBRN mate rials and thus reduces the 
possibility of thus crime and terrorism. Th e action could also contribute to raising 
standards related to job qualit y, as it would increase the acce ss of relevant personnel to 
continuous training. 
 
EN 56   EN Fundamental rights: Reporting losses or suspicious transactions might require the 
processing of personal data. The personal da ta protection principles apply to all 
processing of personal data by any person whose activities are governed by Community 
law. Furthermore, any collection of, or acce ss to personal data by officials of the State 
about an individual must be duly justified an d in line with the law. Only interferences 
which are in accordance with law and necessary in a democratic society in pursuit of one 
or more of the legitimate aims listed in Article 8 para  2 of the ECHR will be considered 
to be an acceptable limitation by the State of an individual’s Ar ticle 8 ECHR rights. 
Assessment of EU-added value  
There is great scope for EU action in this ar ea, as the EU could steer the identification 
and exchanges of good practices, as well as th e development of adequate modalities, thus 
ensuring a more harmonised approach. 
 
EN 57   EN Action H.26 (Improve the identification and reporting of susp icious transactions 
and behaviour) 
Member States and the Comm ission should develop guidelines for the industry, the 
medical sector and the research community containing criteria identifying the forms of 
behaviour which may give rise to suspici on. Member State authorities should provide 
guidance to stakeholders on what suspicious transactions are. 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness 
of the potential dangers and risks, contributing to a high 'security culture' 
3 3 
 
Assessment of (relevant) effects  
Economic impacts: The costs of this action are medi um. The development of guidelines 
would require a mapping of crit eria currently used in the Member States and their 
elaboration into an EU document. Member St ates would have to meet possibly several 
times to agree on the guidelines. It is estimated that  a mapping study would cost around 
100,000 EUR and that up to three meetings convening Member State representatives 
would represent an approximate amount of 90,000 EUR. However, it is not possible to 
estimate the costs for the guidance to be prov ided by Member State authorities, as this 
could be provided in a wide  variety of forms, e.g. a website, a handbook, an awareness 
campaign, training, etc. 
Financial costs Economic impacts 
2 0 
Social impacts: The action could also increase the pub lic perception of unsafety. It would 
be important to emphasise that the criteria concern suspicious behaviour in transactions, 
and not behaviour by colleagues or relativ es. On the other ha nd, the action could 
certainly contribute to raising security and possibly also to ra ising standards related to job 
quality, as it would increase the access of relevant personnel to continuous training. 
Assessment of EU-added value  
There is great scope for EU action in this ar ea, as the EU could st eer the development of 
common criteria, ensuring a more harmonised a pproach to what constitutes suspicious 
behaviour and transactions. 
 
EN 58   EN Action H.27 (Enhance the security of transport) 
The Member States and the Commission should  establish an ad-hoc committee of experts 
on transport security with regard to CBR N materials. This Committee should bring 
together experts from the transport sector, the security services and law enforcement 
authorities. The Committee should address the following issues: 
– Assess whether existing transport s ecurity rules fully cover all CBRN 
materials. 
– Identify and exchange good practices in  the Member States concerning the 
transport of high-risk CBRN materi als (e.g. limited qua ntities in one 
transport; or tracking systems). 
– Identify and exchange current good pr actices in terms of tracking CBRN 
materials. 
– Requirements for the development of tracking and tracing systems for the 
transport of CBRN materials. 
– Identify and exchange good practices  concerning the implementation of 
current ADR (and RID and ADN) requirements such as the development of 
security plans. 
– Identify security requirements for logistics enterprises. 
– Consider establishing a notification syst em for the international transport of 
CBRN materials contained in the CBRN lists (ide ntified under the risk-
management process). 
– Consider the feasibility a nd costs/benefits of introducing a requirement that 
only licensed transporters would be used  for the transport of specifically 
identified CBRN materials. These license d transporters would be obliged to 
follow agreed minimum security requirements. 
The work of the Committee should feed into  existing processes such as the UNECE Ad-
Hoc Working Group. 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness 
of the potential dangers and risks, contributing to a high 'security culture' 
4 4 
Assessment of (relevant) effects  
 
EN 59   EN Economic impacts: The costs of this action would be lo w, consisting of fees for expert 
inputs and facilitation and trav el expenses. Possibly addi tional procurement would be 
required for the feasibility and cost/benefits studies, the identification and exchanges of 
good practice and other analytical tasks. 
Financial costs Economic impacts 
1 0 
Assessment of EU-added value  
The Committee would be established at EU leve l and address issues of international and 
EU concern. It would enhance the development of a common EU position in international matters and help to further harmonise national approaches to transport security of CBRN materials, whilst encour aging peer learning at the same time. 
Action B.13 (Enhance the security of transport) 
The Commission and the Member States should initiate the creation of an EU capability 
and mechanism to rapidly and safely transpor t biological samples, in accordance with 
international regulations, with in the EU and into the EU. 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness 
of the potential dangers and risks, contributing to a high 'security culture' 
4 4 
Having an EU capability and a mechanism to rapidly and safely tr ansport biological 
samples would increase the overall EU capacity to deal with deliberately caused outbreaks. This would prove invaluable with regard to the identification of a particular biological agent, thus reducing the amount of  time before appropriate medical and other 
responses can be initiated. C onsideration would have to be  given to the appropriate 
security of such transport. 
The mechanism would need to be accompanie d by an extensive mapping of available 
laboratories and available carriers. Any transfer  of such samples, particularly of Category 
A biological agents such as anthrax, or i ndeed Category B, such as Q Fever, would 
require appropriately high levels of security to ensure safe transit. At the same time, consideration would also have to be given to  the fact that any la boratory receiving such 
samples would have to maintain an equally high level of security. At present, some 
countries experience great difficulties in organi sing transport, as some carriers refuse to 
handle dangerous substances.  
Assessment of (relevant) effects
 
 
EN 60   EN Economic impacts: The costs of this action would depend on its exact content. For 
example, several different activities coul d be included, such as the mapping of 
laboratories and their specific capacity to handle certain samples, the identification of appropriate carriers, in line with internati onal regulations, as well as agreements between 
the Member States on protocols and transpor t modalities. The acti on would bring some 
efficiency gains as some transport would be dealt with centra lly, based on the most 
relevant and closest laboratory. 
Financial costs Economic impacts 
1-3 + 
Environmental impacts : Possibly positive environmental effects, as the action would 
reduces the likelihood and scale of environmen tal risks, by increasing the safety and 
security of transport of dangerous CBRN  materials and make it more efficient. 
Legal effects: The establishment of a mechanism may require a legislative basis. 
Assessment of EU-added value  
There is a strong rationale for EU action in th is area, as an EU capability and mechanism 
would enable the identification of the closest,  most relevant laboratories and as the action 
would address a transport problem ex perienced by many Member States. 
Action C.20a (Enhance the security of transport) 
Based on a risk-management approach, each Member State should work towards 
eliminating the transport of cer tain high-risk chemicals. This can be done by encouraging 
and supporting the development of relevant ch emical manufacturing facilities at sites 
which require such dangerous chemicals (rath er than transporting them). Enhance links 
between law enforcement authorities a nd transporters of chemical agents. 
Achievement of (relevant) policy objectives  
2.1 To prevent access to 
legitimately produced and used CBRN materials by terrorists or other criminals  2.2 To improve monitoring and 
control over CBRN materials  
3 4 
Assessment of relevant effects  
Economic impacts : Creating similar facilities would re quire very substantial investments 
from both relevant Member States and indus try, which would have an extremely negative 
effect on economic development and competitiveness. Also, while users of high-risk chemicals are geographically dispersed, the quantities that each of them use may be 
relatively small. Furthermore, stakeholders  manufacturing dangerous substances may 
decide to move to third countries with less stringent requirements.  
 
EN 61   EN Financial costs Economic impacts 
3 -- 
Environmental impacts : The potential multiplication of plans manufacturing dangerous 
substances would have negative environmenta l effects and increase the risk of serious 
environmental damage in case of a leak or other incident. Assessment of EU added value  
The EU added value is very low and the act ion will raise significant proportionality and 
subsidiarity issues. Member States showed very little support as the action might imply 
negative consequences for national economise.  
The action is therefore c onsidered unfeasible.  
Action C.20b (Enhance the security of transport) 
The Commission and the Member States should establish an ad-hoc  committee of experts 
on transport security with regard to chemi cal materials. This Committee should bring 
together experts from the transport sector, the security services and law enforcement 
authorities. The Committee should address the following issues:  
– Assess whether existing transport security rules fully cover all high-risk 
chemicals. 
– Identify good practices in the Member States concerning the transport of 
high-risk CBRN substances (e.g. limite d quantities in one transport; or 
tracking systems). 
– Identify current good practices in te rms of tracking chemical agents. 
– Requirements for the development of tracking and tracing systems for the 
transport of high-risk chemicals.  
– Identify good practices concerning the implementation of current ADR (and 
RID and ADN) requirements such as the development of security plans.  
– Identify security requirements for logistics enterprises.  
– Consider establishing a notification syst em for the international transport of 
high-risk chemicals iden tified under the risk-management process mentioned 
in section 1.1.  
– Consider the feasibility a nd costs/benefits of introducing a requirement that 
only licensed transporters would be us ed for the transport of specifically 
identified high-risk chemicals. These licensed transporters  would be obliged 
to follow agreed minimum security requirements. 
 
EN 62   EN The work of the Committee should feed into  existing processes such as the UNECE Ad-
Hoc Working Group. 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness of 
the potential dangers and risks, contributing to a high 'security culture' 
3 3 
Assessment of relevant effects  
Economic impacts:  the costs of this action would be low, consisting of fees for expert 
inputs and facilitation and trav el expenses. Possibly addi tional procurement would be 
required for the feasibility and cost/benefits studies, the identification and exchanges of 
good practices and other analytical tasks. 
 
EN 63   EN Financial costs Economic impacts 
1 0 
Assessment of EU added value  
The Committee would be established at EU leve l and address issues of international and 
EU concern. It would enhance the developm ent of a common EU po sition and help to 
further harmonise national approaches to tr ansport. However, the exclusive focus on 
chemical substances only and not on all CBRN materials will lead to confusion and 
duplication of efforts.  
The action is therefore considered unfeasible. 
Action C.20c (Enhance the security of transport) 
The links between law enforcement authoritie s and transporters of chemical agents 
should be enhanced. 
Achievement of (relevant) policy objectives  
2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness 
of the potential dangers and risks, contributing to a high 'security culture' 
3 1 
Assessment of relevant effects  
Economic impacts:  the costs of this action would de pend on the arrangements in place at 
national level. Whilst some countries alre ady have good links in place, other Member 
States may have to invest in  enforcing such links. This c ould require some investments 
from both transporters and law enforcemen t, in terms of setting up communication 
protocols and tools, repo rting arrangements, etc. 
Financial costs Economic impacts 
1 0 
Assessment of EU added value  
The EU rationale for intervention is high, as the action would contribute to a more 
harmonised approach to transport security throughout the EU, whic h is highly necessary 
considering the many intra-Community movement s of chemical materials. However, the 
exclusive focus on chemical substances only and not on all CBRN materials will lead to 
confusion and duplication of efforts.  
 
EN 64   EN Because of the above reasons and potentially high cost for some stakeholders, the action 
is considered unfeasible. 
 
EN 65   EN Action H.32 (Improve information exchange) 
The Member States should ensure a high level of information exchange between relevant 
actors by having a clearly esta blished notificatio n mechanism which would allow anyone 
to inform the relevant authorities about a lo ss/theft of high-risk CBRN  materials or about 
a suspicious transaction. As  a minimum requirement, facili ty security managers should 
have the necessary contact information for relevant local law enforcement authorities. 
Achievement of (relevant) policy objectives  
1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 2.2 To improve 
monitoring and control over CBRN materials  2.3 To improve overall 
awareness of the potential dangers and risks, contributing to a high 'security culture' 
4 4 2 
Assessment of (relevant) effects  
Economic impacts: Depending on the exact content of this option, the costs involved 
could be high. Some Member St ates may have to set such notification mechanisms up, or 
substantially improve or merge existing ones. Additional investments could be required to facilitate reporting, such as awareness ra ising campaigns, the establishment of a toll-
free national number, etc. 
Financial costs Economic impacts 
1 0 
Social impacts: The option could also increase the pub lic perception of un-safety. On the 
other hand, a successful notifica tion mechanism could help to prevent serious harm to 
public health and security. 
Environmental effects:  The action could possibly have pos itive environmental effects, as 
it would reduce the likelihood and scale of environmental risks, by improving the 
information flow between relevant authoritie s on for example the transport of dangerous 
CBRN materials. 
Assessment of EU-added value  
Several notification mechanisms exist at inte rnational and na tional levels, but most focus 
on notification of (accidental) releases rather  than on thefts and losses. Encouraging the 
Member States to set up no tification mechanisms covering all CBRN material s, to report 
on thefts, losses and suspicious transactions  would be highly bene ficial, as it would 
contribute to establishing cl ear protocols across and enti re production and supply chain. 
This would strongly improve response capacity  and ensure a higher level playing field 
with regard to notification in the EU. Theref ore, there is scope to encourage the Member 
 
EN 66   EN States to deal with CBRN threats in a co mprehensive manner and to establish clear 
mechanisms to respond to losses, thefts and su spicious transactions, in particular given 
the potential cross-border effects. 
Action C.22 (Improve information Exchange) 
The Member States and the Commission should consider establishing an alert mechanism 
in order to quickly transfer security relate d information to security managers in which 
high-risk chemicals are present. 
Achievement of (relevant) policy objectives  
1.2 To raise awareness and 
increase knowledge and information sharing on CBRN 2.2 To improve monitoring and 
control over CBRN materials  
4 4 
Assessment of (relevant) effects  
Economic impacts: The establishment of an alert m echanism would re quire continuous 
monitoring, updating and ongoing a ssessments of whether and wh en facilities need to be 
contacted. It may also require  secured information channels  with a 24/7 functionality. 
Especially for Member States who do not have  similar mechanisms in place, the start up 
and maintenance costs could be substantial, given the high number of chemical plants 
that would have to be linked to the mechanism. 
Financial costs Economic impacts 
2-3 0 
Assessment of EU-added value  
The option should help security  facility managers to rece ive timely information from 
relevant authorities on security issues which may affect the chemical  facilities they work 
in. This would be very beneficial, as it w ould allow for precautionary measures to be 
taken, such as increased security controls or even an interruption of activity. The effective implementation of this option coul d be challenging, as it would require an 
extensive mapping of chemical facilities and their characteristics, as well as an ongoing monitoring process of which information shou ld be transferred to which facilities. 
Nevertheless, it is clear that there is scope to  encourage the Member States to deal with 
CBRN threats in a comprehensive matter, in particular given the potential cross-border effects.  
Action RN.16a (Improve information Exchange) 
The Commission should setup an EU Data base of Illicit Tra fficking Incidents 
Achievement of (relevant) policy objectives  
 
EN 67   EN 2.2 To improve monitoring and 
control over CBRN materials  2.3 To improve overall awareness of 
the potential dangers and risks, contributing to a high 'security culture' 
4 2 
Assessment of relevant effects  
Economic impacts: The action would require financial inputs in terms of the technical 
development of the database (ICT tools, secured system and access), its continuous and timely updating and ongoing quality cont rol of the information included.  
Financial costs Economic impacts 
2 0 
Assessment of EU added value  
The rationale for EU intervention is rather low considering that an international database 
already exists (IAEA's Illicit Trafficking Inci dents database). There would be more scope 
in improving the functioning of th e latter rather than creating a second database. Issues of 
data protection (i.e. of sensitive information) should also be addressed, as Member States 
may be reluctant to add too many de tails to the current database.  
Due to these factors and lack of stakeholders ' support, the action is considered unfeasible. 
5.2.2.  CBRN Detection 
Action H.34 (Establish a scenario-based / modelling approach to identifying work 
priorities in the detection field) 
The Member States should strengthen and support: 
– The exchange of methodologies  for developing scenarios; 
– Networking of detectors at national level (centralising the analysis of 
detection data); 
– The exchange of information and data regarding broader trends of what has 
been detected; 
– The exchange and coordination of information on exercises among the 
Member States and other st akeholders when relevant. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 3.2 To develop an EU approach 
 
EN 68   EN identification capacity and 
capability towards detection and identification 
4 4 
Assessment of (relevant) effects  
Economic impacts: The financial inputs required for the exchanges of methodologies, 
knowledge and information would be relativ ely low, and would concern mainly the 
coordination costs, costs for meetings, id entification of suita ble methodologies and 
possibly publication costs. In addition, these activities would l ead to cost-efficiencies in 
the longer term, as Member States would have  more targeted detec tion work priorities 
and as industry could better respond their specific needs. 
However, one element of this option could po tentially be costly, namely the networking 
of detectors at national level to centralise the analysis of detection data, as it would 
require the development of sophisticated hard ware and software which would be able to 
receive process and analyse high quantities of data in a very short time period.  
Financial costs Economic impacts 
1 (3 if networking of detectors is 
implemented) + 
Assessment of EU-added value  
The EU rationale for this option would be st rong, as it would ensure an overall higher 
level of detection capability and capacity, and enable Member States with less experience to learn from other countries with more  advanced and sophisticated approaches. 
Action B.14 (Establish a scenario-based / modelling approach to  identifying work 
priorities in the detection field) 
The Member States and the Commission shoul d develop detection models for different 
biological pathogens and toxins, considering distribution, possible v ectors, infectious 
dose and stability. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and capability 3.2 To develop an EU approach 
towards detection and identification 
4 4 
Assessment of (relevant) effects  
Economic impacts: The development of models can be very costly and time-consuming, 
depending on the number of biological agents to  be included in the models. However, by 
 
EN 69   EN sharing the work on modelling between the EU  Member States, impor tant cost-savings 
can be made.  
Financial costs Economic impacts 
3 0 
Assessment of EU-added value  
As to the development of models, each biol ogical agent has its ow n characteristics in 
terms of rapidity of spread, potential covera ge and duration of activ ity. It would therefore 
be very useful to develop specific models fo r each agent and ensure that these are made 
available at EU level, to enable all Member States to learn from these. Several Member 
States have good experience in this area, which should be co llected and shared. The EU 
would have an important role, given that it could contribute to the coordination of the 
modelling work, ensuring that Member States can learn from each other and apply a 
common approach to focusing the models. 
Action H.37 (Develop minimum detection standards) 
The Member States and the Commission s hould develop minimum detection standards 
based on relevant scenarios and threat asse ssments while building on existing work (e.g.: 
CEN). When developing such standardisati on activities, adequate engagement of the 
private sector should be ensured and le gal requirements for evidence considered. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and capability 3.2 To develop an EU approach 
towards detection and identification 
4 5 
Assessment of (relevant) effects  
Economic impacts : The process of developing mini mum detection standards can be 
undertaken at a relatively low cost. It involves, po ssibly, some financ ial costs to cover 
negotiation and publication, as well as some expert inputs to steer the work. In the longer 
term, important financial gains could be ma de. The private sector would only have to 
comply with a single set of EU standards ra ther than many specific  national ones. They 
would know, for example, the specific desi gn and performance criteria, test and 
calibration requirements, and operating instruction requirements. This will help them to focus their efforts and save resources. 
Financial costs Economic impacts 
1 ++ 
Assessment of EU-added value  
 
EN 70   EN Whilst there are clear benefits of an EU a pproach towards detection, from a quality and 
cost-effectiveness perspective, it needs to be stressed that the choice, purchasing and 
deployment of detection systems, technologies  and equipment is a national competence. 
Establishing minimum standards in this area would have to be based on the principle of 
voluntary negotiation and agreement. 
Action B.16 (Develop minimum detection standards) 
Member States and the Commission shoul d set requirements for the detection, 
identification and monitoring of pathogens and t oxins within a civilian security context at 
the EU level. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and capability 3.2 To develop an EU approach 
towards detection and identification 
4 4 
 
EN 71   EN Assessment of (relevant) effects  
Economic impacts : The action would require low se t-up costs, but meeting the EU 
minimum requirements might require substantia l investments from some Member States 
with less developed approaches. It would lead to important cost efficiencies on the longer 
term, as industry would be able to better ca ter detection needs a nd research would be 
better targeted and more relevant. 
Financial costs Economic impacts 
1 ++ 
Assessment of EU-added value  
Whilst there are clear benefits of an EU approach towards mini mum requirements for 
detection, identification and monitoring from a quality and cost-effectiveness 
perspective, as well as in the light of cr oss-border phenomena, the choice, purchasing and 
deployment of detection systems, technologies and equipment is a strictly national affair. 
Establishing minimum requirements in this area, if not through a process of voluntary 
negotiation and agreement, could raise issues of subsidiarity. 
Action H.38 (Establish trialling, te sting and certification schemes for CBRN 
detection in the EU) 
The Member States and the Commission should: 
– Map out and document the technical requi rements necessary for the detection 
of chemicals, according to the field of application of the devices. 
– Establish an EU wide certification scheme to evaluate whether detection 
systems and tools meet set requiremen ts relying on existing capabilities and 
facilities. 
– Establish an EU wide tes ting scheme for detection tools and systems to assess 
the performance and quality of solutions  relying on existing capabilities and 
facilities. 
– Establish an EU wide trialling sche me to evaluate the quality of both 
detection tools and systems in practical  field operations relying on existing 
capabilities and facilities.  
– Exchange good practices, approaches  to and methodologies on quality 
assurance in CBRN in Member States. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and 3.2 To develop an EU approach 
towards detection and 
 
EN 72   EN capability identification 
4 4 
A common certification scheme would impr ove the efficiency of validating and 
approving detection tools and me thodologies, as once a certain tool is validated in one 
country, it would automatically be approved in all 27 Member States. This would imply 
substantial cost savings. Prior to the creati on of a certification, it w ould be important to 
build on the experiences in the Member Stat es and to develop a scheme to which all 
countries are willing to commit.  
A common testing scheme would ensure ha rmonisation of methodologies and tools for 
detection, as all Member States would eff ectively have to follow the same criteria, 
approaches and possess tools with similar performance and of similar quality. An EU-
wide scheme would also be beneficial, as Member States could share testing data and 
pool testing costs. This could offset deve lopment costs and help stimulate research, 
innovations and improvements, thus contributin g to increased detec tion probability and 
increased prevention and intervention opportunities.  
EU wide trialling would enable Member Stat es to share information and data and would 
improve the overall effectiven ess and quality of detection. At present, Member States 
carry out trialling individuall y, hence a common scheme woul d in the long-term mean a 
cost-saving and help countries with fewer resources.  
Assessment of (relevant) effects  
Economic impacts : This action, in its entirety, is potenti ally very costly to set up and run. 
It could lead to increases in the price of detection systems and equipment. The 
development of an EU trialling system could in particular require substantial 
investments, especially when taking into account the natura l and geographical differences 
between the Member States. In  the longer term, the action c ould lead to important cost 
savings, if Member States would mutually  accept certification, te sting and trialling 
results. 
Financial costs Economic impacts 
3 ++ 
Environmental impacts:  Large-scale trialling, and to a lesser extent testing, could 
represent a certain risk to the environment,  if the necessary precautionary measures 
would not be taken into account. 
Legal effects : The EU schemes could require the deve lopment of legislation especially to 
ensure mutual recognition of results. 
Assessment of EU-added value  
There is a strong rationale for EU interven tion in this area, as common certification, 
testing and trialling could increase the overall  level and quality of detection across the 
 
EN 73   EN EU and encourage a more harmonised appr oach. However, ultimately the choice, 
purchasing and deployment of detection syst ems and equipment are a strictly national 
affair. Mapping and documenting different technical requirements for the detection of 
chemicals has a high added value, as it w ould lead to an EU overview and learning 
between Member States. 
Action B.18 (Identify good practices relat ed to detection of CBRN materials, 
awareness raising and training) 
Member States and the Co mmission should initiate: 
– The development of mobile dete ction, identification and sampling 
capabilities at the EU level to be undertaken by commerc ial enterprises, 
research institutions and universitie s, and support mobile bio-forensic 
capabilities; 
– The establishment and maintenance of a network of refere nce laboratories 
within the EU (if not yet done so). 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and capability 3.2 To develop an EU approach 
towards detection and identification 
4 4 
Having a mobile capability, part icularly if it becomes appa rent that an outbreak was 
caused deliberately, would prove invaluable in responding to, and at least initially 
identifying the use of a particular biologi cal agent, thus reduc ing the amount of time 
before appropriate medical and other responses  can be initiated a nd increasing the chance 
of finding forensic clues. Whilst having a mobile solution for sampling and initial 
detection could be very  useful in certain cases, furt her detection, identification and 
analyses could take place in the most appropr iate laboratories which are in some vicinity 
of the accident, as long as good transport is available. The action should therefore not negate the development of appropriate labor atory facilities. Consideration would also 
have to be given to the appropr iate security of such mobile  laboratories. Developing such 
capability at the EU leve l would ensure the centra lisation of information. 
Assessment of (relevant) effects
 
Economic impacts : The development of a network will  require some set-up and running 
costs which relate to the coordination of  information, contact details and possibly 
meetings between the laboratory representative s. A mobile detection capability, able to 
deal with all biological substances, is potentia lly very costly. Severa l industrial solutions 
currently exist, but th ese do not do not yet cover the full spectrum. 
Financial costs Economic impacts 
 
EN 74   EN 3 0 
Environmental impacts : Possibly positive impacts as the mobile unit may reduce 
transport needs and if the netw ork would assist in the identi fication of the closest most 
relevant reference laboratory. 
 
EN 75   EN Assessment of EU-added value  
There is a strong rationale for EU intervention in this area, as the network would enable 
an EU overview of laboratories and their capaci ties. The mobile unit could be deployable 
throughout the EU and address emergency situ ations. This would in particular help 
Member States with le ss detection capacity. 
Action B.20 (Improve the exchange of information) 
Members States and the Commission should support: 
– EU and national projects performing measurements of biological background 
at specific areas, and enhance cooper ation and information exchange among 
Member States on such projects; 
– Exchange good practices among Member States on cases and processes when 
a dangerous biological s ubstance is detected. 
Achievement of (relevant) policy objectives  
3.1 To improve detection and 
identification capacity and capability 3.2 To develop an EU approach 
towards detection and identification 
4 3 
Appropriate detection equipment at key locat ions, particularly when deployed covertly, 
allows the ability to check for biological agen ts and maintain security, while minimising 
any inconvenience or delays to  both the public and commerci al trade. The exchange of 
such knowledge and technology amongst Member St ates, if carefully c ontrolled to ensure 
the maintenance of security, would prove equall y beneficial. From a perspective of social 
unrest and privacy, the impact of detection tools and methodologies on civilians should 
be minimised, whilst maintaining an appropriate  level of security. This option could be 
considered in the light of relevant  scenarios and threat assessments. 
Assessment of (relevant) effects  
Economic impacts : The development of EU and national projects performing 
measurements of biological background at s ecurity relevant area s requires potentially 
high levels of funding. Relativel y lower levels of financial inputs would be required for 
the exchanges of best practices, in relati on to the identification of the good practices, 
their compilation and their ex change, for example through events or papers, etc. 
Financial costs Economic impacts 
3 0 
Social impacts: There is a remote possibility, dependi ng on the location of the 'security 
relevant areas', the measures could inhibit fr ee movement and /or targ et specific social 
 
EN 76   EN groups. On the other hand, the action would increase public security, and improve the 
chances of the detection of mate rial that could be used for cr iminal or terrorist purposes. 
 
EN 77   EN Assessment of EU-added value  
EU level projects performing m easurements of biological bac kground at security relevant 
areas and exchanges of good practices would increase overall security levels and 
harmonise approaches, national projects coul d, on the other hand, in crease fragmentation. 
5.2.3.  CBRN preparedness and response 
Action H.45 (Improve response plans) 
The Member States and the Commission s hould develop and conduc t regular exercises 
and training at all levels (n ational, European and intern ational), involving and testing 
cooperation of all relevant organisations, partic ularly of health, firs t responders, security 
and judicial authorities; involvement of pr ivate sector in such exercises should be 
foreseen. Possible criminal inve stigations and forensics should  be part of these regular 
exercises. The Commission should ensure coordi nation of relevant exercises at EU level. 
Achievement of (relevant) policy objectives  
1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 4.1 To improve response 
and emergency planning and protocols, also at the EU level 4.4 To increase the 
chances of finding and prosecuting terrorist and other criminals 
4 4 2 
Assessment of (relevant) effects  
Economic impacts : This action is potentially very costly, depending on the type of 
exercises and training to be provided and the level of EU  coordination required. Whilst 
some Member States already organise exerci ses and training, these may not cover the full 
CBRN spectrum or specifically targ et security issues (as oppose d to safety). In addition, 
the content of training for first respondents could be very  different from training to 
private sector stakeholders or  judicial authorities, thus  requiring the development of 
different courses. 
Financial costs Economic impacts 
3 0 
Social impacts:  Apart from contributing positively to increasing the security of citizens 
by raising the level of prepare dness of relevant personnel, t he action could also 
contribute to raising standards related to job quality, as it would increase the access of 
relevant personnel to conti nuous training and exercises. 
Assessment of EU-added value  
The EU has an important role to play in ensu ring that exercises and training are provided 
in all Member States, that they include some common elements and that they cover EU-
 
EN 78   EN wide or cross-border elements. This also ju stifies the proposal to assign a coordinating 
role to the Commission of  relevant exercises. 
 
EN 79   EN Action B.21 (Improve response plans) 
Member States and the Comm ission should constitute an EU  level working group to 
consider: 
– Better cooperation among relevant agen cies in crisis and consequence 
management, response and recovery ma nagement; it should develop a bio-
specific checklist of requirements fo r consequence management, response 
and recovery. 
– Good practices on responding to security  incidents involving the facilities 
possessing any of the biologi cal agents and toxins on the EU biosecurity list; 
Achievement of (relevant) policy objectives  
1.2 To raise awareness and increase 
knowledge and information sharing on CBRN 4.1 To improve response and 
emergency planning and protocols, also at the EU level 
3 4 
Assessment of (relevant) effects  
Economic impacts : The costs for setting up a work ing group and to ensure regular 
communication opportunities (meetings, virtual exchanges, etc) are low. For example, 
the set up and preparatory work: (e.g. backgr ound study, identification of experts, etc) 
would amount to around 200,000 EUR, the crea tion of a website / virtual forum would 
cost around 20,000 EUR and inputs to the develo pment of the bio-ch ecklist would also 
be around 20,000 EUR. Additional costs would need  to be set aside for meetings of the 
working group. For example, logistics for fo ur meetings per year of a group of 30 
persons: (e.g. travel, subs istence, conference rooms) : approximately 1,000 EUR per 
person, thus totalling 120,000 EUR. On the longer  term, cost efficiencies could occur due 
to a more targeted to consequence,  response and recovery management. 
Financial costs Economic impacts 
1 0 
Assessment of EU-added value  
The added value of Community action in this fi eld is to be considered, specifically as 
many of the elements proposed are alrea dy covered through more  general actions 
addressing all CBRN materials. Whilst biological agents and toxins have very specific 
features, there would still be scope in a ddressing CBRN as a w hole in consequence, 
response and recovery management  rather than singling it out,  thus adding an extra layer 
to response plans and other tools. 
Action RN.25a (Improve response plans) 
 
EN 80   EN Awareness should be raised among the public of  radiological hazards, radioactivity and 
its effects on human beings and on the envi ronment, the various t ypes of radiological 
emergencies and their consequences for the population and the environment. Information 
should also be provided on the emergency measur es envisaged to alert, protect and assist 
the population in the event of a radiological emergency as we ll as on action to be taken 
by the population in the event of a radiological emergency. 
Achievement of (relevant) policy objectives  
1.1 To increase effective 
international cooperation, coordination and dialogue on CBRN 1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 4.1 To improve 
response and emergency planning and protocols, also at the EU level 
4 2 3 
Assessment of relevant effects  
Economic impacts: The costs of the action are estimated  to be low to medium, depending 
on the scale and coverage of  the awareness raising activities (ranging from the 
preparation of printed folders and post ers to national tele vision campaigns). 
Financial costs Economic impacts 
1-2 0 
Social impacts : The action could have serious negative social effects. Informing the 
public about the possible dangers  in their day-to-day lives and direct envi ronment could 
create the perception of low security and l ead to unnecessary panic and suspicion. On the 
other hand, the action would contribute to increasing public security, and improving 
preparedness against the potential criminal or terrorist use of radioactive material. 
Assessment of EU added value  
The rationale for EU intervention is this case  is low, especially in view of potentially 
negative social effects. There is absolutely  no need to provide detailed information on 
emergency measures in every aspect of the CBRN area.  
As the action also received little stakeholde r support, it is co nsidered unfeasible. 
Action RN.25b (Improve response plans) 
Member States should develop plans on how to organise the dissemination of 
information in the event of a radiological emergency and determine the content of the 
information. In order to ensure that the general public takes the message seriously 
without exaggerating the scale of the hazard, the information should be credible and 
allow the general public to s ee that the emergency plans drawn up would be implemented 
in the event of a real emergency. 
 
EN 81   EN Achievement of (relevant) policy objectives  
1.1 To increase effective 
international cooperation, coordination and dialogue on CBRN 1.2 To raise awareness 
and increase knowledge and information sharing on CBRN 4.1 To improve 
response and emergency planning and protocols, also at the EU level 
4 2 3 
Assessment of relevant effects  
Economic impacts: The costs of the action are estimated to be low, however the 
dissemination of the information could re quire higher investments, depending on the 
modalities of its organisation. 
Financial costs Economic impacts 
1-2 0 
Social impacts : The action could have negative soci al effects, as it could create a 
perception of low security and lead to unn ecessary panic and suspicion. On the other 
hand, the action would contribute to in creasing public security, and improving 
preparedness against the potential criminal or terrorist use of radioactive material. 
Assessment of EU added value  
The option received very little stakeholder supp ort and raises some subsidiarity issues. It 
is in principle the responsibility of the Me mber States to define whether and how to 
inform the public based on nati onal experience and procedures.  
Due to these factors, the acti on is considered unfeasible.  
Action H.47 (Strengthen the EU’s countermeasure capacity) 
Each Member State should:  
– Assess the required amounts and types of medical countermeasures in case of 
a incident involving high-risk CBRN materials; 
– Assess the availability of hospital beds  and hospitals able to carry out the 
decontamination of victims, the ava ilability of medical and paramedical 
personnel, transport possibilities and of required countermeasures in the form 
of technical CBRN equipment.; 
– Assess the possibility of sharing medi cal counter-measures across borders in 
case of an incident. 
Achievement of (relevant) policy objectives  
 
EN 82   EN 4.3 To ensure ongoing information 
flows in case of CBRN emergencies 4.5 To enhance national and EU 
countermeasures and on-the-ground response capacity 
1 4 
Assessment of (relevant) effects  
Economic impacts : The costs for the assessments to be undertaken by the Member States 
are expected to be relatively low, as th e action would include mapping, analysis and 
reporting. Any additional steps, for example Member States increasing their vaccine stockpiling, would be very costly. For exampl e, the 2009 US Strategic National Stockpile 
(SNS), the main program for vaccine, medicat ion, and some other medical materials and 
equipment stockpiling has set aside USD 570 million for a total population of slightly 
more than 300 million people. When applying this to the estimated nearly 500 million persons living in the EU, the costs could am ount to nearly USD 1 billion or 700 million 
euro. 
Financial costs Economic impacts 
1 (3 in case of additional steps) 0 
Social impacts : The action would have th e potential to improve Public health and safety 
given that it could help to reduce deaths and injuries among citizens.  
Assessment of EU-added value  
The added value of Community action in this field is to be considered, as the action 
invites the Member States to undertake severa l assessments without sp ecifying the role of 
the EU or the possible next st eps following these assessments. 
Action B.22 (Strengthen the EU’s countermeasure) 
The Health Security Committee should consider: 
– The possibilities to a) establish ther apeutics and vaccine stockpiles towards 
the known threat of biological agents a nd toxins, and determine the necessary 
auxiliary medical supplies to stockpile (gloves, masks, syringes, etc.); b) 
establish a standby capacity  to produce therapeutics,  including vaccines, and 
c) establish sustained funding for a technology platform to secure 
countermeasures towards biological ag ents and toxins that are unknown 
today (public-private experts working group); 
– The possibilities to scale up the diagnos tic capacity in cr ises situations. 
Involvement of the private sector in the working group should be considered. 
– Ensuring a sufficient amount of medical  products to combat an eventual 
threat; 
 
EN 83   EN – Build an EU wide coordinated appro ach to access medical countermeasures 
allowing adequate protection of the EU  population, based on risk assessment. 
Achievement of (relevant) policy objectives  
4.2 To develop an EU approach 
towards response and emergency planning 4.5 To enhance national and EU 
countermeasures and on-the-ground response capacity 
2 4 
Assessment of (relevant) effects  
Economic impacts : The costs of this action would be low, as they would mainly concern 
the inputs by the Health Security Committee,  some reporting and travel and subsistence 
in case of meetings. The financial costs of any action resulting from the Committee’s work and accepted by the Member States ar e potentially huge, especially if it would 
involve ensuring an EU countermeasure capacity against all CBRN materials. 
Financial costs Economic impacts 
1 (3 for actions resulting from the 
Committee’s work) 0 
Social impacts:  The action would have the potential to  improve Public health and safety, 
given that as a result of the work of the Committee it could help to reduce deaths and injuries. 
Assessment of EU-added value
 
There is great value in e xploring an EU approach to wards medical countermeasure 
capacity, in particular if the assessments proposed under Action H.46 would confirm the 
need. An EU approach would also help Memb er States to share the potential burden. 
Action B.23 (Strengthen the EU’s countermeasure capacity) 
The Commission and Member States should c onsider the creation of mechanisms for 
rapid licensing procedures of drugs and va ccines in crisis situ ations and possible 
exemptions from licensing procedures, ta king existing work into consideration. 
Achievement of (relevant) policy objectives  
4.1 To improve response and 
emergency planning and protocols, also at the EU level 4.5 To enhance national and EU 
countermeasures and on-the-ground response capacity 
4 4 
Assessment of (relevant) effects  
 
EN 84   EN Economic impacts : The costs for setting up the mechanisms for rapid licensing and 
exemptions are relatively low and would ma inly be administrative. There could be 
negative economic effects on competition and the functioning of the internal market 
should the mechanism be activated, given th at certain pharmaceutical companies would 
be exempted from standard procedures a nd would be the sole producer of a drug or 
vaccine. 
Financial costs Economic impacts 
1 0 (- if the mechanism would be activated) 
Social impacts:  The action would have the potential to  improve Public health and safety, 
given that it could help to re duce deaths and injuries and incr ease the security of citizens. 
Legal effects : Additional legislation might be required to create the mechanisms for rapid 
licensing procedures. 
 
EN 85   EN Assessment of EU-added value  
The EU added value is strong: crisis situations will nearly always have cross-border 
consequences and hence require an EU mech anism, especially because some Member 
States will have a better capacity than othe rs to effectively produ ce the required medical 
products. 
Action H.49 (Improve domestic and int ernational information flows in case of 
CBRN emergencies) 
Member States should exchange inform ation on emergency plans regarding CBRN 
incidents, involving all relevant agencies. 
Achievement of (relevant) policy objectives  
4.1 To improve response and 
emergency planning and protocols, also at the EU level 4.4 To increase the chances of 
finding and prosecuting terrorist and other criminals  
4 1 
Assessment of (relevant) effects  
Economic impacts : The costs for the exchanges or info rmation are generally low and will 
depend on the type of exchanges, e.g. through briefings and meetings , online platforms, 
reporting, etc. 
Financial costs Economic impacts 
1 0 
Social impacts:  The action would have the potential to  improve Public health and safety, 
given that it could help to re duce deaths and injuries. It would also increase the security 
of citizens.  
Assessment of EU-added value  
Encouraging Member States to exchange information on emergency plans to enable peer 
learning would indeed provide  an EU-added value, it is  though worth mentioning that 
domestic exchanges within Member St ates are mainly a national affair. 
Action  R.27 (Improve domestic and internatio nal information flows in case of 
CBRN emergencies) 
The Member States and the Commission shoul d consider integrating and building upon 
existing platforms for international exchange  of information during nuclear emergency 
situations, as well as assessing their applicabil ity to all radiological and nuclear incidents 
 
EN 86   EN of concern (scenario-based). An effort s hould be made to assess the possibilities of 
streamlining alert messages going thr ough different rapid alert systems. 
 
EN 87   EN Achievement of (relevant) policy objectives  
4.1 To improve response and 
emergency planning and protocols, also at the EU level 4.3 To ensure ongoing 
information flows in case of CBRN emergencies  
4 4 
Assessment of (relevant) effects  
Economic impacts : The costs of reviewing existing pl atforms for international exchanges 
of information would be relatively low, as this would imply a mapping and possibly 
some discussions with relevant organisations  responsible on thei r scope and coverage. 
The effective streamlining of rapid alert sy stems, in terms of adapting, expanding and 
maintaining these, could require relativ ely higher investments, depending on the 
alterations that are to be made. 
Financial costs Economic impacts 
2 0 
Social impacts : The action would have the potential to  improve Public health and safety, 
given that it could help to re duce deaths and injuries. It would also increase the security 
of citizens.  
Assessment of EU-added value  
The EU rationale for this ac tion is to be considered. The platforms and systems under 
consideration are international and it may therefore not be possi ble for the EU to 
integrate or expand these without the explicit consent of the relevant international organisations and third countries participating. 
As a result of the above assessment, 14 act ions are considered unfeasible and will be 
excluded from the preferred policy option. 
6. PREFERRED POLICY OPTION (CBRN  ACTION PLAN) 
This section presents the main advantages a nd success factors of the preferred option, as 
well as a summary of its relevance, feasibility  and expected impacts.  Finally, it includes 
an assessment and considerations of proportionality and EU added value. 
Based on the screening and the detailed assessments presented in section 5, the preferred 
policy option includes a total of 133 actions, organised in to the four main strands 
(Actions applicable to prevention, detecti on and response; Prevention; Detection; and 
Preparedness and Response). A schema tic overview is presented below. 
 
EN 88   EN Due to the fact that the curre nt situation and differences be tween Member States is not 
completely clear at this st age, many of the proposed acti ons will require a mapping study, 
before its implementation starts. 
 
EN 89   EN Table 7: Actions by strand and type 
 Horizon
tal C B R/N Total 
Actions applicable to 
prevention, detection, and response 19 5 6 1 31
Prevention 13 17 7 21 58
Detection 10 1 7 2 20
Preparedness and 
response 15  3 6 24
Total 57 23 23 30 133
6.1. Summary of relevance, feasibility and expected impacts 
Table 8: Preferred policy option 
Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
1.1 To increase effective 
international cooperation, 
coordination and dialogue on 
CBRN 4 The preferred policy option will make a positive contribution towards increasing the effec tiveness of international 
cooperation, coordination a nd dialogue on CBRN. Several of the actions included in the Action Plan, across the 
various strands, would in particular, lead to: 
– increased mapping of existing international cooperati on and coordination mechanisms addressing CBRN issues, 
thus providing an opportunity to identify gaps, po ssible areas of duplicati on and new opportunities. 
– more focused coordination and coopera tion efforts, as the mapping of existing mechanisms will help to consider 
which are most relevant for the EU and the Member States; 
– increased cooperation with relevant agencies at international, EU and national levels; 
– improved identification and exchanges of good practices with international, Europ ean and national partners, 
enabling in particular Member States with less advanced  approaches and less capacity to learn from countries 
with more experience and expertise; 
– taking the first steps towards a common EU position on cer tain issues in international forums, as well as 
working towards the achievement of common EU objectiv es. This may still, however, be challenging as it 
would require the political commitment of the Member States; 
– improved communication with the public, through the dissemination of good practices with regard to 
communication strategies, the development of guidelin es for communication and their integration into 
emergency plans. 
The positive impacts will apply to all Member States, especi ally to those that so far have been less engaged in 
international coordination a nd coordination activity, or those with little national experience related to CBRN 
security and threats. 
Actions that would in particular contribute to this specific objective include actions H.2, H.2, H.3, H.4, C.1 and B.1, 
H.27 RN.22, H.40, H.44 and H.38. 
1.2 To raise awareness and 
increase knowledge and 
information sharing on CBRN 4 The preferred policy option would help to raise awar eness and increase knowledge and information sharing on 
CBRN through several actions, across the various strands, should be included in the Action Plan, such as those 
proposing actions to: 
 
EN 90   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
– map, identify and exchange good practices on security; 
– map existing international and EU legislative instrument s with a view to verifying whether these adequately 
cover terrorist or criminal acts related to CBRN materials; 
– develop inventories or libraries of re sources on CBRN materials, so that relevant actors can quickly have access 
to good-quality information; 
– establish an Early Warning System on CBRN-related inci dents as well as other ensuring other information 
flows, making sure that all relevant EU and national acto rs are informed of threats,  losses, thefts, etc enabling 
them to undertake timely action;. 
– training of various stake holder groups, including first responders, local  authorities, EOD e xperts, laboratory 
staff, facility managers and other employees, etc, to make them understand the potential dangers of CBRN 
materials and to improve their capac ity to prevent, identify and respond to  incidents involving CBRN materials. 
The positive effects would benefit all Member States, as a ll countries would benefit fr om greater information and 
knowledge sharing, in particular those with less know-how and experience. By making certain information available 
EU wide, the likely cross-border effects of CBRN acts could also be better pr evented, identified and responded to. 
Some of the actions may encounter some level of reluctan ce, as Member States are concerned about the sensitivity 
of the information and knowledge to be shared and the extent to which this can be adequately secured. 
Actions that would in particular contribute to this specif ic objective include actions H.23, H.24, C.19, B.11, RN.12, 
C.20, B.12, RN.13, H.25, H.26, H.39, H.41, RN.23 and H.44. 
1.3 To reduce, where possible, judicial, legal, jurisdictional 
barriers and constraints 3 The actions included in the preferred policy option woul d help to address some barriers and obstacles which 
currently inhibit European co mmon action in the area of CBRN: 
– reviewing penal legislation in the Member States with  a view to verifying whether these adequately cover 
terrorist or criminal acts related to CBRN materials; 
– explore possibilities to enforce the mutu al recognition of forensic evidence; 
– assess the possibility to enc ourage mutual recognition in the area of personnel vetting. 
Other actions included in the preferred policy option would also help to furthe r this objective, su ch as activity to: 
– increase cooperation with relevant agencies at international, EU and national levels; 
– improve identification and exchanges of good practices with international, European and national partners, 
enabling in particular Member States with less advanced  approaches and less capacity to learn from countries 
with more experience and expertise. 
Whether reduction of judicial, le gal and practical barriers and constraints can  be effectively attained heavily depends 
on the commitment of the Member States. However, severa l international and EU developments in this area have 
proven that there is an interest in at least harmonisi ng some elements. Member States would overall benefit from 
these actions. 
Actions that would in particular contribute to this  specific objective include actions H.11, H.19 and H.55 
1.4 To improve personnel 
security 4 Several actions included in the preferred policy option, across the various strands, would contribute to improving 
personnel security overall, for example through: 
– introducing common graduated criteria for background checks and vetting procedures, to make sure that the 
credentials of personnel having access to CBRN materi als throughout the supply chain are verified, thus 
reducing the possibility of crimin als and terrorists gaining access; 
– improved identification and exchanges of good practices in  the area of security ch ecks with international, 
European and national partners, enabling in particular Member States with less advanced approaches and less 
 
EN 91   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
capacity to learn from countries with more experience and expertise; 
– strengthened management structures in CBRN facilitie s, so that personnel are adequately and regularly 
appraised and monitored; 
– The establishment of regist ries of personnel having access to or info rmation on biological agents and toxins 
Other actions which will contribute to improved personnel security include: 
– The identification and exchanges of good practices, as well as the developm ent of minimum training 
requirements and guidelines for persons working w ith, having access to or handling CBRN materials. 
– Education and training of various st akeholder groups laborator y staff, facility managers and other employees, 
etc, to improve their capacity to  prevent, identify and respond to incidents involving CBRN materials. 
– The development of guidelines, codes of conduct and other voluntary means to increase the awareness of 
security issues of staff. 
The preferred policy option would improve the level of personnel security in all Member States, and in particular in 
those countries which may have less adva nced approaches and arrangements in place. It would also ensure a more 
harmonised approach towards personnel security at EU level, which would lead to greater preparedness and 
detection and response capacity. 
Actions that would in particular contri bute to this specific objective include ac tions H.9, H,10, C.2, B.2, C.3, B.3, 
H.12, H.13, C.4, B.4, B.5, H.23, H.24, C.19, B.11, RN.12 
1.5 To strengthen and prioritise research on CBRN 4 A number of actions included in the preferred policy option, across the various strands, would increase the 
effectiveness and relevance of research, by mapping exis ting research, identifying needs and launching new research 
on this basis. Actions that would be  particularly beneficial concern: 
– Mapping and sharing of research results and planned resear ch, thus enabling Member States to be informed as 
to what already exists and to encourage them to launch new research. 
– Increased research cooperation with international partne rs to enhance synergies and duplication of efforts. 
– Stimulating new research in specific CBRN areas, such as  the development of low-risk chemical alternatives, 
response and recovery from biological incidents, det ection and identification of radioactive sources, the 
potential psychological effects of CBRN  emergencies on the population, etc.  This research needs have been 
identified by the CBRN task for ce as particularly relevant. 
All Member States would greatly benefit from increased res earch efforts at the European level, in particular those 
that may not have sufficient resources available to laun ch research projects themselv es. The increased mapping and 
cooperation will strongly help to prio ritise research and select the most  relevant and urgent projects. 
Actions that would in particular contribute to this speci fic objective include actions H.14, H.15, H.16, , C.5, B.6, 
RN.1,  
1.6 To increase awareness of 
security implications in 
funding decisions 3 One action included in the preferred policy option would help  to increase awareness of th e security implications in 
funding decisions and scientific resear ch projects and activities. This would be  beneficial as knowledge of what the 
potential security aspects are can help funding organisa tions and other stakeholders  to, where necessary, take 
precautions. 
The action that would in particular contribute to this specific objective is H.18 
1.7 To increase awareness of 
security aspects in publishing 2 One action included in the preferred policy option may help  to increase awareness of the security implications of 
scientific publications, even though the need for this would be verified through a study. 
The action that would in particular contribute to this specific objective is H.17 
 
EN 92   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
2.1 To prevent access to 
legitimately produced and 
used CBRN materials by terrorists or other criminals  4 The preferred policy option comprises several actions, ma inly under the Prevention strand, aimed at reducing the 
number of persons having access to CBRN materials to those that really need  such access, to improve physical and 
administrative security arrangements of facilities and to reduce the ‘lethality’ of some materials. These will help to 
prevent access to legitimately produced a nd used CBRN materials, for example by: 
– developing EU lists of high-risk CBRN materials, base d on a risk-management analyses, to focus measures on 
substances of specific security concern; 
– enhancing the security of CBRN materials within f acilities, through the developm ent of security plans, 
communication mechanisms to transfer security related information and the establishment of registries of 
facilities; 
– focusing on ways to improve the assessment of secur ity arrangements in high-ri sk CBRN facilities, improving 
links to law enforcement authorities, improving licensi ng requirements and laboratory standards related to 
security; 
– encouraging the chemical industry to replace, where possible, high-risk ch emicals with suitable alternatives; 
– identification and exchanges of good practices in these areas. 
The actions would help the Member States to target thei r efforts to increase the security on the most relevant 
materials and facilities. They would also help to harmonis e the current national approaches to facility and material 
security, by working towards common requirements and sta ndards. Member States with less advanced approaches 
will be able to learn from those with more expertise and experience. A number of actions mainly consist of action to 
be taken at Member State level and their success would th erefore strongly depend on their national willingness and 
commitment. 
Actions that would in particular contribute to this specifi c objective include actions H.20, H.21, C.6, B.7, RN.2, C.7, 
B.8, RN.3, H.22, C.8, B.9, RN.4, C.9, B.10, C.10, C.11.C.12, C.13 and C.14. 
2.2 To improve monitoring 
and control over CBRN 
materials  4 The preferred policy option includes a number of ac tions, mainly under the Prevention strand, which would 
contribute to improved monitoring and control over CBRN materials (in par ticular chemical and radioactive 
materials, as these are most traded and transported), in particular in terms of accounti ng, information exchanges and 
reporting on threats, losses and other incidents, transport and import and export. Releva nt action proposed include: 
– increased compliance with internationa l obligations and use of existing monitoring and control mechanisms, in 
particular in the chemical area, as these already provide  valuable tools to restrict access and use by legitimate 
users only; 
– improved licensing, registration, delivery control to en sure that CBRN substances are appropriately recorded 
and monitored and to reduce the chances of  such materials being lost or stolen; 
– improved communication and informati on exchange on threat levels, thefts , losses and incidents, through the 
development of links to aut horities, notification mechanisms and communication channels; 
– enhanced transport of CBRN materials, through actions to  making transport more secure and better organised, 
and by setting. This also in cludes exploring ways to trace and track the transport of in particular chemical and 
radioactive substances, based on national experiences or  similar approaches in other EU areas. This also 
includes specific attention to the import / export regime of radioactive sources; 
– increased focus on high-risk radioactive sources, through the exchange of good practices, improved 
identification and detection and a source recovery programme combined with a source exchange system. 
The actions would encourage Member States to increase their current monitoring and control mechanisms and to 
reduce the risks that CBRN materials fall into the wrong ha nds. The actions would also help to harmonise the 
current national approaches, by promoting good practices a nd exploring the adoption of international or EU tools, 
standards and requirements. A number of actions mainly c onsist of action to be taken at Member State level and 
their success would therefore strongly depend on their nationa l willingness and commitment. 
Actions that would in particular contribute to this spec ific objective include actions C.15, RN.5, C.16, RN.6, C.17, 
 
EN 93   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
RN.7, C.18, RN.8, RN.9, RN.10, RN.11, H.30, H.31, H.32,  C.21, RN.16, C.22 and RN.17, RN.18, RN.19, RN.20, 
RN.21, RN.22. 
2.3 To improve overall awareness of the potential 
dangers and risks, contributing 
to a high 'security culture' 3 There are several actions, mainly under the Preventi on strand which would contribute towards a high ‘security 
culture’, with persons working with and having access to CBRN materials bei ng more aware of the potential dangers 
and risks and being more alert to suspicious transactions  and behaviour. The following actions are likely to have a 
particular positive impact: 
– the identification and exchanges of good practices in the area of security education and training, as well as 
awareness raining, including the development of guidelines, minimum training requirements, etc; 
– the identification and exchanges of good practices in the ar ea of suspicious transacti ons and behaviour, in terms 
of reporting and modalities for reporting; 
– the development of specific security training on radiol ogical and nuclear materials and for private sector 
security staff. 
The actions would encourage Member States to improve th eir current training and awareness-raising activities, as 
well as to place increased focus on suspicious transacti ons and behaviour, in terms of reporting and modalities for 
reporting. The actions would also help  to harmonise the current national a pproaches, by promoting good practices 
and exploring the adoption of internationa l or EU programmes and requirements.  
Actions that would in particular contribute to this specif ic objective include actions H.23, H.24, C.19, B.11, RN.12, 
C.20, B.12, RN.13, H.25, H.26.  
3.1 To improve detection and 
identification capacity and 
capability 4 Various actions, mainly in the Detection strand, would help to increase detection a nd identification capacity and 
capability, through a combination of measures focused on: 
– the identification and exchanges of good practices in th e area of awareness raising, training and exercises, 
exchanges of scenario and modelling approaches  and information between the Member States; 
– improving communication and informa tion exchanges between the Member States, public and private 
stakeholders as well as networking of laboratories and equipment / systems; 
The actions would stimulate Member States to improve thei r current efforts in the field of detection by promoting 
good practices and exploring improved communication with the detection suppliers and the military sector. This 
would benefit the capacities and capabilities of Member States ove rall, as the area to be c overed by detection is very 
wide, as well as enable Member States with less a dvanced approaches to learn from their peers.  
Actions that would in particular contribute to this spec ific objective include actions H.34, B.14, B.16, H.39, H.40, 
H.41, C.23, B.20, RN.24. 
3.2 To develop an EU approach towards detection and identification 5 Several actions, mainly in the Detection strand, woul d promote the development of an EU approach towards 
detection and identification, in  particular with regard to: 
– joint work on scenarios, in terms of EU level modelling and exchange of informati on, taking into account the 
likely cross-border effects of events; 
– minimum detection standards based on the scenario-building activities; 
– the establishment of EU trialling, testing and cer tification schemes, as well as mobile capacity; 
– the development of EU guidance and information, in  the shape of handbooks, training and networking. 
The actions would enable some great economies of scale as well as improve the links between the supply and the 
demand side of detection systems a nd technologies. It would also help to increase detection capacities and 
capabilities in the Member States to a level playing field.  
Actions that would in particular contribute to this specific objective include actions H.33, H.35, H.37, B.15, H.38, 
 
EN 94   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
B.17, H.39, B.18, RN.23, B.19 
4.1 To improve response and 
emergency planning and 
protocols, also at the EU level 4 Several actions which are part of the preferred policy opti on, in particular as part of the Preparedness and Response 
strand, will contribute to improving re sponse and emergency pla nning at both national and EU levels. The most 
relevant activities proposed include: 
– a mapping of existing state structures and identifica tion and exchanges of good practices concerning CBRN 
incidents, as well as increased focus on the integration of security issues  and in particular CBRN emergencies 
into response plans; 
– the development of training and exercises for all stak eholders involved in emer gency and response plans. 
The actions would improve overall respons e and emergency planning in the Member States, as well as enable those 
with less advanced approaches to learn from those countries  that have more experience in this field. A number of 
actions mainly consist of action to be  taken at Member State level and thei r success would therefore strongly depend 
on their national willingness and commitment. 
Actions that would in particular contribute to this spec ific objective include actions H.42, H.43, H.44, H.45, H.47, 
H.51 
4.2 To develop an EU approach towards response 
and emergency planning 4 The preferred policy option includes several actions, main ly within the Preparedness and Response strand, which 
will strengthen an EU-wide approach towards response and emergency planning, in  particular through the 
development of: 
– The coordination of training and exerci se at EU level to improve overall re sponse plans, as well as the provision 
of guidance to medical staff. 
– Exchanges of information on emergency plans, also ta king into account existing international platforms for 
nuclear emergency situations. 
– The development of an Emergency Response Guidebook,  based on existing guidance and information tools. 
The actions would also help to harmonise the current national approaches, by exploring the adoption of EU 
coordination measures and integrati on with international platforms. 
Actions that would in particular contribute to this specif ic objective include actions H.44, B.21, H.47, H.48, RN.27, 
H.50, H.51 
4.3 To ensure ongoing information flows in case of 
CBRN emergencies 4 There are several actions, especially in the Prep aredness and Response strand, which would increase the 
effectiveness of domestic and international inform ation flows in case of CBRN emergencies, such as: 
– increased exchanges of informati on between the Member States on their approaches to handling CBRN 
emergencies; 
– measures to improve information fl ows between public authorities and the supply chain, in particular with 
regard to radioactive materials, reviewing who should be involved and informed at what stage. 
Increased information flows, as well as the development of appropriate prot ocols for such flows, would strongly 
benefit the speed and quality of emergency responses. A number  of actions mainly consist of action to be taken at 
Member State level and their success would therefor e strongly depend on their national willingness and 
commitment. 
Actions that would in particular contribute to th is specific objective include actions RN.25, H.48 
4.4 To increase the chances of 
finding and prosecuting 
terrorist and other criminals 4 The preferred policy option includes various actions that  are part of the Preparedness and Response strand which 
will increase investigative and forens ic approaches, for example through: 
– encouraging Member States to increase forensic awaren ess of in particular first responders in a CBRN crime 
scene, thus ensuring that important evidence is not destroyed; 
 
EN 95   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
– studying potential problems in relation to CBRN contaminated materials and their transport; 
– increasing cooperation with relevant EU agencies to establish laboratory practices which can ensure that 
forensic evidence can be used in  courts, as well as exchanges of good practices in this area 
The quality of forensic evidence, as well as its possible admissibility in different Member State courts is essential in 
order to find and prosecute terrorist and other criminals.  The actions included will in particular help the Member 
States to identify their current problems a nd needs, as well as help Member States  with less expertise in this area to 
learn from those with more advanced approaches. 
Actions that would in particular contribute to this speci fic objective include actions H.53, H.54, H.55, and RN.30. 
4.5 To enhance national and 
EU countermeasure capacity 4 The preferred policy option includes several actions, main ly within the Preparedness and Response strand, which 
would increase national and EU counter measure capacity in terms of th erapeutics, vaccines, diagnostics, 
decontamination and overall medi cal capacity, for example by: 
– encouraging Member States to review their counterme asures and overall medical capacity in order to assess 
their possible needs in case of a CBRN incident, as well as  the exchange of good prac tices in this regard. This 
would also include assessing the possible sharing of me dical countermeasures and the development of rapid 
licensing mechanisms; 
– the involvement of the Health Security Committee to fu rther study the establishment of therapeutics and vaccine 
stockpiling, scaling up diagnostic capacity and EU co ordination in the field of medical countermeasures; 
– increasing the decontamination capacity of Member Stat es, through assessing the available means and capacity 
and studying further decontamin ation needs and procedures; 
– the improvement of modelling tools to verify further research needs 
The actions would also help to harmonise the current national approaches, by exploring the adoption an EU 
capacity.  
Actions that would in particular contribute to this spec ific objective include actions H.46, H.47, B.22, B.23, H.49, 
H.51, H.51 
Expected impacts 
Assessment Criteria Rating 
(from 
Low to 
High) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Financial and economic 
impacts Medium Most of the 133 actions included in the preferred policy option are expected to require low financial costs, to be 
incurred at EU and national levels by various stakeholde rs. Such costs would relate, for example, to studies, 
mapping activities, identification and disse mination of good practices, participati on in networks, meetings and other 
events.  
It is estimated that around 18 actions could potentially imply high financial costs. These re late, for example, to the 
funding of new research in all CBRN areas, the estab lishment of a comprehensive early warning system and 
capacity, the requirement for facilities to have security  plans/security management systems in place and the 
establishment of EU wide testing, tr ialling and certification schemes for detec tion systems and equipment. The exact 
costs are difficult to estimate at this stage. However, co stly actions will be subjects to separate feasibility studies. 
The actions that could potentially imply high economic costs are: H.08, H.10, C.03, C.05, B.06, RN.01, C.07, C.11, 
C.12, C.14, B.08, B.09, RN.03, RN.06, B.14, H.38, H.45, H.53. 
The expected costs of the implementati on of the Action plan are difficult to a ssess precisely, as these will depend on 
several factors, e.g. the length of the EU lists. It is wort h noting however that even if the aggregate costs of these 
actions could run into several tens of millions euro, this  would be divided between di fferent implementation levels 
(i.e. the Commission, EU agencies and 27 Member States) and spread over several years. Whilst some actions would 
start immediately, several would only be launched as from 2011. This will provide sufficient ti me to adequately plan 
 
EN 96   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
for such costs. In addition, the existing financial progra mmes, in particular the specific programme ‘Prevention, 
Preparedness and Consequence Management of Terrorism and other Security related risks’, as well as the specific 
programme "Prevention of and Fight against Crime" will be able to offer relevant  financial support for the 
implementation of the Action plan. These specific program mes will cover the period until December 2013. Up to 
100 million EUR will be made available to support the implementation of the CBRN package within these 
programmes. 
Attention is also drawn to the potential negative economic e ffects in terms of competitiveness or the internal market 
of a minor number of actions (not more  than 5) relating to rapid licensing, in creased screening of visiting staff from 
third countries, funding organisations ha ving to take security issues into  account in funding decisions and the 
development of secure registries of biological facilities.  Nevertheless, all 133 actions  included in the preferred 
policy option are consistent with horizontal EU strategies su ch as Sustainable Development Strategy or Strategy for 
Growth and Jobs. 
Social impacts Medium The majority of actions included in the preferred polic y option are not expected to have serious social effects. 
Clearly, however, the overall positive social effect of successfully countering CBRN threats is improved public 
health and safety, the security of citizens, in terms of a reduction of casualties and long-term health problems, 
reduced levels of fear and increased pe rception of safety, and fight against terrorism and crime. In this sense, the 
Action Plan as a whole could already positively contribute to such improved perception, if  promoted also to a wider 
public. 
Several actions, at least 20, would also have a positive effect on Governance, for example because they would 
enhance institutional cooperation and communication, improve  the organisation of information flows or help to 
establish protocols, etc. These would at the same time al so help to increase the trust between Member States. Among 
the actions with positive social impacts are; H.08, C.03,  H.12, H.13, B.04, H.18, RN.06, H.25, H.26, H.32, B.20, 
H.45, H.47, B.22, B.23. H.49. 
Around 10 of the actions could, potentially, have negative so cial impacts: B.03, H.12, H.13, B.04, H.18, RN.13, 
H.25, H.26, H.32 and B.20. These include increased screen ing of staff from third c ountries and requesting funding 
organisations to consider the security aspects of potential funding decisions. The possible negative effects relate to 
interferences with the fundamental rights to private life a nd to the protection of personal data. The content and actual 
implementation of the actions can however be such that these effects do not have to occur at all. 
Environmental impacts Very low The assessment of the preferred policy options does not consider indirect environmental effects for each proposed 
action. Nevertheless, it needs to be st ressed that the consequences of a poten tial CBRN incident c ould be devastating 
for the environment. Improving the prev ention, detection and response aspect  of potential CBRN incidents therefore 
has a significant positive environmental impact. 
5 of the actions included in the preferred policy option are expected to have an environmental impact: B.8, B.13. 
H.32, H.38, B.18 In two cases, such imp acts could be positive. This concerns a positive environmental impact if an 
action putting additional security requirements for laborator ies dealing with high-risk agents and toxins would 
reduce the number of laboratories handli ng such substances, and a positive effect  if an EU mechanism would ensure 
the rapid and safe transport of biological samples. A pote ntial negative environmental im pact was identified in the 
case of large-scale trialling, and to a lesser extent testi ng, of detection equipment a nd systems, which could have 
negative effects on the environment or br ing certain risks to the environment. 
Impacts on fundamental rights Low Potential issues in relation to fundamental rights have  been identified in around 5 actions: H.12, H.13, B.04, RN.13 
and H.25. Two of these actions concern measures to increase the security of visiting staff from third countries. These could, if not handled with care, negatively affect the non-discriminati on principle and academic freedom. 
Background checks and vetting requirement can negatively affect the freedom to  choose an occupation and the right 
to engage in work. At the same time, mutual recogniti on of vetting procedures through out the EU could facilitate 
taking up work in similar area s in other Member States. 
There are also 3 actions which deal with notifying and re porting suspicious transactions. These might represent an 
interference with the concerned person’s private life and his or her right to pr otection of personal data (Articles 8 
ECHR, Article 7 and 8 EUChFR) and must be duly justified a nd in line with the law. On ly interferences which are 
in accordance with law and necessa ry in a democratic society in pursuit of one  or more of the legitimate aims listed 
in Article 8 para. 2 ECHR will be considered to be an a cceptable limitation by the State of an individual’s Article 8 
ECHR. Provided that adequate protection of personal data is ensured, the c ontent and actual implementation of the 
actions can however be such that th ese effects do not occur at all.  
 
EN 97   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
Impacts on EU legislation Low Ten actions could, depending on the chosen modalities of implementation, requi re new EU legislation. For example, 
there could be a ‘single market’ rationale for adoption of EU wide detection standards and certification schemes (at 
present, industry incurs high administrative and compliance co sts for having to deal with different sets of standards 
and certification), as well as a security rationale (some Me mber States do not have any standards in place and in 
others these are insufficient, hence increasing the chances of CBRN material s passing a border or being smuggled 
into a key public building undetected). 
Some of the actions also work towards greater harmonisation, if not specifically of legisla tion, but of practices based 
on national legislation. For example, th ere are several actions which aim to increase mutual recognition or introduce 
common criteria for different procedures, such as for example background checks. Another action includes an 
analysis of the level of criminalisation of CBRN act, in order to identify whethe r such acts are, and are 
appropriately, penalised in the Member States. 
Actions that could potentially require legislation at EU le vel are: H.12, H.13, H.20, C.07, C.10, B.08, RN.13, B.13, 
H.38 and B.23. If decided to legislate in these cases, the legislation would be proposed and adopted in a time frame 
of a minimum of 5 years. Where this is the case, such actions will themselves have to be subject to Impact 
Assessments, including on the respect for fundamental rights,  in particular the right to personal data protection.  
Impacts on third countries Low Impact on third countries is very difficult to assess. There are two actions (H.13, RN.13) which propose to focus on 
the security of visiting staff from third countries. If th ese would lead to rigid bac kground checks or other vetting 
procedures, nationals from third countries  may decide not to visit EU countries. 
There are around 3 more actions which suggest improving control on imports and exports to third countries. 
Depending on the extent of such controls, it may become more expensive for third countries to import and export 
to/from EU Member States. Transport costs could also increase as a result of increased monitoring and control 
requirements. 
There are several actions which aim at improving the iden tification and reporting of suspicious transactions. Due 
care should be given that transactions requested from certai n third countries do not become suspicious by default, as 
again this could impact on commerce with these countries. 
The increased efforts in the area of detection, and in particular the development of minimum standards and the 
establishment of EU testing, trialling and certification, will possibly make the EU a more attractive region for trade 
in detection systems and equipment, al so from industry in third countries. 
Throughout the Action Plan, there is high focus on increasing security requirements in terms of personnel, facilities, 
response plans, etc. This may require high financial invest ments in some Member States, as well as from industry. 
On the other hand, multinational companies will benefit from  more harmonised security requirements across the EU, 
which could mean an improvement to the cu rrent 27 different sets of requirements.  
Feasibility 
Assessment Criteria  Rating 
(from 
Low to 
High) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Implementation feasibility Medium 
to High The implementation of the preferred policy option is considered to be overall f easible. The Action Plan is based on a 
thorough, long-term consultation exercise through expe rt groups, green papers, workshops and the CBRN Task 
Force. This has helped to gain momentum and to creat e overall consensus on the need  to address CBRN threats. 
The structure of the Action Plan is graduated, as it envisages different implementation peri ods for different 
individual actions. Whilst some may seem relatively am bitious, overall the timing seems appropriate. The Action 
Plan also sets out initial roles and responsibilities,  even though this could be further detailed. 
There is a risk that the sheer coverage of the Action Plan, which includes 133 individu al actions, could be very 
challenging. A multitude of activities acro ss the different strands and for differe nt types of CBRN will start and be 
undertaken simultaneously. It will be very important to  adequately monitor progress on all these different 
developments, in order to keep all re levant stakeholders invol ved and committed. There may be scope in producing 
regular monitoring reports, or developing an online tool were information on progress can be presented. Several 
stakeholders could be made responsible for providing re gular updates of activities within  their strand or group of 
 
EN 98   EN Assessment Criteria Rating 
(from 0 - 
5) Motivation of the rating and aspects of the po licy actions necessary to achieve the impact 
Relevance 
actions. 
Financial feasibility Medium 
to High As highlighted under the section discu ssing the financial and economic impacts,  the Preferred policy option will, as 
a whole, require some financial inputs  to start up and run the activities pla nned as part of the 133 actions. The 
implementation of the Action Plan, however,  appears to be feasible given that: 
– the costs would be shared at differe nt implementation levels (EU, Member  States, public and private actors); 
– the costs would be spread over several years; 
– there are important financial gain s to be made on the longer term 
– a significant part of the financing will be provided by the EU fi nancial programmes.  
Whilst some of the options could lead to  industry calculating increased costs into  their prices, it is expected that the 
financial gains will at least balance out these effects. 
Political feasibility High As mentioned earlier, the Action Plan is based on a thorough, long-term consultati on exercise between Member 
States, experts and private sector. The Green papers provide d a clear opportunity for Member States to present both 
their political views as well as concrete inputs on CBRN. 
The CBRN Task Force was by no means a forum to voice po litical views, as it had a strong practical focus on 
discussing current problems and needs without taking the political directions of individual countries into account. 
However, it was obvious during the Task Force meetings th at representatives were closely liaising with their 
national partners and that, on a regular ba sis, the views presented were indeed very similar to the political position of 
the country. 
In this sense, it is anticipated that  the Action Plan is politically feasible as a policy package. Due attention should 
however be given to some of the actions, in particular those that: 
– only ‘prescribe’ what Member States should do, with a low focus on stimulating a more EU common approach 
or harmonisation through exchanges of  good practices, guidance, etc. 
– actions for which subsidiarity issues have been iden tified (in around 6 cases), for example because certain 
approaches to facility security could well be undertaken solely at national level, of  because setting standards for 
detection are a strictly national affair. 
Due to the fact that the curre nt situation and differences be tween Member States is not 
completely clear at this st age, many of the proposed acti ons will require a mapping study, 
before its implementation starts. 
The following table presents a summarised de scription of the most  important actions 
(actions potentially involving high costs or new legislation) in terms of type of the 
instrument, implementation period and responsible actors. 
Table 9: Selected actions potentially requiring legislative action or involving high costs 
1) Actions applicable to CBRN prevention, detection and response 
 
EN 99   EN No. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
H.08 The Member States and the Commission should establish a law 
enforcement Early Warning System (EWS) for CBRN related 
incidents, taking account of exis ting systems and experiences and 
based on established common European lists of the most high-risk 
CBRN materials. Such a mechanism would include information on immediate threats, losses/thefts, and suspicious transactions and would 
in any case need to be accessible to the law enforcement authorities 
and relevant emergenc y responders of the Member States and to 
Europol. As a first step, the extension of the existing G6 system 
should be considered. The system should be without prejudice to the 
exchange of information on public health issues.  Exchange of 
information From 
2009 Commission X 
C.03 The Member States should organise regular exercises concerning the 
security of chemical facilities in orde r to test preparedness measures in 
place and raise awareness among staff.  Organisation 
of exercises From 
2010 Member 
States, 
Commission X 
B.03 Member States and the Commissi on should consider and develop:  
• Guidelines at the EU level for minimum training requirements for 
persons working with, having access to, or handling biological agents and toxins;  
• In conjunction with universities and professional associations, 
minimal requirements for academic training on biosafety, potential misuse of information and biological  agents and toxins and bio-ethics 
for undergraduate, graduate and postgraduate students.  Identification 
of best 
practices 2010-
2012 Member 
States, 
Commission, relevant stakeholders  
H.12 The Member States and the Commission should develop and introduce 
common graduated criteria for background checks and vetting 
requirements in relation to pers onnel having access to high-risk CBRN 
materials along the whole chain of production, storage, distribution 
and use. This should be done based on the establishment of a common European list of the most high-ri sk CBRN materials. These common 
criteria should be based on a graduate d approach. In the course of the 
recruitment process, the recruiting organisation should ensure that the credentials of the candidates are properly checked and assessed. The 
Commission should launch a study concerning existing background 
check procedures and requireme nts within the CBRN industry.  Potentially 
legislative From 
2011 Member 
States, 
Commission, EU agencies  
H.13 The Member States and the Commis sion should identify and exchange 
good practices on approaches to secu rity of non-EU visiting staff and 
students; Member States should aim at common procedures across the 
EU. Potentially 
legislative 2010-
2012 Member 
States, 
Commission  
B.04 Member States should ensure that Each Member State and/or 
organisation has a secure registry of personnel having access to or 
information on biological agents and toxins on the EU biosecurity list 
(along the whole chain of production, storage, distribution and use). 
Law enforcement should have access to such a registry.   2010-
2011 Member 
States  
 
EN 100   EN H.18 The Member States and the Commission should encourage funding 
organisations (be it public or private) to take security aspects of 
proposed research projects and othe r publications into account, as well 
as the suitability of the funds r eceiver (from both a safety and a 
security perspective) to work on the research the receiver is proposing. Best practices of funding organi sations should be identified and 
exchanged across Member States.  Funding of 
research  From 
2010 Member 
States, 
Commission, 
relevant 
stakeholders   
2) Prevention strand 
N
o. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
H.
20 The Member States and the Commission should establish and regularly 
update EU lists of:  • high-risk chemical agents;  
• biological agents and toxins (biosecurity list);  • high-risk radioactive sources;  of special security concern. 
 
These lists should be developed based on  a risk assessment analysis. This 
process should include the following steps: 
o Identifying and analysing relevant CBRN materials; 
o Assessing its potential for being used for malicious purposes; o Selecting the most dangerous material  in terms of its potential for being 
used for malicious purposes;  
o Assessing its vulnerability in terms of  theft/loss (ease of obtaining them);
o Establishing possible preventive measures: physical / technical and 
administrative; 
o Carrying out a cost / benefit study on these possible measures.  Potentiall
y legislativ
e From 
2010 Member 
States, Commiss
ion, EU 
agencies  
H.
22 The Member States and the Commission should develop criteria on 
assessing security arrangements at hi gh-risk CBRN facilities. This should 
be done in the form of a good practice document.  Identifica
tion of good 
practices 2011-
2015 Member 
States, Commiss
ion, EU 
agencies  
C.
07 The Member States should ensure that security plans/security management 
systems are in place in high-risk chemical facilities. The security plans 
should provide for graduate d levels of security based on the existing threat 
level. Member State authorities should be involved in assessing whether these security plans satis fy the necessary level of protection requirements.  Potentiall
y 
legislativ
e From 
2010 Member 
States X 
C.
10 The Member States and the Commission should develop a high level 
approach to chemical f acility security which iden tifies key objectives and 
steps to be taken in order to increase security, based on national risk 
assessment approaches.  Potentiall
y 
legislativ
e 2011-
2015 Member 
States, 
Commission, EU agencies  
B.
08  The Member States should establish:  
• A secure registry of facilities posse ssing any of the biological agents and 
toxins on the EU biosecurity list with in each Member State while allowing 
access to law enforcement;  
• A process to verify and if necessary  to enhance security arrangements of 
facilities, including diagnostic laborato ries handling and possessing any of 
the biological agents and toxins on the EU biosecurity list.  
• A mechanism within facilities storing biological agents and toxins on the 
EU biosecurity list to regularly review  the need of such biological agents 
and toxins while keeping a good record of stored materials;  Potentiall
y 
legislative 2010-
2014 Member 
States, 
Commiss
ion, 
relevant stakeholders X 
R
N.
06 The Member States should launch r ecovery programmes for disused high-
risk sources. The launch of a source recovery programme could be coupled 
with the creation of a source exchange system among the Member States, 
so that recovered sources can be made available to those states that need 
them (rather than manufacturing new sources).  Coordina
tion and 
informati
on 
exchange 2011-
2015 Member 
State, X 
R The Member States and the Commission should enga ge with research Potentiall From Member  
 
EN 101   EN N
o. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
N.
13 stakeholders to raise awareness of security issues and facilitate the 
exchange of good practices on dealing with security threats. Particular 
attention should be given to background check requirements for visiting 
researchers/students. This work should lead to an increased security culture 
within the research sector.  y 
legislative 2010 States, 
Commiss
ion, EU 
agencies 
H.
25 Member States and the Commission should:  
• identify and exchange good practices on the reporting of suspicious 
transactions in relation to CBRN materials used by private and public entities (e.g. industry, medical sector, research). 
• establish modalities for reporting loss or suspicious transactions while 
enhancing awareness of relevant stake holders about suspicious transactions 
and encourage stakeholders to report su ch transactions to law-enforcement 
authorities  Identifica
tion of 
best 
practices From 
2010 Member 
States, 
Commission, EU agencies  
H.
26 Member States and the Commission should develop guidelines for the 
industry, the medical sector and the research community containing criteria 
identifying the forms of behaviour which may give rise to suspicion. Member State authorities should provide guidance to stakeholders on what suspicious transactions are.  Identifica
tion of 
best practices, 
developi
ng guidelines From 
2010 Member 
States, 
Commission, EU agencies  
H.
27 The Member States and the Commissi on should establish an ad-hoc 
committee of experts on transport secur ity with regard to CBRN materials. 
This Committee should bring together experts from the transport sector, the 
security services and law enforcement authorities. The Committee should 
address the following issues:  • Assess whether existing transport s ecurity rules fully cover all CBRN 
materials. 
• Identify and exchange good practices  in the Member States concerning 
the transport of high-risk CBRN mate rials (e.g. limited quantities in one 
transport; or tracking systems). 
• Identify and exchange current good practices in terms of tracking CBRN 
materials. 
• Requirements for the development of tracking and tracing systems for the 
transport of CBRN materials.  • Identify and exchange good practices  concerning the implementation of 
current ADR (and RID and ADN) requirements such as the development of 
security plans.  • Identify security requirements for logistics enterprises.  
• Consider establishing a notification sy stem for the international transport 
of CBRN materials contained in the CBRN  lists (identified under the risk-
management process) • Consider the feasibility and costs/be nefits of introducing a requirement 
that only licensed transporters woul d be used for the transport of 
specifically identified CBRN materials.  These licensed transporters would 
be obliged to follow agreed minimum security requirements. 
The work of the Committee should feed into existing processes such as the 
UNECE Ad-Hoc Working Group.  Identifica
tion of 
best practices 2011-
2015 Member 
States, 
Commiss
ion, EU 
agencies  
B.
13 The Commission and the Member States should initiate the creation of an 
EU capability and mechanism to rapidly and safely transport biological samples, in accordance with internati onal regulations, within the EU and 
into the EU.  Potentiall
y legislativ
e 2010-
2014  Member 
States, Commiss
ion  
H.
32 The Member States should ensure a high level of information exchange 
between relevant actors by having a clearly established notification mechanism which would allow anyone to  inform the relevant authorities 
about a loss/theft of high-risk CBRN  materials or about a suspicious 
transaction. As a minimum requirement , facility security managers should 
have the necessary contact informati on for relevant local law enforcement 
authorities.  Informati
on 
exchange 2011-
2012 Member 
States, Commiss
ion, EU 
agencies  
 
EN 102   EN N
o. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
C.
22 The Member States and the Commission should consider establishing an 
alert mechanism in order to quickly tran sfer security rela ted information to 
security managers in facilities in wh ich high-risk chemicals are present.  Informati
on 
exchange 2011-
2012 Member 
States, 
Commiss
ion, EU 
agencies  
3) Detection strand 
No. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
H.34 The Member States should strengthen and support:  
• the exchange of methodologies for developing scenarios;  • networking of detectors at national level (centralising the analysis of 
detection data);  • the exchange of information and data regarding broader trends of 
what has been detected;  
• the exchange and coordination of  information on exercises among 
the Member States and other stakeholders when relevant.  Information 
exchange From 
2011 Member 
States, Commission, 
EU agencies  
B.14 The Member States and the Commission should develop detection 
models for different biological pathogens and toxins, considering 
distribution, possible vectors, infectious dose and stability.  Development 
of standards 2012-
2014 Member 
States, 
Commission  
H.37 The Member States and the Commission should develop minimum 
detection standards (including within the context of border 
monitoring) based on relevant scenarios and threat assessments while 
building on existing work (e.g.: CEN). When developing such standardisation activities, adequate engagement of the private sector 
should be ensured and legal requirements for evidence considered.  Minimum 
standards 
development 2012-
2014 Member 
States, 
Commission  
B.16 Member States and the Commission should set requirements for the 
detection, identification and mon itoring of pathogens and toxins 
within a civilian security context at the EU level  Development 
of standards 2012-
2014 Member 
States, 
Commission  
H.38 The Member States and the Commission should:  
• Map out and document the technical requirements necessary for the 
detection of CBRN materials, according to the field of application of 
the devices. 
• Establish an EU wide certification scheme to evaluate whether detection systems and tools meet se t requirements relying on existing 
capabilities and facilities. 
• Establish an EU wide testing sche me for detection tools and systems 
to assess the performance and quality of solutions relying on existing 
capabilities and facilities. 
• Establish an EU wide trialling scheme to evaluate the quality of both detection tools and systems in prac tical field operations relying on 
existing capabilities and facilities.  
• Exchange good practices, approaches to and methodologies on 
quality assurance in CBRN in Member States.  Potentially 
legislative From 
2011 Member 
States, 
Commission X 
B.18 Member States and the Commission should initiate: 
• The development of mobile det ection, identification and sampling 
capabilities at the EU level to be undertaken by commercial enterprises, research institutions and universities, and support mobile 
bio-forensic capabilities; Development 
of standards 2010-
2014 Member 
States, 
Commission  
 
EN 103   EN • The establishment and maintena nce of a network of reference 
laboratories within the EU (if not yet done so).  
B.20 Members States and the Commission should support: 
• EU and national projects performing measurements of biological 
background at specific areas, and enhance cooperation and information exchange among Member States on such projects; 
• Exchange good practices among Member States on cases and 
processes when a dangerous biological substance is detected.  Exchange of 
good 
practices From 
2010 Member 
States, 
Commission  
4) Preparedness and response strand  
No. Policy action Type of action Time of 
implementation Relevant actors Potentially costly 
H.45 The Member States and th e Commission should develop and 
conduct regular exercises and training at all levels (national, 
European and international), involvi ng and testing cooperation of all 
relevant organisations, particular ly of health, first responders, 
security and judicial authorities; involvement of private sector in 
such exercises should be foreseen . Possible criminal investigations 
and forensics should be part of these regular exercises. The Commission should ensure coordinati on of relevant exercises at EU 
level.  Organisation 
of exercises From 
2010 Member 
States, 
Commission, 
EU agencies X 
B.21 Member States and the Commission should constitute an EU level 
working group to consider:  
• Better cooperation among relevant  agencies in crisis and 
consequence management, response and recovery management; it 
should develop a bio-specific checklist of requirements for consequence management, response and recovery. 
• Good practices on responding to security incidents involving the 
facilities possessing any of  the biological agents and toxins on the 
EU biosecurity list;  Development 
of good 
practices 2011-
2014 Member 
States, 
Commission, 
relevant 
stakeholders  
H.47 Each Member State should:  
•Assess the required amounts and type s of medical countermeasures 
in case of a incident involving high-risk CBRN materials; • Assess the availability of hospital beds and hos pitals able to carry 
out the decontamination of victims,  the availability of medical and 
paramedical personnel, transpor t possibilities and of required 
countermeasures in the form of technical CBRN equipment.; 
• Assess the possibility of shari ng medical counter-measures across 
borders in case of an incident.  Problem 
identification 2011 Member 
States 
supported by the Commission  
B.22 The Health Security Committee should consider: 
• The possibilities to a) establish therapeutics and vaccine stockpiles 
towards the known threat of biological agents and toxins, and 
determine the necessary auxiliary medical supplies to stockpile 
(gloves, masks, syringes, etc.); b) establish a standby capacity to 
produce therapeutics, including vaccine s, and c) establish sustained 
funding for a technology platform to secure countermeasures 
towards biological agents and toxins that are unknown today (public-private experts working group); 
• The possibilities to scale up the diagnostic capacity in crises 
situations. Involvement of the private sector in the working group should be considered. 
• Ensuring a sufficient amount of medical products to combat an 
eventual threat;  • Build an EU wide coordinate d approach to access medical 
countermeasures allowing adequate protection of the EU population, 
based on risk assessment.  Coordination 2011-
2014 Member 
States, 
Commission, 
relevant 
stakeholders  
B.23 The Commission and Member States should consider the creation of 
mechanisms for rapid licensing proc edures of drugs and vaccines in 
crisis situations and possible exem ptions from licensing procedures, 
taking existing work into consideration.  Potentially 
legislative  2012 Member 
States, Commission, 
relevant  
 
EN 104   EN stakeholders  
H.49 Member States should exchange  information on emergency plans 
regarding CBRN incidents, invol ving all relevant agencies.  Information 
exchange  Ongoing Member 
States, 
Commission   
RN.27 The Member States and the Co mmission should consider integrating 
and building upon existing platforms for international exchange of 
information during nuclear emer gency situations, as well as 
assessing their applicability to all radiological and nuclear incidents 
of concern (scenario-based). An ef fort should be made to assess the 
possibilities of streamlining aler t messages going through different 
rapid alert systems.  Information 
exchange  From 
2010 Member 
States, 
Commission, EU agencies   
As mentioned earlier, actions involving legisl ative action or implying high costs will be 
subject to separate impact assessments/feasibility studies. 
6.2. Assessment of the EU added value 
The EU leading cooperation 
There is a need for cooperation at the EU level. Terrorism is international in character, 
the EU has shared borders and some terrorists  can move freely within the EU. There is a 
strong emphasis in the preferred policy opti on on actions involving cooperation between 
Member State authorities and other stakeholders, cooperation with international stakeholders and cooperation with in Member States. The EU is well placed to lead and to 
act as a catalyst for this cooperation. It w ould also favour the development of an EU 
position in the international arena. 
The cooperation proposed ranges from the ex changes of experiences and good practices 
in some actions to exchanges of information and intelligence that could have operational 
significance in others. These act ions could all help reinforce channels for bilateral and 
multilateral cooperation be tween Member States. 
In some cases the cooperation concerns the exchange of expe rience and good practice 
and in others it involves the exchange of  intelligence that could have operational 
significance. These actions could themselves help reinforce channels for bilateral and 
multilateral cooperation be tween Member States. 
In this sense the preferred policy option is perfectly in line with the principles of 
proportionality and subsidiarity. Firstly, proof of that is the choice of the instrument itself 
– an Action plan, rather than  a regulatory framework. Secondly, the Action plan is mostly 
concentrating on high-risk CBRN materials only, rather than all CBRN materials. 
Thirdly, a large number of measures propos ed build upon existi ng safety measures. 
Where gaps between applicable safety and security measures exist, only these are 
addressed. Furthermore, given the potential consequences of a CBRN attack in terms of 
human lives, costs, psychologica l effect, etc, the actions ta rgeted at preventing these 
attacks or ensuring an efficient response are proportionate. 
Regarding subsidiarity, the very nature of the terrorist threat can imply international 
consequences, thus EU level coordinated ap proach is needed. Information on existing 
vulnerabilities in Europe is of course clas sified, however based on the last reports on the 
CBRN threat, evidence of such possibilitie s does exist. There are several examples 
among the actions proposed, where a cross- border/EU element is obvious. These for 
 
EN 105   EN example include activities related to informa tion exchange, international co-operation or 
transport security, and securi ty vetting. Furthermore, many of the measures proposed are 
based on the internal market principle. Proposing an EU a pproach towards these issues 
would ensure a level playing field across the EU in terms of price competitiveness and possibly eliminate the weakest links in terms of security. 
The EU as a provider of funding for actions 
Some of the actions included in the Prefe rred policy option involve, are or likely to 
involve EU expenditure. This include s funding for cooperation, mapping and 
identification of good practices, working gr oups, research and the development of 
testing, trialling and certifica tion schemes for detection sy stems and equipment. Whilst 
normally the costs of the la tter would be met by producers,  there is a strong public 
interest in ensuring that detection equi pment and systems work in practices. 
Expected take-up among relevant stakeholders  
The expected take up among releva nt stakeholders is very hi gh, due to the fact that all 
actors that will have to implement the Ac tion Plan participated actively in its 
development through the wide EU consultati on, and especially the CBRN Task force.  
As already outlined in the beginning of the report, the Action Plan was informed by a 
large-scale consultation process, involving the establishment of the CBRN Task Force 
and its specific sub-groups, including public an d private experts from all relevant sectors 
and from all Member States. The experts ha ve, together with the Commission, already 
extensively discussed the possibl e actions to be undertaken with  regard to the security of 
CBRN materials and put forward recommendations  as to which actions would be most 
relevant and necessary for incl usion in the Action Plan.  
All actions that are presented and assessed in this report ha ve already been extensively 
reviewed, further shaped and validated by expert s in the field, in particular in terms of 
their relevance and appropriateness to counter  CBRN threats. Limitations and bottlenecks 
have already been considered during the consultati on phase, and have le d to discarding a 
number of actions from th e preferred policy option.  
Such an approach has ensured that ownershi p of the actions to implement is present 
among all relevant stakeholders. In order to ensure maximum take-up, the intention is to 
continue to build on the community which was formed by the CBRN Task Force. In 
particular, the Commission foresees that the members of the Task Force will be invited to become members of a CBRN Advisory Group, wh ich will assist in providing advice on 
the implementation of the Action Plan. Other rele vant actors will also be included in the 
implementation of the Action plan, e.g. the Health Security Committee.  
Holistic / Framework approach at EU level 
An additional advantage of the single approach chosen is that it allows for synergies to be 
identified. Many of the actions which have be en identified as necessa ry by the experts are 
applicable to all the different materials covered – this means that similarities in the methodology to be used to take certain actions  forward and increase efficiency can be 
 
EN 106   EN used across the board. A prime ex ample of the benefits of a coordinated approach relates 
to security vetting for thos e persons who have access to CBRN  materials – clearly this 
requires a consistent approach for all material s. An added benefit is that the different 
materials will (at least in theory) be equally well protected – avoiding displacement choices by the would-be terrorists for those ma terials which are the easiest to obtain. The 
approach taken avoids the po ssibilities of a fragmented approach towards different 
sources of threats and releva nt stakeholders, for example prevention planners, first 
responders, critical infrastructu re operators, complying with different sets of rules and 
different systems. 
 
EN 107   EN 7. MONITORING AND EVALUATION  
The timeframe proposed for the initial impl ementation of the CBRN Action Plan is 3 
years. This period should be long enough for si gnificant progress to be achieved, and fits 
in well with the timeframe of the financial programmes supporting its implementation. An evaluation study, focusing of course also on unforeseen or unintended effects, will be 
prepared before the firs t evaluation takes place. 
Due to the nature of CBRN threats, the im plementation of the CBRN Action Plan will be 
an ongoing process, adjusted and fine-tuned in line with up-to-date risk assessments. The 
implementation of the Action Plan should st art immediately following its adoption by the 
Council. The implementation of the vast majo rity of measures id entified in the CBRN 
Action Plan will be completed or underway in the period 2010-2013.  
In order to ensure maximum take-up, the in tention is to continue to build on the 
community which was formed by the CBRN Ta sk Force. In particular, the Commission 
foresees that the members of the Task Force will be invited to become members of a CBRN Advisory Group, which will assist in providing advice on the implementation of 
the Action Plan. Over the course of the initi al three year period, regular reporting and 
monitoring of the implementation will also ta ke place through the continued involvement 
of relevant Council Working Gr oup(s) dealing with CBRN issues and the Health Security 
Committee.  
The CBRN Advisory group is going to meet at  least once a year to  discuss horizontal 
issues (across the C, B and RN strands) and will schedule additional meetings for specific strands. The main purpose of the Advisory group  will be to monitor the progress made in 
the implementation of the Action plan. The first meeting of the CBRN Advisory group 
will be scheduled immediately after the adoption of the CBRN Action plan in the 
Council, in order to discuss a nd define the implementation pr iorities for the first year. 
The advisory group meeting reports (prepared on  the basis of defined indicators) will be 
considered as yearly monitoring/review reports; 
An evaluation of the Action Plan and its implementation will be prepared by the 
Commission in line with the generally applicab le framework for such evaluations at the 
end of the three year implementation period. As  the Action plan is going to be discussed 
in the Council, where the possibility of changes of specific actions exists, it is too early to 
define key indicators in detail s (they can only be considered  provisional). Nevertheless, 
concrete indicators could be the number of implemented actions, but more importantly, 
could also be a decrease in CBRN incidents, which could for example be verified by way 
of the IAEA, Interpol's and Europol's data on this topic. Additi onal indicators could 
relate to the implementation of security plans at CBRN facilities, as well as measures 
adopted to increase the securi ty of transport, the adopti on of codes of conduct etc.  
The main monitoring and evaluation arrangeme nt will focus on the achievement of the 
objectives established by the CBRN Policy package. For this purpose, the "scoreboard principle" will be followed in order to assess the progress in the implementation of the 
 
EN 108   EN measures. This will be particularly relevant  for a number of issues identified in the 
Action Plan, for which feasibility assessments will be conducted in 2010-2012. On this basis, possible amendments or a revised/ new strategy/action plan  can be presented. 
 
EN 109   EN ANNEX 1: CBRN  GLOSSARY  
AAAS American Association for the Advancement of Science 
ACDP Advisory Committee on Dangerous Pathogens 
ADN International Carriage of Dangerous Goods by Inland 
Waterway Regulations 
ADNS Animal Disease Notification System ADR International Carriage of  Dangerous Goods by Road 
Regulations (Accord européen relatif au transport international des marchandises dangereuses par route) 
AFSSA Agence française de sécurité sanitaire des aliments (France) 
ARGOS DSS Accident Reporting and Gu idance System - Decision Support 
System 
BSS Basic Safety Standards BTWC Biological and Toxin Weapons Convention BWC Biological Weapons Convention CA Competent Authority CBRN Chemical, Biological, Radiological and Nuclear 
CCPNM Convention on the Physical Pr otection of Nuclear Material  
CCS Civil Contingency Secretariat (UK) CDHS United States Center for Homeland Security and Defence 
CEFIC European Chemical Industry Council CEN European Committee for Standardisation (Comité Européen de 
Normalisation) 
COBRA Civil contingencies committee leading responses to national 
crises (UK) 
COSHH Control of Substances H azardous to Health Regulations 
CPS&Q Consumer Products Safety & Quality 
 
EN 110   EN CWC Chemical Weapons Convention 
Defra Department of the Environm ent, Food and Rural Affairs (UK) 
DG ENTR Directorate-General for Enterprise and Industry of the 
European Commission 
DG JLS Directorate-General for Justi ce, Freedom and Security of the 
European Commission 
DG RTD  Directorate-General fo r Research and Technological 
Development of the European Commission 
DG SANCO European Commission’s Dire ctorate General for Health and 
Consumer Affairs 
DG TREN Directorate-General Energy and transport of the European 
Commission  
DGSE Direction Générale de la Sécurité Extérieure  
EBDS European Bomb Data System EBSA European Biosafety Association EUChFR Charter of Fundamental Rights of the European Union 
ECHR European Convention on Human Rights ECDC European Centre for Disease Prevention and Control ECURIE  European Community Ur gent Radiological Information 
Exchange for Nuclear Emergencies  
EDA European Defence Agency EEA European Economic Area ENAC Emergency Notificati on and Assistance Convention 
EPCIP European Programme for Crit ical Infrastructure Protection 
ESCON Epidemiological Surveillanc e Component of the Community 
Network 
ESRAB European Security Research Advisory Board ESRIF European Security Research and Innovation Forum 
 
EN 111   EN EURDEP European Radiological  Data Exchange Platform 
EUROPHYT European Network of Plant Health Information Systems EWRS Early Warning and Response System FMD Food and Mouth Disease FORATOM European Atomic Forum FP7 / FP8 European Union’s Framew ork Programme for research and 
technological development 
FVO Food and Veterinary Office of the EU GHSI Global Health Security Initiative GICNT Global Initiative to Combat Nuclear Terrorism HASS High Activity Sealed Sources and Orphan Sources HazMat Hazardous materials HEDIS Healthcare Effectiveness Data and Information Set HEU Highly Enriched Uranium HSC European Commission’s Health Security Committee IAEA International Atomic Energy Agency IFCS Intergovernmental Forum on Chemical Safety INCHEM The International Programme on Chemical Safety IND Improvised Nuclear Device INERIS National Institute for Industrial environments and risks 
(France) 
ITRAP Illicit Trafficking Radiati on Detection Assessment Programme 
JRC Joint Research Centre NATO North Atlantic Treaty Organization NORM Naturally Occurring Radioactive Materials NPR Non-Proliferation Regime 
 
EN 112   EN NPT Treaty on the Non-Proliferation 
NSABB National Science Adviso ry Board for Biosecurity 
OECD Organisation for Economic Co-operation and Development OIE World Organisation for Animal Health OPCW Organisation for the Proh ibition of Chemical Weapons 
PAHO Pan American Health Organization RAS 
BICHAT Rapid Alert System for Biologi cal, Chemical and Chemical 
Terrorist Events 
RAS-CHEM Rapid Alert System for Chemicals RDD Radiological Dispersion Device REACH European Union Regulati on on Registration, Evaluation, 
Authorisation and rest riction of Chemicals 
RID International Carriage of Dangerous Goods by Rail 
Regulations 
RITNUM Response to Illicit Tra fficking of Nuclear Material 
RPG Rocket-Propelled Grenade RPM Radiation Portal Monitor SAGAS 
Group Stakeholders Advisory Group on Aviation Security 
SAPO Specified Animal Pathogens Order 
SARS Severe Acute Respiratory Syndrome SGDN General Secretariat of National Defence (Secrétariat Général 
de la Défense Nationale, France) 
SitCen EU Joint Situation Centre SÜG Security Vetting Act (Sic herheitsüberprüfungsgesetz, 
Germany) 
TIC toxic industrial chemicals TRACES Community Trade Control and Expert System 
 
EN 113   EN UN FAO Food and Agriculture Orga nization of the United Nations 
US GAO US Government Accountability Office WHO World Health Organisation WMD Weapons of Mass Destruction 
 
EN 114   ENANNEX 2: EXAMPLES OF INCIDENTS , MILITARY AND TERRORIST ATTACKS INVOLVING CBRN  MATERIALS  
Attacks involving biological substances 
Date  Organisation/ 
Perpetrators Location/ 
Country Biological Agent Comments Damage/ Casualties 
Large-scale attack plans  
Attacks 
1982- 
Onwards The Civil Cooperation 
Bureau (CCB) of South 
African Military Intelligence  South Africa, various Bacteria: Anthrax 
Bacillus anthracis 
 And various other 
Biological Agents The South African Apartheid regime established a covert 
biological warfare unit ‘Project Coast’ was covertly es tablished, developing biological 
weapons which were used in assassinations  
March 1988 - 
onwards  Iraqi Authorities Al-Salman (Salman 
Pak),  
al-Taji and 
al-Hakam, Iraq  Bacteria: Anthrax 
Bacillus anthracis;  
Bacteria: Gas gangrene  
Clostridium perfringens Following its Chemical warfare capabilities, Saddam 
Hussein’s regime began deve loping biological weapons   
Failed attacks 
1972 Order of the Rising Sun / 
extreme right wing 
terrorists Chicago, St. Louis and 
other major cities,  
United States Bacteria: Typhoid 
Salmonella typhi; 
Various other Biological 
Agents Planned to poison water supplies to disseminate 
pathogens Conspiracy foile d by authorities 
1992 Japanese Aum Shinrikyo 
religious cult / terrorist group Zaire and Kamikuishiki 
Japan Virus: Ebola  
(Filovirus causing 
haemorrhagic fever) Members of the Cult travelled to Zaire to acquire samples 
of the Ebola virus, but the group was unsuccessful in developing it as a weapon Conspiracy failed as the group was unable to achieve 
weaponisation of the Ebola cultures at their base  
May 1995  Aryan Nations member / Ohio, Bacteria: Plague A laborator y technician and white extremis t, Larry Harris, Conspiracy f oiled by authorities 
 
EN 115   ENDate  Organisation/ 
Perpetrators Location/ 
Country Biological Agent Comments Damage/ Casualties 
extreme right 
supremacist / Laboratory Technician  United States  Yersinia pestis 
 used false letterhead to obtain three vials of Plague  
Small-scale attacks 
Attacks 
1970s Soviet Military Research 
Scientists Vozrozhdeniye 
‘Renaissance’ Island, 
Aral Sea, Central Asia Bacteria: Anthrax 
Bacillus anthracis  Secret trials using Anthrax and other biological agents  Still contaminated with Anthrax spores to a high degree 
1978 Bulgarian KDS Secret 
Police  Paris, France Cytotoxin: Ricin 
(Produced from mash left 
after processing of Castor 
oil beans) Bulgarian exile Vladimir Kostov had a pellet containing 
Ricin shot into him with an ‘Umbrella gun’ Lived due to thick clothing pr eventing deep penetration and 
wax covering of Ricin failing to melt  
September 
1978 Bulgarian KDS Secret 
Police  Waterloo Bridge, 
London, England  Cytotoxin: Ricin  
(Produced from mash left 
after processing of Castor oil beans) Bulgarian exile 
Georgi Markov had a pellet containing Ricin shot into 
him with an ‘Umbrella gun’ Died 72 hours after attack, following high fever and heart 
attack 
September19
84 Devotees of Bagwhan 
Shree Rajneesh / religious cult Wasco, Oregon,  
United States  Bacteria: Salmonella  
Salmonella typhimurium Contaminated glasses and bowls in local salad bars to 
incapacitate population before elections and gain office No fatalities but around 751 cases of ‘Food poisoning’ 
1990-1993 Japanese Aum Shinrikyo 
religious cult / terrorist 
group Japan various Bacteria: Anthrax 
Bacillus anthracis;   
Neurotoxin: Botulinum 
(produced by Bacteria: 
Clostridium botulinum  ) Prior to well known attacks using Sarin nerve agent, 
experimental release of aerosol sprays containing Anthrax 
and Botulism at least 10 times Apparently no victims reported. In a case of Anthrax used 
‘Sterne’ strain which does not affect humans, possibly as a test 
run  
October 2001 Believed disgruntled  
Military Research 
Scientist  Senate Building 
Washington & New 
York media offices Bacteria: Anthrax 
Bacillus anthracis 
 
Military grade ‘Ames’ Anthrax spores were dispatched through the US postal 
system in five envelopes to  be opened by recipients 11 pulmonary cases, 5 of whom died, and 11 cutaneous who 
survived, thousands treated and 300 locations tested 
 
EN 116   ENDate  Organisation/ 
Perpetrators Location/ 
Country Biological Agent Comments Damage/ Casualties 
strain spores mixed with 
Bentonite to prevent clumping 
Failed attacks 
1979 Rhodesian Central 
Intelligence Organisation  
 London Cytotoxin: Ricin  
(Produced from mash left 
after processing of Castor 
oil beans) Plan to assassinate Robert Mugabe with a Ricin tipped 
bullet  The Conspiracy was allegedly called off when the assassin was 
already in London 
1980s German Red Army 
Faction / 
Extreme left terrorists  Paris, France Neurotoxin: Botulinum 
(produced by Bacteria: 
Clostridium botulinum  ) A large amount of the Botulinum toxin was found in the 
groups Parisian safe house  
1991 Minnesota Patriots 
Council / extreme right militia  
 Minnesota, 
United States  Cytotoxin: Ricin 
(Produced from mash left 
after processing of Castor 
oil beans) Planned to smear Ricin on door  handles in attacks on local 
police & tax officers Conspiracy foile d by authorities 
December 
16th 2002 Algerian GSPC 
extremists linked to the 
Al Qaeda network / 
terrorist group Paris, France  Believed various Chemical 
weapons and toxins Two cells in la Courneuve and Romainville associated 
with the Benchellali family were planning attack on 
Russian Embassy Conspiracy to launch a ‘non – conventional’ attack on the 
Russian Embassy, Paris was foiled by the authorities  
January 2003 Algerian extremists 
linked to the Al Qaeda 
network / terrorist group Wood Green, London  
 
Manchester  Cytotoxin: Ricin 
(Produced from mash left 
after processing of Castor 
oil beans) Conspiracy to create Ricin, possibly to smear it on door 
and car handles to kill members of the public Conspiracy foiled by the authorities in ‘Operation 
Springbourne’ but not without the murder of Detective 
Stephen Oake 
Accidents 
1971 Soviet Accident Aralsk, Aral Sea, 
Central Asia Virus: Smallpox 
Variola virus  It has been suggested that a limited outbreak in Aralsk 
may have been due to a research accident Around 10 people may have died in the outbreak, believed to 
have emanated from nearby Vozrozhdeniye ‘Renaissance’ 
Island 
1972 Soviet Accident  Aral Sea, near 
Vozrozhdeniye ‘Renaissance’ Island, Bacteria: Plague 
Yersinia pestis Believed a local fishing vessel sailed too close down wind 
to test area and exposed  Several local Kazakh fisherman found dead from the Plague 
aboard their boat 
 
EN 117   ENDate  Organisation/ 
Perpetrators Location/ 
Country Biological Agent Comments Damage/ Casualties 
Central Asia   
 
1977  British Accident United Kingdom Virus: Smallpox 
Variola virus  Accidental release of virus from a research laboratory  One research scientist died 
April 2nd 1979 Soviet Accident Soviet Institute of 
Microbiology  
& Virology,  
Sverdlovsk, 
(Yekaterinburg) 
Russia Bacteria: Anthrax 
Bacillus anthracis Failure to replace a filter at a research plant released a 
cloud of Anthrax spores which dispersed for at least 35 miles downwind Believed around 100 deaths, probably more, others infected, 
tens of thousands vaccinated, and dead livestock 
April 13th 
1988 Soviet Accident  Vektor Viral Research 
Centre, Koltsovo, Siberia, Russia Virus: Marburg 
(Filovirus causing 
haemorrhagic fever) A biological warfare scientist was accidently injected with 
the virus One research scientist, Nikolai Ustinov died from 
haemorrhagic fever  
 
Attacks involving chemical agents 
Date  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
Large-scale attack plans  
Late 1940s- 
early 1950s British Forces  Malaya va rious Trichlorophenoxyacetic 
Acid / 245 T 
 Defoliant: Herbicide killi ng crops and vegetation. 
During Malayan Campaign 245 T was used to try and 
starve Communist Guerrillas NA 
1950s Soviet experts  Various research and 
production sites mainly believed to have been Soman (GD) Nerve Agent  Nerve Agent: Interferes with acetylcholinesterase, 
disrupting the mechanism by which nerves communicate NA 
 
EN 118   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
located in the Ural 
mountains with organs, leading to overstimulation and death 
In order to compensate for the US advantage in Nuclear 
weaponry, the Soviet Uni on developed stockpiles of 
various chemicals including Soman  
1950s to early 1960s  
 American Experts  Various US Research 
locations Agent BZ / 3-
Quinuclidinyl benzilate 
(QNB BZ) 
 Incapacitant: Affects the peripheral and central nervous 
systems, producing incapacitation, hallucinations, 
confusion and the effects associated with a drugs ‘trip’ 
Hundreds of American servicemen and members of the 
public, were used to test the ‘incapacitant’ LSD and other 
similar drugs resulting in the development of BZ  At least one US patient receiving psychiatric treatment known 
to have died in 1953, having  unknowingly been given an 
overdose of Mescaline during such clinical testing 
1960s to early 
1970s US Air Force South East Asia: 
Vietnam, Laos & 
Cambodia  Agent Orange / Containing 
245T and Dioxin 
 Defoliant: Herbicide killing crops and vegetation 
During the Vietnam War the US made extensive use of 
Agent Orange to strip jungle, reduce hiding places & limit ambushes Despite being a defoliant, the minute traces of dioxin 
accumulated through the scale of usage, leading to birth 
defects, illness and cancers amongst those exposed.  
1960s to early 1970s US Military  South East Asia: 
Vietnam, Laos & 
Cambodia Agent CS / CS Gas / 2-
Chlorobenzalmalononitrile 
 Incapacitant: Causes stinging and burning of eyes and 
skin, runny nose, sneezing and coughing 
Used by the US military duri ng the war in Southeast Asia, 
in particular to flush Viet Cong out of tunnel complexes. While not fatal, a high level of exposure, particularly in a non-
ventilated area could cause longer term problems. 
Late 1960s to 1990s British Military  Northern Ireland  Agent CS / CS Gas / 2-
Chlorobenzalmalononitrile Incapacitant: Causes stinging and burning of eyes and 
skin, runny nose, sneezing and coughing 
Regularly used by British Milita ry against riots during the 
‘Troubles’ in Northern Ireland.  While not fatal, a high level of exposure, particularly in a non-
ventilated area could cause longer term problems. 
1980- 1988 Iraqi Military  Ira n-Iraq border areas  Mustard Gas (H) / ‘Sulfur 
Mustard’ / Dichlorethyl 
Sulphide and Nerve Agents, Tabun (GA), Sarin 
(GB) During the course of the Iran-Iraq War, to counter the 
numbers and ‘human wave’ tactics of the Iranian forces, 
the Iraqis used extensive chemical weapons Although no exact figures are ava ilable, one figure quoted by a 
US source estimated that around 20,000 Iranian soldiers had 
been killed in Iraqi chemical attacks. 
 
EN 119   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
March 1988 Iraqi Military  Halabja, Kurdish 
region, Northern Iraq Mixture of : Mustard Gas 
and Hydrogen Cyanide (AC)  Blister and Blood Agents 
During its attacks against the Iraqi Kurds, the Iraqi Air 
Force attacked Halabja with Chemicals Between 3500 and 5000 Kurdish villagers were killed during 
the attack and 10,000 injured.  
2001-2 Al- Qaeda (AQ) Kandahar and other 
locations in 
Afghanistan  Cyanide  
 Blood Agent: Stops the cells ability to take up oxygen, 
either from the blood or from the air into the blood, via 
the lungs, causing unconsciousness, convulsions and 
death 
In Afghanistan, Coalition fo rces discovered drums of 
Cyanide in AQ tunnels by Kandahar airport and videos of 
dogs being gassed. Believed AQ attempted to deve lop a Chemical capability. 
2003 onwards 
 
e.g. three in 
February 
2007  Tawhid Wal Jihad / al-
Qaeda in Iraq  Iraq, various locations Chlorine Gas (CL)  Pu lmonary / Choking Agent: Attacks lining of lungs 
leading to pulmonary oede ma and ‘land drowning’ 
During the course of the ongoing conflict in Iraq, 
insurgents have enhanced th eir bomb attacks by utilising 
chlorine gas tankers to create a cloud of gas engulfing 
survivors and rescuers. Coalition Forces and Iraqi civilians 
April 2003 Possible extreme right 
wing. Three 
conspirators, no target or motive known: William 
Krar, Judith Bruey & 
Edward Feltus Noonday, Eastern 
Texas, USA Sodium cyanide (800gms) 
& acids (hydrochloric, 
nitric & acetic) 
 To be used to make Cyanide gas (highly lethal) 
As well as the chemicals, police recovered 65 pipebombs, 
guns & 1m rounds of ammuniti on, forged official passes 
to the UN & the DEA Potentially could ha ve killed “thousands” 
Small-scale attacks and accidents 
Attacks 
1959  Soviet KGB  Munich, Germany. Prussic Acid / Cyanide 
 Blood Agent: Stops the cells ability to take up oxygen, 
either from the blood or from the air into the blood, via 
the lungs, causing unconsciousness, convulsions and death Stefan Bandera, a Ukrainian dissident was assassinated.  
 
EN 120   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
KGB agent Bogdan Stashinsky  used a prussic acid ‘gun’ 
to fire the poison into his victims face. 
1964 Believed Soviet KGB Zagorsk Monastery, 
near Moscow, Russia Nitrogen Mustard Gas 
 Blister Agent / Vesicant: Causes  severe blistering to skin, 
eyes and airways, often lethal 
A technical specialist successfully ‘swept’ the German 
Embassy in Moscow for listening devices, before taking a 
sightseeing trip to the famous Zagorsk Monastry, where he was attacked.  German technical specialist Ho rst Schwirkmann had severe 
chemical burns to his buttocks and backs of thighs. 
November 1979 Saudi Military with 
French and US Support  The Grand Mosque, 
Mecca, Saudi Arabia Agent CS / CS Gas / 2- 
Chlorobenzalmalononitrile 
 Incapacitant: Causes stinging and burning of eyes and 
skin, runny nose, sneezing and coughing 
On 20
th November 1979, followers of Juhayman al 
Uteybi, seized the Grand Mosque. During their attempts 
to recapture the Mosque and its buildings, Saudi security forces used CS gas.  Extremists linked to the Juhayman movement who had seized 
the Grand Mosque. 
November 1976 The “Alphabet Bomber”  
(Muharem Kurbegovic – 
lone actor) Los Angeles, USA Sodium cyanide Possession of 25lbs of Sodium cyanide plus other 
chemicals e.g. acids. Could have been used to make 
cyanide gas or in the manufacture of tabun  
Two years after arrest & conviction for making & 
planting an IED that killed 3 people, he revealed to police 
the location of other materials in his house If he had not been caught, Kurbegovic would have gone on to 
commit a terrorist act with a chemical agent. He was 
particularly knowledgeable about nerve agents such as sarin & 
tabun  
March 1987 
 “Captain Nemo of Force 
Majeure” Cyprus Dioxin Highly detailed & initia lly credible threats to release  
dioxin  unless $15m is paid by the Cypriot government. 
Cited 1976 Seveso incident as a consequence of dioxin release. 
Panos Koupparis arrested on May 14
th 1987 in London 
along with two members of his family (one a chemistry student at university) No casualties 
 
EN 121   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
June 1990  Liberation Tigers of 
Tamil Eelam (LTTE)  East Kiran Sri Linkan 
Special Forces base. Chlorine Gas (CL)  Pulmonary / Choking Agent: Attacks lining of lungs 
leading to pulmonary oede ma and ‘land drowning’ 
Attacking a military base, the LTTE placed drums of 
chlorine around the perimeter and released it when the 
wind direction was correct Sri Lankan Army special forces.  
June 27th 
1994 Aum Shinrikiyo Cult  Matsumoto, Japan 
  
Kamikuishiki, Japan  Sarin (GB)  
 Nerve Agent: Interferes w ith acetylcholinesterase, 
disrupting the mechanism by which nerves communicate with organs, leading to overstimulation and death   
The religious extremist cult used home-made Sarin to 
attack an apartment block in Matsumoto district and a small village next to the ASK compound  The Matsumoto attack killed seven and injured three hundred.  
In Kamikuishiki, no deaths but several people suffered 
identical symptoms to Matsumoto 
December 1994 Aum Shinrikiyo Cult Japan  Agent VX  
 Nerve Agent: Interferes w ith acetylcholinesterase, 
disrupting the mechanism by which nerves communicate 
with organs, leading to overstimulation and death 
The religious extremist group managed to apply VX nerve 
agent to the skin of an opponent.  The victim died from exposure to Nerve Agent. 
20th March 
1995  Aum Shinrikiyo Cult Tokyo underground 
system, Japan.  Sarin (GB)  
 Nerve Agent: Interferes w ith acetylcholinesterase, 
disrupting the mechanism by which nerves communicate 
with organs, leading to overstimulation and death 
Five members of the Aum Shinrikyo Cult got onto the 
tube in the morning rush hour at different locations. Each 
carried a plastic bag of Sarin, which were all punctured 
with umbrellas Twelve people died and over fi ve thousand were injured.  
October 2002  Russian Army Special 
Forces Dubrovka Theatre, 
Moscow Believed Halothene or 
Fentanyl 
 Anaesthetic: Believed based around Opiate/Morphine 
This gas knocked out the terro rists and stopped detonation 
of their suicide bombs, but lack of care left 155 hostages 
dead. Chechen extremists were knocked unconscious and then shot 
by members of Russian Alpha & Vympel Special Forces units. 
 
EN 122   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
September 
2004 Possibly Ukrainian 
officials with links to the Russian Federalnoye 
Slyzhba Bezopasnosti 
(FSB) Kiev, Ukraine  Dioxin In September 2004,  Viktor Yushchenko was running as an 
opposition candidate for the Presidency of Ukraine, when he was struck down with an  unexplained illness. This 
caused severe damage to his internal organs and severe 
facial acne. Medical investigations showed that he had been poisoned with dioxin and that his body had 1,000 
times the normal concentration. Despite the severe damage it caused to him, later President 
Yushchenko survived this assassination attempt.  
Failed 
1980 The Covenant, Arm and 
Sword of the Lord Northern Arkansas, 
USA Potassium cyanide  was to be used to poison the water supply to a city 
(believed to be Washington) 
The CSA had accumulated/manufactured 30 gallons of it 
in their own facility No casualties caused 
23rd April 
1997 
 Ku Klux Klan Fort Worth, Texas, 
USA Hydrogen Sulphide gas.  Plan by four members to hold up and rob an armoured car 
with cash in transit. To tie up police resources, they would cause an explosion at a nearby refinery to release the gas. Four pre-emptive arrests made. No  injuries. Estimated that if 
carried, up to 30 000 casualties possible. 
2002  Al- Qaeda  (AQ) Rome, Italy  Potassium ferro-cyanide 
 Blood Agent: Stops the cells ability to take up oxygen, 
either from the blood or from the air into the blood, via 
the lungs, causing unconsciousness, convulsions and 
death 
Four Moroccans were arrested by the Rome police 
planning to mount an attack on the US Embassy by 
putting Cyanide in its water supply.  Believed terrorists planning to  attack US Embassy staff 
April 2004 Kataeb al Tawhid  
(linked to “AQ in 
Mesopotamia”- led by 
Abu Musab Zarqawi  Amman, Jordan Chemical mix containing 
sulphuric acid, blister, choking & nerve agents Three specially adapted vehicles carrying 20 tons of 
“chemical mix” containing sul phuric acid, blister, choking 
& nerve agents 
Was to have been series of suicide attacks on HQ of 
Jordanian security service, PM office, US Embassy & others. Vehicles stopped & arrests made. If it had gone ahead as planned & intended, Jordanian officials 
estimated up to 80 000 casualties and very many deaths 
 
EN 123   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
August 2004 
 Al-Qaeda London, UK various Chlorine Gas (CL)  Pulmonary / Choking Agent: Attacks lining of lungs 
leading to pulmonary oede ma and ‘land drowning’ 
In a conspiracy led and organised by Dhiren Bharrot aka. 
Isa al Hindi, plans were proposed to utilise chlorine 
tankers as improvised chemical weapons in built up areas  Believed terrorists planned the use of chlorine tankers as 
improvised chemical weapons  
Accidents 
1952-61 British experts Porton Down research 
establishment, 
Salisbury Plain, Wiltshire / Nancekuke 
production site, 
Cornwall  Sarin (GB)  
 Nerve Agent: Interferes w ith acetylcholinesterase, 
disrupting the mechanism by which nerves communicate 
with organs, leading to overstimulation and death  
Four accidents during test experiments or facility 
maintenance involving Nerve Agents.  Three staff left permanently affected by exposure and 
invalided and one serviceman acti ng as a ‘guinea pig’ killed by 
a drop of Nerve Agent applied to his forearm.  
1952 British experts Plant Protection 
Laboratory, Imperial 
Chemical Industries (ICI)  Agent VX  
 Nerve Agent: Interferes w ith acetylcholinesterase, 
disrupting the mechanism by which nerves communicate 
with organs, leading to overstimulation and death 
While attempting to develop a new pesticide, Dr. Ranajit 
Ghosh discovers a more visc ous and more powerful liquid 
nerve agent than the German ‘G’ series. NA 
1976 Industrial accident Seveso, Italy Dioxin  Release of  dioxin from chemical plant after an accidental 
explosion 
Burns, sores on the skin in se veral residents near the plant. 
Symptoms of fatigue, loss of appetite & nervousness in many more Italian authorities forced to slaughter 80 000 domestic animals 
as a protective measure 
3rd December 
1984 Union Carbide Accident  Union Carbide Plant, 
Bhopal, India Methyl Isocyanate (MIC)  
 Pulmonary / Choking Agent: Attacks lining of lungs 
leading to pulmonary oede ma and ‘land drowning’ 
After water entered one of the plants storage tanks, 42 
tonnes of the gas were accidentally released, affecting the nearby town. Although no exact figures are available, it is estimated that 
anywhere up to 5000 local people died, and thousands more 
were seriously injured.  
 
EN 124   ENDate  Organisation/ 
Perpetrators Location/ 
Country Chemical agent Comments Damage/ Casualties 
January 1997 
Onwards Not known but believed 
to be same perpetrator (lone actor?) Sydney, Australia 
 Three locations Chlorine and Sulphuric 
Acid  Devices designed to release quantities of  Chlorine (x2) or 
Sulphuric Acid 
No explosives involved. Injuries to 11 (sulphuric acid), 20 and 4 (chlorine) from 
inhalation of fumes 
2000 Striking Cellatex 
Employees Cellatex Factory, 
Ardennes, France Sulphuric Acid During a strike over the closure of the factory, staff 
poured 1,500 gallons of acid into a tributary of the Meuse 
and threatened to use 56,000 tons of other chemicals in 
their possession Environmental damage, no known fatalities. 
Attacks involving nuclear or  nuclear-related material 
Date Incident Material Comment 
Attacks  
June 1995 Czech Republic. Incident related to December 1994 
arrests. 0.0004 gms HEU (87.7%) Russia 
June 1995 Czech Republic. Incident related to December 1994 arrests 0.017 kgs HEU (87.7%) Russia 
November 2006 Alexander Litvinenko dies in London, UK after exposure 
to radioactive material. Believed to be murder, suspects 
known but not yet arrested. Polonium - 210 Russia (believed) 
Seizure of nuclear ma terials and arrests  
May 1992 Seizure by police in Moscow, Russia as the result of an 
investigation into an employee of a nuclear facility suspected of stealing equipment 1.5kgs Highly Enriched 
Uranium (HEU) (90%) Source of HEU was a State Re search Institute in Russia 
March 1993 Interception in Istanbul, Turkey by police of enriched 
uranium from the Former Soviet Union (FSU) 6kgs Uranium from FSU 
military source. Came in from 
Tashkent, Uzbekistan  
 
EN 125   ENMay 1993 Seizure by police in Lithuania. Probably a contaminant on 
the 4.4 tons of Beryllium that  was the focus of the police 
investigation 0.1kg HEU (50%) Source unknown 
July 1993 Seizure by police in Murmansk, Russia of two fuel rods 
stolen from a naval facility. Arrests made. 1.8kgs HEU (36%)  
October 1993 Seizure in Istanbul, Turkey of Uranium. Four Turks and 
four Iranians arrested  2.5 kgs of U238. Uranium believed to have been  flown in by a private plane taking off from 
Hartenholm, Germany, a private airfie ld owned by Iranian arms dealers 
November 1993 Seizure by police in Murmansk, Russia of several fuel 
rods stolen from a naval facility 4.5kgs HEU (20%) Russian sourced material 
March 1994 Seizure by police in St Petersburg, Russia of material 
smuggled out of a nuclear material production centre. Three arrests made as a result of trying to sell it 3.05kgs HEU (90%) Russian sourced material 
May 1994 Seizure by police in Tengen, Germany as a result of a 
possible “red mercury” scam 0.006kgs Plutonium-239 
(99.75% purity) Source unknown 
June 1994 Seizure by police in Landshut, Germany as the result of an 
undercover operation 0.0008kgs HEU (87.8%) Russian sourced material 
July 1994 Seizure of 12 kgs of Uranium, Istanbul. Seven Turks 
arrested 12 kgs Uranium, weapons 
grade, originating in Azerbaijan  
July 1994 Seizure by police in Germany 0.00024kgs Plutonium Russian sourced material 
August 1994 Seizure by police at Munich Airport, Germany. 
Individuals involved came from Spain and Colombia. Arrests also made in Moscow. 0.4 kgs Plutonium 
(plus 200gms of Lithium) Russian sourced material 
October 1994 Bulgaria. Suspected radio active material seized off a bus 
en route to Turkey  No further details 
December 1994 Seized in the Czech Republic when attempts were made to 
sell it. Three “nuclear workers” arrested. 2.7 kgs HEU (87.7%) Russia 
 
EN 126   ENFebruary 1996 Failed attempt to sell highly enriched uranium in 
Switzerland leads to a large seizure and eight arrests in 
Turkey 1, 128 kgs of highly enriched 
Uranium, as used in nuclear 
power plant fuel rods. Origin unclear  
1997 Russia, Novosibirsk. Two men arrested trying to smuggle 
nuclear material to Pakistan or China. Enriched Uranium, 11 pounds Stolen from nuclear facility in Kazakhstan 
March 1997 Failed attempt in Turkey to sell $3m worth of Osmium  2. 5gms of Osmium Used with Plutonium to form a very rigid & he at resistant coating in nuclear 
missile warheads 
June 1998 Seizure in Bursa, near Istanbul, Turkey of Antimony, 
Bismuth and Scanium. Three Turks arrested  Smuggled into Turkey from Azerbaijan 
July 1998 Thirteen cylinders believed to contain nuclear material 
seized in Van, Turkey after attempt to sell them for $1000 
each. Five Turks and one Iranian arrested Cylinders marked UPAT 
UKA3 M8 and stamped with 
three stars  
September 1998 Seizure in Istanbul, Tu rkey of Uranium and Plutonium. 
Nine arrests made 4.5 kgs of Uranium 
6 gms Plutonium 
 Believed to have been smuggled in from  Russia. Legitimate value of over 
$3m, asking price $1m 
May 1999 Seizure by Bulgarian Customs at the border. Turkish 
national arrested 0.004 kgs HEU  Russia 
October 1999 Seizure as a result of a ttempted sale in Kyrgyzstan 0.0015 kgs Plutonium Unspecified source 
April 2000 Four people arrested in Georgia. Their intention was to 
smuggle the material into Turkey and sell it 0.9 kgs HEU (30%) Detected at the border as the result of a police investigation. Source may have 
been Russia 
September 2000 Seized and arrests made  in Georgia during an attempt to 
sell it 0.0004 kgs Plutonium Source probably Russia but may have been Ukraine 
January 2001 Greece. About 300 metallic plates found buried in a forest, 
probably awaiting the opportunity for resale 0.003 kgs Plutonium Source unknown 
July 2001 Three arrests in Paris, France 0.005 kgs HEU (80%) Source unknown 
 
EN 127   EN2003 Two arrests in Brno, Czech Republic for attempt to sell 
bars of nuclear material for $715 000 Unconfirmed but reported as 
low enriched Uranium in bars Source unknown 
2006 Georgia, arrest of Russian citizen trying to sell a small 
amount of refined Uranium. It was in a plastic bag in his 
pocket. Weapons grade Uranium, 
small quantity  Unknown but Russia a possibility 
November 2007 Two arrests in Bratisla va, Slovakia and one in Hungary on 
suspicion of trying to sell nuclear material for $1m. Unconfirmed but reported as 
2.2 pounds of enriched Uranium  
July 2008 Two arrests in Cherkassy, Ukraine and seizure of Uranium 
and Cesium. One worked at the Ukrainian Embassy in 
Germany. Uranium and Cesium worth 
$4.9m (no further details) Stolen from a nuclear facility in Kiev 
Accident 
December 2000 Germany. Radioactiv e contamination on aging nuclear 
waste material discovered through testing. A site worker was arrested Less than 1 mg of Plutonium  German source, a closed spent fuel reprocessing plant 
Attacks involving radioactive material 
Date Incident Material Comment 
November 1995 Radioactive material found in a park in Moscow after 
Chechen group informed Russian TV station 32 kg container believed to 
contain Cesium-137. Source 
may have been Budyonnovsk 
hospital, Russia that they had 
temporarily occupied earlier 
that year Incident was to show that the Chechen s could strike in Moscow if they 
wished 
December 1998 Argun, Chechnya. A container with radioactive material 
inside and rigged to a land mine was found and defused   
 
EN 128   EN ANNEX 3: N ON-EXHAUSTIVE LIST OF INTERNATIONAL AND EUROPEAN LEGISLATION 
AND NON -BINDING FRAMEWORKS CURRENTLY IN PLACE  
International legislation Non-binding frameworks 
Chemical threats 
The Convention on the Prohibition of the 
Development, Production, Stockpiling and 
Use of Chemical Weapons and on their Destruction (the Chemical Weapons 
Convention – CWC)  
Global Harmonised System of 
Classification and Labelling of Chemicals 
(GHS)  The NATO International Task Force (ITF-
25)  
 
Biological threats  
The Convention on the Prohibition of the 
Development, Production and Stockpiling of Bacteriological (Biological) and Toxin 
Weapons and on their Destruction 
World Health Organisation (WHO) norms 
and standards 
World Organisation for Animal Health 
(OIE) norms The Australia Group 
Radiological and nuclear threats  
International Atomic Energy Agency  
The IAEA Convention on Nuclear Safety  
The IAEA Convention on Early 
Notification of a Nuclear Accident  
The IAEA Convention on the Physical 
Protection of Nuclear Material 
The IAEA Convention for the Suppression 
of Acts of Nuclear Terrorism 
The Emergency Notification and 
Assistance Convention (ENAC) 
The IAEA Convention on Assistance in the 
Case of a Nuclear Accident or Radiological Emergency 
The Joint Convention on the Safety of 
Spent Fuel Management and on the Safety of Radioactive Waste Management 
Regulations for the Safety Transport of International Atomic Energy Agency
 
Code of Conduct on the Safety and 
Security of Radioactive Sources, and supplementary Guidan ce on the Import and 
Export of Radioactive Sources 
Code of Conduct on the Safety of Research 
Reactors 
Guidance on the import and export of 
radiactive sources 
Safety Requirements on Preparedness and 
Response to a Nuclear or Radiological 
Emergency 
Guidance and considerations for the 
implementation of INFCIRC/225/Rev.4, 
The Physical Protection of Nuclear Material and Nuclear Facilities 
 
 
EN 129   EN Radioactive Materials 
United Nations  
The Non-Proliferation Regime (NPR): 
Treaty on the Non-Proliferation of Nuclear 
Weapons (NPT), a number of related acts 
(e.g. Resolution No. 1540), etc. 
United Nations  
International Carriage of Dangerous Goods 
by Road (ADR) Regulations 2007 
International Carriage of Dangerous Goods 
by Rail (RID) Regulations 
International Carriage of Dangerous Goods 
by Inland Waterway (ADN) Regulations  
 
European legislation and non-binding frameworks33 
Chemical threats  
Council Directive 96/82/EC of  9 December 1996 on the cont rol of major-accident hazards 
involving dangerous substances (Seveso II)  
2006 Regulation concerning the registration, evaluation, authorisation and restriction of 
chemicals (REACH)  
Biological threats  
Directive 2000/54/EC to guarantee a better st andard of safety and health for workers 
exposed to biological agents at work 
Council Directive 82/894/EEC on the notification of animal diseases and its impact on 
humans 
Council Directive 2000/29/EC on protective measures against the introduction into the 
Community of organisms harmful to plants or plant products and against their spread within the Community 
Radiological and nuclear threats  
Council Directive 2003/122/Eura tom of 22 December 2003 on the control of high-activity 
sealed radioactive sources and or phan sources (HASS Directive)  
Council Directive 96/29/Euratom of 13 May 1996 laying down basic safety standards for 
the protection of the health of  workers and the general public  against the dangers arising 
from ionizing radiation ("Basic Safety Standards” Directive / BSS Directive)  
Council Directive 2006/127/Euratom of 20 November 2006 on the supervision and control 
of shipments of radioactiv e waste and spent fuel  
                                                 
33 For a comprehensive CBRN inventory, see the Council document 10382/08. 
 
EN 130   EN Council Regulation 93/1493/ Euratom of 8 June 1993 on shipments of radioactive 
substances between Member States („Shipme nt of Radioactive Su bstances” Regulation) 
Council Directive 89/618/Euratom: on informing the general public about health 
protection measures to be applied and steps to be taken in the event of a radiological 
emergency 
Cross-cutting threats  
Framework Directive 2008/68/EC of 24 September 2008 on the inland transport of 
dangerous goods 
Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to 
encourage improvements in the safety  and health of workers at work. 
Regulation (EC) No 2320/2002 of the European Parliament and of the Council of 16 
December 2002 establishing co mmon rules in the field of  civil aviatio n security 
Regulation (EC) No 622/2003 of 4 April 2003 laying down measures for the 
implementation of the common basic standards on aviation security. 
The EU Action Plan on Combating Terrorism The European Programme for Critical Infrastructure Protection (EPCIP) 
 
EN 131   EN ANNEX 4: FIRST SCREENING OF IDENTIFIED CBRN  ACTIONS TO BE UNDERTAKEN  
1) Actions applicable to CBRN prevention, detection and response 
The following four tables present the outco mes of the first screening exercise. Actions identified through the work of the CBRN  Task force and to be 
included in the CBRN Action Plan, are divide d by strand, namely 1) Actions applicab le to CBRN prevention, detection and respons e; 2) Prevention; 3) 
Detection and 4) Preparedness and Response.34  
No. Policy action First screening Strong stakeholder 
supportPositive overall effects Low financial costs High EU added value / 
rationaleNo subsidiarity / 
proportionality issues
0. Implementing the Action Plan 
B.0 The EBN (European Bio-Network) should be created in order to support 
the implementation of the Action Plan. EBN would be a structure which 
would pull together European e xpertise on bio-preparedness from 
different sectors – research community , private sector and public sector 
(including the security and intelligence community). Its role would be to 
develop guidelines and codes of c onducts for researchers concerning 
materials and resources for education about effective and secure bio-
standards and best practices. The Network would promote and support 
development of bio-standards at EU level. Unfeasible 
Stakeholders did not support this action which raises proportionality and subsidiarity issues. 
Creating a new European Bio-Network to support the implementation of the Action Plan, to pull 
together expertise, to devel op guidelines and codes of conduct and to promote and support the 
development of bio-standards woul d take the form of a formal and permanent body at the EU 
level. This would necessitate th e setting up of a whole administrative and managerial structure, 
leading to financial and responsibility issues and concerns. In addition, su ch a body would be a 
duplication of existing structures. Finally, most of the actions foreseen within this network 
should be the responsibility of Member States to  define, develop and implement them according 
to their own experiences and structures.    
X X     
1. Enhance international cooperation 
H.01 The Member States and the Commission should continue to strengthen the 
international exchange of good pr actices with external partners 
concerning staff-awar eness and training. Uncontroversial  
The further development of excha nge is positive, as it will allow in particular Member States 
with less experience and capacity to learn from ot her Member States or third countries which are 
more advanced in this area. X X X X X 
                                                 
34 The actions applying to the horizontal st rand are marked by the letter H, chemical strand – letter C, biological strand – lett er B, radiological/nuclear strand – letter RN. 
 
EN 132   EN H.02 The Member States and the Co mmission should, where appropriate, 
exchange information on their partic ipation in various international 
forums and should strive towards coor dination of positions in order to 
ensure that common EU objectives are achieved Uncontroversial 
The economic costs of this action would be very  low, and would at the same time help to 
strengthen the common EU approach towards terro rism. The EU is also well placed to ensure 
increased knowledge and information sharing. .   X X X X 
2. Improve communication with the public 
H.03 The Member States and the Commission should regularly organise 
meetings of communication specialists from the Member States dealing 
with security issues (in particul ar CBRN events) with a view to 
encouraging the spread of good practices concerning communication 
strategies. Uncontroversial 
The exchange of good practices of communicati on strategies is positive, as it will allow in 
particular Member States with less experience to learn from other Member States which are 
more advanced. It will also help Member States  to develop common approaches, should this be 
considered useful.  X X X X X 
H.04 The Member States and the Commission should review existing 
international guidelines and incorpor ate appropriate existing procedures 
or, when needed, should establish new guidelines for the development of 
security communication strategies  involving CBRN incidents, which 
could be integrated with ex isting emergenc y planning and 
communications strategies, and woul d involve all relevant agencies. Uncontroversial 
The compilation of existing international guidelin es and procedures in a revised or renewed 
format is positive as it will allow an update of  the existing information and a good reference 
material for relevant agencies to define their communication strategies. It will also help to 
identify possible gaps and inconsistencies.  X X X X X 
H.05 Each Member State should look into  the practical implementation of the 
good-practices on public and media relations identified in a joint effort by the Commission, Europol and the Member States. Uncontroversial 
Making use of existing validated good practi ces on communication with the public and the 
media is positive, as it will build on proven expertis e and allow in particular Member States with 
less experience to learn from other Member Stat es which are more advanced in this area.  X X X X X 
C.01 The Member States and the Commission should establish guidelines for 
the development of chemical security communication strategies Uncontroversial 
Establishing guidelines for the communication strategies is positive as it will support the 
development of communication strategies at th e national level which follow a common approach 
to the management of public crises.  X X X X X 
B.01 Member States and relevant orga nisations should develop awareness and 
crisis communication strategies for th e public living close to any facilities 
possessing any of the biological agents and toxins on the EU biosecurity 
list.  Uncontroversial 
A specific communication strategy with the main aim of informing and 't ranquilising' the public 
living close to facilities processing biological agen ts and toxins on the EU priority list is 
beneficial, as in the case of an incident their be haviour will be key in order to reduce the spread 
(if any) to other areas.  X X X   X 
3. Develop improved information tools for CBRN security 
H.06 The Commission should establish a system in which good-practices on 
security could be shared. The use of existing systems should be explored 
in this regard. Uncontroversial 
A system to exchange good practices on security is positive, as it will allow in particular 
Member States with less experience to easily access information from other Member States 
which are more advanced in this area.  X X X X X 
H.07 The Commission should establish a library of resources which could be 
used by the relevant authorities (i n particular the law enforcement 
community and public health authoritie s). Such a library would contain 
applicable information about the natu re of CBRN agents and how to deal 
with them. This library could incl ude national contributions from the 
Member States. Uncontroversial 
The establishment of a library of resources is  positive as it will give single access point to a 
source of information on the all the CBRN agen ts, which will be constantly updated with the 
experience of Member States. The need to secure the library is  to be considered.  X X   X X 
 
EN 133   EN H.08 The Member States and the Commission should establish a law 
enforcement Early Warning System (EWS) for CBRN related incidents, 
taking account of existing systems and experiences and based on 
established common European lists of the most high-risk CBRN 
materials. Such a mechanism woul d include information on immediate 
threats, losses/thefts, and suspicious  transactions and would in any case 
need to be accessible to the law enforcement authorities and relevant 
emergency responders of the Member States and to Europol. As a first 
step, the extension of the existing G6 system should be considered. The 
system should be without prejudice to the exchange of information on 
public health issues. To be assessed in detail   X   X   
4. Improve training 
H.09 The EOD Network should address the need for developing minimum 
standards of CBRN training for EOD sp ecialists. The applicability of the 
standards developed by the EDA to the non-military context may be assessed in this regard. Training shou ld be provided to EOD personnel in 
terms of contacting relevant CBRN speci alists and on forensic awareness. Uncontroversial 
This action is positive as it aims at ensuring th at EOD specialists will be properly trained to 
respond to CBRN issues. Making use of existing standards, or work on existing standards, in particular those developed by the EDA for the military contex t and adapted to the civilian 
context, will avoid duplication of efforts and help to develop targeted training.  X X X   X 
H.10 The Member States should ensure that CBRN information, including on 
EOD matters, is integrated into tr aining programmes for relevant first 
responders and local authority personnel. The Member States and the 
Commission should ensure that em ergency response personnel receive 
training concerning available modelling tools. Uncontroversial 
It is very positive to ensure that CBRN informati on is included in the trai ning of first responders 
and local authority personal as their actions w ill have an important impact on the immediate 
response as well as on investigative and forensic activities.  X X   X X 
C.02 The Commission should provide suppor t for the organisation of specific 
HazMat specialist trainings. Uncontroversial 
Supporting the organisation of traini ng of HazMat specialists is pos itive as it will ensure that the 
training targeted at handling and dealing with sp ecific chemical substances is of high quality.  X X  X X  X 
C.03 The Member States should organise regular exercises concerning the 
security of chemical facilities in orde r to test preparedness measures in 
place and raise awareness among staff. To be assessed in detail X X       
B.02 Member States and the Commission should identify and spread:  
• Good practices on well targeted traini ng for and education of individuals 
working with, having access to or hand ling biological agents and toxins 
on the EU biosecurity list;  
• Good practices on academic training on biosafety, potential misuse of 
information and biological agents and toxins, and bio-ethics for 
undergraduate, graduate and postgraduate students;  
• Good laboratory practices. Uncontroversial 
Identifying and disseminating good practices on tr aining and education within academia and 
laboratories will ensure a more harmonised appr oach in the EU Member States and enable 
counties with little experience in this  area to learn from their peers.  X X X X X 
B.03 Member States and the Commission should consider and develop:  
• Guidelines at the EU level for minimum training requirements for 
persons working with, having access to, or handling biological agents and 
toxins;  
• In conjunction with universities and professional associations, minimal 
requirements for academic training on biosafety, potential misuse of 
information and biological agents and toxins and bio-ethics for 
undergraduate, graduate a nd postgraduate students. To be assessed in detail X X   X   
5. Strengthen personnel security 
 
EN 134   EN H.11 Member States and the Commission should analyse the need to establish a 
system of mutual recognition of s ecurity vetting processes for certain 
categories of personnel. Uncontroversial 
Analysing the mutual recognition per se  would be positive as it would be a step forward towards 
assessing the need for a more harmonised approach  towards security vetting and thus ensuring a 
greater ‘security level playing field’ across the EU.    X  X X X 
H.12 The Member States and the Commission should develop and introduce 
common graduated criteria fo r background checks and vetting 
requirements in relation to personnel having access to high-risk CBRN 
materials along the whole chain of pr oduction, storage, distribution and 
use. This should be done based on the establishment of a common 
European list of the most high-ri sk CBRN materials. These common 
criteria should be based on a graduated approach. In the course of the 
recruitment process, the recruiting organisation should ensure that the 
credentials of the candidates are properly checked and assessed. The 
Commission should launch a study concerning existing background check 
procedures and requirements within the CBRN industry. To be assessed in detail       X X 
H.13 The Member States and the Commissi on should identify and exchange 
good practices on approaches to secu rity of non-EU visiting staff and 
students; Member States should aim at common procedures across the 
EU. To be assessed in detail X   X X   
C.04 The Member States and the Commi ssion should identify and exchange 
good practices on robust management structures at commercial, industrial 
and research facilities possessing high -risk chemical agents ensuring 
regular appraisal of the staff and its monitoring Uncontroversial 
The identification and exchange of good practices  on robust management structures is positive, 
as it will allow in particular Member States with  less experience and capacity  to learn from other 
Member States or third countries which are more advanced in this area. Appraisals should in 
particular identify whether staff is put under pre ssure by third parties, whether their ideas are 
radicalising, etc. They could also be linked to re gular renewals of security clearance, and random 
checks, particularly to verify whether a person so employed has a 'change of circumstances'.  X X X X X 
B.04 Member States should ensure that Each Member State and/or organisation 
has a secure registry of personne l having access to or information on 
biological agents and toxins on the EU biosecurity list (along the whole 
chain of production, storage, distribution and use). Law enforcement 
should have access to such a registry.  To be assessed in detail       X X 
B.04a Developing mandatory professional c ode of conducts at EU level Unfeasible 
Stakeholders did not support the development of  mandatory professional codes of conduct at the 
EU level. They expressed their views that self -regulation might be better in this sense. In 
addition, they stressed Member States' responsibility  to ensure of the professionalism and ethic 
of people handling biological substances.    X X     
B.05 The Member States and the Commi ssion should identify and exchange 
good practices on robust management structures at commercial, industrial and research facilities possessing biologi cal agents and toxins on the EU 
biosecurity list ensuring regular appraisal of the staff and its monitoring. Uncontroversial 
The identification and exchange of good practices  on robust management structures is positive, 
as it will allow in particular Member States with  less experience and capacity  to learn from other 
Member States or third countries which are more advanced in this area. Appraisals should in particular identify whether staff is put under pre ssure by third parties, whether their ideas are 
radicalising, etc. They could also be linked to re gular renewals of security clearance, and random 
checks, particularly to verify whether a person so employed has a 'change of circumstances'.  X X X X X 
 
EN 135   EN 6. Strengthen and prioritise research 
H.14 The Member States and the Commis sion should improve the aggregation 
and spread of research results both at EU level as well as at national level 
across the EU Member States. For unclassified materials, this should be done by way of organising confer ences and setting up a dedicated 
research web-portal (for all of CBRN  security) which would contain a 
summary of the relevant research pr ojects and contact information where 
further details can be obtained, as we ll as opportunities for future research 
collaboration and work. Uncontroversial 
Improving aggregation and dissemina tion of research and especially for unclassified material, 
will give a single access to existing research, stat e of the art and prospects for new research, 
bringing together the work of researchers thr oughout the EU. The action will also help to focus 
research on the most relevant issues and to ensure increased European cooperation. The cost / 
benefits of this action would need to be assesse d, given that conferences and a web-portal could 
require medium initial investments.  X X   X X 
H.15 The Member States and the Commission should engage in further 
research cooperation with international partners with a view to enhancing 
synergies and avoiding duplications. The research work performed by the 
European Defence Agency and the J RC as well as the recommendations 
to be made by the European Security Research and Innovation Forum (ESRIF) should be fully taken into  account in these efforts. The 
Commission should organise periodi c meetings of CBRN experts, 
including specialists from other partner countries, in order to share and 
spread good practices on CBRN issues. The results of these meetings 
should be collected and the disseminated among the Member States. Uncontroversial 
Fostering research and cooperation in the research field with the EDA and the JRC as well as 
integrating the work of the ESRIF is important and positive to take the most out of the existing 
work performed at the international level and to ensure a cross-border perspective to the 
research. The sharing of information on the m eetings of CBRN experts will further help to 
inform Member States and to encourage them  to engage in furthe r research cooperation.  X X X X X 
H.16 The Member States and the Commission should improve the use of 
existing scientific networks to e nhance work in the detection area. Uncontroversial 
Improving the use of existing scient ific networks is positive in order to make the most out of 
existing techniques and to avoid duplication of ef forts. It would be important to first map the 
existing networks in this area, in terms of their coverage, specific focus / features, etc.  X X X X X 
H.17 The Commission should launch a study on the necessity and impacts of 
assessing scientific research and scien tific publications against security 
aspects.  Uncontroversial 
Launching a study on the necessity and impacts of assessing scientific research and scientific 
publication is a useful action whic h will allow determining the state of the art, the gaps and the 
needs.  X X  X X X 
H.18 The Member States and the Commission should encourage funding 
organisations (be it public or private) to take security aspects of proposed 
research projects and other publications into account, as well as the 
suitability of the funds receiver (f rom both a safety and a security 
perspective) to work on the research the receiver is proposing. Best 
practices of funding organisations should be identified and exchanged 
across Member States. To be assessed in detail X     X X 
C.05 The Commission and the Member States should support research into the 
following areas:  
• Prevention:  1. Development of low-risk altern atives to high-risk chemicals.  
• Detection: 
1. Ensuring interoperability  and network applicati on of detection devices 
in view of joint team operations; 2. Improving the presentation of detec tion results in a way that they can 
easily be understood by end-users, particularly first responders; 
• Response: 1. The potential psychological effect of CBRN emergencies on the 
population and the likely reactions of local populations in case of Uncontroversial  
Supporting research in the mentioned areas is  positive as it will ensure looking into new 
possibilities and alternatives to chemicals, deve loping new capabilities especially in the case of 
joint operations, further developing crisis ma nagement and new detection technologies. The 
earlier actions aimed at mapping existing research and sharing of information on research (e.g. 
H.15) will help to identify what has already been done in the areas listed.  X X   X X 
 
EN 136   EN incidents 
• Technology research: 1. Further miniaturising detection equipment, which should combine 
various capabilities in one device.  
2. The development of transportabl e equipment which can be used by 
emergency responders in the field. 
B.06 The Commission and Member States should enhance:  
• Research on capabilities for respons e and recovery from biological 
incidents;  • The understanding of and research in emergency logistics and 
distribution operations (e.g., of medicines) at the regional, national and 
international level. Uncontroversial 
Increasing funding to research will benef it overall response and recovery capabilities. 
Increasing understanding of emerge ncy logistics and distribution operations will increase the 
chances of successful response and recovery in ca se of a real incident. Again, the earlier aimed 
at mapping existing research and sharing of info rmation on research (e.g. H.15) will help to 
identify what has already been done in the areas listed.  X X   X X 
B.06a All scientific publications should be assessed by peer reviewers before 
their publication Unfeasible 
Stakeholders did not support the review by peers of all scientific publications. A first concern is 
that peer review might have a negative imp act on research: it might for example prevent 
researchers to investigate areas considered by so me, and not by others, as being dangerous if the 
information was to fall into wrong hands. This c ould either stop the research on some areas or 
develop "illicit" and secret research . In addition, this kind of peer  review might raise concerns as 
to its compatibility with fundamental rights such as freedom of science and speech by preventing 
researchers to publish their fi ndings. Finally, it is not clear what further consequences and 
actions there would be in case a peer reviewer raises security concerns.      X     
B.06b Publications of studies with sensitive biological dual-use research in two 
versions (public and restricted version) Unfeasible  
Stakeholders showed little support for this option.  The first point raised was that it would be 
overall impossible to conduct such a procedure in pr actice. This is in particular the case when a 
body or structure would need to  be delegated the responsibility to decide on the issue. This 
would need to be agreed by all Member States  and might raise proporti onality and subsidiarity 
issues. In addition, this action might also raise c oncerns as to its compatibility with fundamental 
rights, such as freedom of speech and access to information.           
RN.01 The Commission and the Member States should support research into the 
following areas:  
• Detection:  1. Detection and identification of diff icult to detect radioactive sources 
and nuclear materials;  
2. Detection and identification of  masked and shielded sources 
3. Improving spectrometry based dete ction and addressing the problems 
of "innocent" and false alarms 
4. Detection and location of ra diation source in large crowds; 
• Response: 
1. The potential psychological effect of CBRN emergencies on the 
population and the likely reactions of local populations in case of incidents, and possible action-oriented responses;  2. The further development of nuclear forensics;  
3. The development of radiological forensics 
4. Guidance on storage of contaminat ed evidence for an extended period 
of time;  
5. Guidance on the disposal of contaminated materials;  
6. Particle size distribution and pot ential chemical composition changes Uncontroversial  
Increasing research will benefit overall detecti on, response and recovery capabilities. Mapping 
existing research and fostering European coopera tion in this area, as proposed in the actions 
above (e.g. H.15) will help to identify gaps and opportunities. Evidence suggests that indeed 
current detection technologies and equipment are in sufficient with regard to radioactive sources. 
Contamination and disposal of ra diological materials is also an area which would require further 
EU efforts, especially because such activities are very costly and many Member States cannot 
bear such costs alone. Finally, undertaking resear ch into new technologies will also help to 
improve control, monitoring and detection capacity and capability. X X    X X 
 
EN 137   EN following an explosion.  
7. Other gaps identified base d on a risk-assessment process 
• Technology research:  
1. Detection technologies and electr onic tracking systems for radioactive 
sources;  2. Integration of differe nt technological solutions [address the current 
status when numerous devices are required for detection];  
3. Improving detection software;  4. Enhance mobility and portab ility of detection solutions.  
5. The development of transportabl e equipment which can be used by 
emergency responders in the field (i ncluding neutralisa tion and detection 
equipment for bomb squads);  6. Decontamination equipment; 
7. Ensure the criminalisation of acts  involving high-risk CBRN materials 
H.19 The Commission should analyse the penal legislation enacted in the 
Member States concerning CBRN terro rism, in order to assess whether 
any further work at EU level is necessary. Uncontroversial 
Analysing the penal legislation enacted in Member  States will be positive in order to focus the 
work of the EU on potential gaps and cross-bo rder issues. It will also help to formulate 
proposals to further harmonise pe nal legislation, where possible,  making sure that CBRN illegal 
acts are adequately criminalised throughout the EU.  X X X X X 
 
2) Prevention strand 
No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
1. Develop EU lists of high-risk CBRN materials and risk-based approaches to security 
H.20 The Member States and the Commission should establish and regularly 
update EU lists of:  
• high-risk chemical agents;  
• biological agents and toxins (biosecurity list);  
• high-risk radioactive sources;  
of special security concern. 
 
These lists should be developed based on a risk assessment analysis. This 
process should include the following steps: 
o Identifying and analysing relevant CBRN materials; 
o Assessing its potential for being used for malicious purposes; To be assessed in detail       X X 
 
EN 138   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
o Selecting the most dangerous material in terms of its potential for 
being used for malicious purposes;  
o Assessing its vulnerability in term s of theft/loss (ease of obtaining 
them); 
o Establishing possible preventive measures: physical / technical and 
administrative; 
o Carrying out a cost / benefit study on these possible measures. 
H.21 The Commission should: 
• establish fora for EU level dialogue  between relevant authorities in the 
field of CBRN risk-management in or der to take cross-border threats 
fully into account in national and EU  planning processes. This should 
allow the attainment of a common understanding among the Member 
States and the Commission of th e risks faced by the entire EU. 
• facilitate the exchange of best -practices concerning CBRN risk-
management by organising regional /EU level meetings and channelling 
funding toward the development/id entification/implementation of 
suitable methodologies Uncontroversial 
Fostering cross-border cooperation via fora for EU  level dialogue is positive to move towards a 
more harmonised understanding of the risks faced by  the EU. The exchange of best practices is 
positive to go beyond existing bilateral agre ements in terms of risk management.  X X X X X 
RN.02 The Member States should ensure that law-enforcement authorities keep 
the operators of facilities in which high-risk radioactive sources are 
present informed on a need-to-know basis about potential threats. If no system exists, each Member State should consider establishing a 
communication mechanism in order to quickly transfer security related 
information to security managers  in facilities in which high-risk 
radioactive sources are handled. Uncontroversial 
Ensuring that information is adequately distributed  to operators of facilities is very positive as it 
will enhance security of the facilities. It will par ticularly be important to  ensure that they are 
aware of potential threats and are part of a sy stem of information on security of high-risk 
radioactive materials.     X  X X X 
2. Enhance the security of CBRN materials and facilities 
H.22 The Member States and the Commission should develop criteria on 
assessing security arrangements at  high-risk CBRN facilities. This 
should be done in the form of a good practice document. To be assessed in detail     X X X 
C.06 The Member States should ensure that relevant authorities engage in 
dialogue with the relevant site secur ity managers and advise operators on 
the necessary levels of security. Member States should encourage the 
establishment of trusted relationships  between security managers and law 
enforcement counterparts. Uncontroversial 
Increasing dialogue and relations between relevant security actors is positive in order to ensure 
exchange of information and experience. This will help to improve th e prevention and response 
to incidents, making sure that security mana gers and law enforcement counterparts know whom 
to contact and what to do.  X X X X X 
C.07 The Member States should ensure that security plans/security 
management systems are in place in high-risk chemical facilities. The 
security plans should provide for gra duated levels of security based on To be assessed in detail   X   X   
 
EN 139   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
the existing threat level. Member St ate authorities should be involved in 
assessing whether these security plans satisfy the necessary level of 
protection requirements. 
C.08 The Member States should:  
• Ensure that the responsibilities of th e operator and the State in terms of 
security of facilities should be clearly defined. 
• Ensure that local law enforcemen t authorities possess information on 
high-risk chemical f acilities in their area. Uncontroversial 
Ensuring the definition of roles of operators a nd the State for the security of facilities and 
ensuring that information on high-risk chemical  facilities is known by local law enforcement 
authorities is positive as it is a prerequisite to en sure that the security of  chemical materials and 
facilities is enhanced. Clear links will need to be made to safety issues.  X X X X X 
C.09 The Member States and the Commis sion should ensure that the chemical 
industry develops and implements the security side of the Responsible 
Care programme. Uncontroversial 
Ensuring the development and implementation of the security side of the Responsible Care 
programme is positive as it will allo w progress on existing basis and avoid duplication of efforts. 
In addition, this action is positive as it build s on voluntary action of the chemical industry.  X X X X X 
C.09a The Commission should investigate gaps with regard to the delivery 
documentation mechanism established under the Responsible Care 
programme. Unfeasible  
Stakeholders showed little support for this action Their main concern was that there is no need 
for such an investigation and this will not be useful.   X X   X 
C.10 The Member States and the Commission should develop a high level 
approach to chemical facility secu rity which identifies key objectives 
and steps to be taken in order to increase security, based on national risk 
assessment approaches. To be assessed in detail  X X       
C.11 The Member States and the Commission should encourage industry to 
replace, where possible, the use of high-risk chemicals with suitable 
lower-risk alternates. The potential use of the REACH framework or of 
separate, more specific legislation shoul d be examined in this regard as 
well, in close coordination with th e authorities competent for chemicals 
of the Member States. Uncontroversial 
Using suitable lower risk alternatives is very positive, as it would reduce the risks of certain 
industrial processes and products. Some considerable  work has already been undertaken in this 
area by the industry itself and is being worked on within the REACH framework: these could me 
a relevant basis to work from and enhan ce the development of alternative solutions.  X X   X X 
C.12 The Commission should bring together  the relevant security authorities 
from the Member States in order to  identify good practices concerning 
the security of high-risk chemical facilities. Based on this work, the 
Commission should develop a good pr actice document addressing such 
issues as: 
• The responsibility of an authority to  assess the security measures in 
place for various types of materials; 
• Creating varying levels of security measures adapted to the risk posed 
by particular chemical agents, amounts of certain materials or combinations of materials. These security measures should address inter 
alia: background checks for personnel, physical security measures and Uncontroversial 
The identification and developmen t of good practices is positive, as it will allow in particular 
Member States with less experience and capacity to learn from other Member States or third countries which are more advanced in this area . It is also highly positive to adapt security 
measures to the risks, as only facilities using high quantities of high-risk substances or certain 
combinations of substances would require a ma ximum security level. Others may require less 
rigid (and costly) measures.  X X  X X X 
 
EN 140   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
information security.  
C.13 The Commission should launch studies on:  
• the applicability of existing safety  provisions to enhancing security. 
• training requirements for inspection and enforcement entities, so that 
they can provide the highest possible levels of relevant security expertise. Uncontroversial 
Studies on the applicability of existing safety  provisions which could also contribute to 
enhancing security and on training requirements for inspection and enforcement entities are a 
useful action which will allow determining the state of the art, the gaps and the needs.  X X X X X 
C.14 The Commission should accelerate its work to support enhancing the 
protection of SCADA systems against cyber-attacks. Uncontroversial 
This action is positive as cyber attacks in partic ular in relation to illegal and terrorist use of 
information is increasing.  X X   X X 
B.07 The Commission should assist Memb er States in proper implementation 
of applicable procedures at "the  laboratory bench level" and in 
developing mechanisms for assessing and monitoring its correct 
implementation. Uncontroversial 
EU level assistance with the implementation of a pplicable legislation will be highly beneficial, as 
it will help to ensure a harmonised approach in  the Member States. The same applies to the 
development of mechanisms for assessing and m onitoring implementation - Member States will 
receive useful feedback on their strengths and weaknesses as well as concrete suggestions for 
improvements.  X X  X X   
B.08  The Member States should establish:  
• A secure registry of facilities posse ssing any of the biological agents 
and toxins on the EU biosecurity list within each Member State while 
allowing access to law enforcement;  
• A process to verify and if necessa ry to enhance security arrangements 
of facilities, including diagnostic  laboratories hand ling and possessing 
any of the biological agents and t oxins on the EU biosecurity list.  
• A mechanism within facilities storing biological agents and toxins on 
the EU biosecurity list to regularly review the need of such biological 
agents and toxins while keeping a good record of stored materials;  To be assessed in detail   X   X X 
B.08a Introduce the accreditation of a specific and limited number of 
laboratories, health institutions, and production establishments on the 
basis of compliance with mi nimum security standards. Unfeasible  
Stakeholders did not support this action. They firs tly raised the issue of co sts associated to this 
additional accreditation. In addition,  they stressed the fact that existing national authorisations 
and standards already provide minimum security standards and to a certain extent correspond to 
an accreditation scheme. This action would lead  to an unnecessary duplication of efforts.   X    X 
B.09 The Commission and the Member States should support: 
• A process whereby facilities (clinical , diagnostic, university, etc) would 
avoid keeping clinical samples cont aining any of the biological agents 
and toxins on the EU biosecurity list unnecessarily; • The identification and development of good practices on handling 
clinical samples containing any of th e biological agents and toxins on the Uncontroversial 
Supporting Member States in those areas will be ve ry beneficial to prevent access to substances 
which are on the biosecurity list. Facilities shoul d be allowed to handle dangerous biological 
agents and toxins only with specific authorisati on. Establishing good practices on when facilities 
should be allowed access is beneficial, as it will increase clarity, make facilities aware of the 
dangers and reduce the risk of samples being 'lost'. The establishment of a wide network X X   X X 
 
EN 141   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
EU biosecurity list;  
• Progress in creating collaborative ne tworks of facilities working on the 
biological agents and toxins on the EU biosecurity list while taking into 
account existing networks; involving all relevant facilities and laboratories could contribut e to increased cooperation and 
exchanges of good practices and experiences in general.  
B.10 The Commission and the Member States should ensure that: 
• A comprehensive overview of the re levant standards at hand and their 
relevance to biosecurity and biosafety is achieved; • Facilities possessing biological agents  and toxins on the EU biosecurity 
list consider as appropriate the implementation of the CEN Workshop 
Agreement (CWA 15793), WHO Laboratory Biosecurity Guidance or their national equivalent standards; 
• Appropriate standards are met as pa rt of a national authorisation or 
accreditation process or as a condition for issuing licences for work with 
biological agents and toxins on the EU biosecurity list. Regular control 
over the adherence to and implementa tion of such standards should also 
be ensured. Uncontroversial 
The establishment of a comprehens ive overview of existing standards is a useful exercise to map 
all what exists, to avoid duplication of efforts and to agree on the most relevant standards. It will 
indeed be beneficial if facilities will consider th e implementation of standards set at international, 
EU or national level. Security standards should be an integrated component of authorisation, 
licensing and accreditation processes, as this will ensure that they are taken into account by 
facilities from the very start. The Commission a nd the Member States should closely follow both 
the adoption and the implementation of standards, in order to ensure some form of harmonised 
approach.  X X X X X 
RN.03 The Member States and the Comm ission should analyse potential gaps 
and, if needed, propose solutions with regard to security requirements for facilities in which certain high-risk  sources are manufactured and/or 
disposed of (and which are located  outside of nuclear facilities). Uncontroversial 
Improving the security requirements of the fac ilities manufacturing and/or  disposing high-risk 
sources, based on an gap and need analysis, is pos itive as it will reduce the ri sks of loss or thefts 
of those sources.  X X   X X 
RN.03
a The Commission should bring together the relevant authorities from the 
Member States in order to identify good practices concerning the 
physical protection of various categories of sources. Based on this work, 
the Commission should develop a good practice guideline addressing 
such issues as:  
1. The responsibility of an authority to assess the security measures in 
place for various types sources;  
2. Linking the results of the above mentioned security assessment to the 
licensing/registration procedure;  
3. Creating varying levels of security measures adapted to the risk posed 
by particular radioactive sources, amounts of certain sources or 
combinations of sources. These security measures should address inter 
alia: background checks for personnel, physical security measures and 
information security.  Unfeasible 
This action received little support from stakeholders . Most of the guidelines were said to have 
already been developed within the IAEA. This action would therefore lead to duplication of 
efforts. In addition, they stressed the lack of need to have this type of work at the EU level: it 
should be the Member States' responsibility to en sure the security of radiological and nuclear 
facilities and materials.   X X   
RN.04 The Member States and the Commission should conduct an analysis of 
the feasibility of linking security vetting/background check requirements Uncontroversial 
An analysis of feasibility will be very positive as  a first step to assess the possibilities of linking X X  X X X 
 
EN 142   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
to existing licensing systems used to authorise the handling of high-risk 
radioactive sources. security vetting/background check requirements to existing licensing systems.  
3. Enhance control over CBRN substances 
C.15 Member States and the Commission should make sure that where this 
does not take place already today, the chemical industry ensures that in 
line with international obligations, high-risk chemicals and equipment 
are only delivered to legitimate user s. A sufficient customer qualification 
scheme should be established in this regard, which is proportionate to the 
risk and cost effective. The risks as sociated with trade of chemicals over 
the Internet should be investigated further.  Uncontroversial 
Ensuring that the chemical industry delivers high-risk chemicals and equipment only to 
legitimate users is positive as this is crucial to ensure control over the us e of the substances and 
would limit their possible use and transformation by  terrorist organisations. It would be important 
indeed to learn from successful schemes already in place in Member States . Indeed, the internet 
is a growing area of concern, and it would be important to look at the risks this medium represents.  X X X X X 
C.16 Member States and the Commissi on should assess the benefits of 
establishing and if needed should consider creating a licensing scheme 
for certain high-risk chemicals (in particular for certain CWA 
precursors) similar to that existing fo r certain scheduled substances in the 
framework of the Drug Precursors Regulation. For chemicals covered by the CWC, the CWC licensing scheme should be considered as meeting some or all of the set-out objectives.  Uncontroversial 
Assessing the benefits of establishing a licensing scheme for high-risk chemicals is positive as it 
will assess the costs and benefits of establishing such a system before its potential development. 
The Drug Precursors Regulation provides a good star ting point, given that the substances are 
often similar.  X X X X X 
C.17 The Commission should perform a feasibility assessment on the 
possibility of using the delivery do cumentation mechanism to better 
understand and monitor the supply chain (possibly link it to tracking and tracing).  Uncontroversial 
A feasibility assessment on those issues will be very positive as it will assess the possibilities, 
costs, benefits and consequences of providing a new mechanism to mon itor the supply chain, 
before potentially and eventually launching such as mechanisms.  X X X X X 
C.18 The Commission should launch a st udy concerning the availability of 
certain high-risk chemicals to the general public.  Uncontroversial 
A study on the availability of high-risk chemicals to the general public is positive as it will allow 
assessing the extent to which the general public ha s access to (sufficient) high-risk chemicals. It 
would be important, again, to look at access th rough the internet or by making multiple small 
purchases, as terrorists have used  similar approaches in the past.  X X X X X 
RN.05 The Member States should ensure that national source registries contain 
information on all high-risk sources.  Uncontroversial 
National source registries with information on all hi gh-risk sources will be very useful, especially 
if held by the Member States themselves. Such  registries may already be in place in several 
countries, but the extent to which these are m onitored, controlled and regularly updated varies.  X X  X X X 
RN.06 The Member States should launch recovery programmes for disused 
high-risk sources. The launch of a so urce recovery programme could be 
coupled with the creation of a source exchange system among the 
Member States, so that recovered sources can be made available to those 
states that need them (rather th an manufacturing new sources).  To be assessed in detail   X   X X 
 
EN 143   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
RN.07 The Member States and the Commission should assess the potential and 
practicalities of establishing tracking systems for high-risk sources (e.g. 
user-accessible web-based systems;  electronic tagging of sources). Uncontroversial 
An assessment of the potential and practicalities of establishing trackin g systems for high-risk 
sources will be a very useful as a first step  before potentially establishing such a system.  X X X X X 
RN.08 The Member States and the Comm ission should identify and exchange 
good practices for commercial, h ealth care and research facilities 
possessing radioactive sour ces to ensure regular appraisal of the staff and 
its monitoring. Uncontroversial 
The identification and exchange of good practices  for facilities possessing radioactive sources is 
positive, as it will allow in particular Member States with less experience and capacity to learn 
from other Member States or third countries whic h are more advanced in this area. Appraisals 
should in particular identify whether staff is put  under pressure by third parties, whether their 
ideas are radicalising, etc. They could also be linked to regular renewals  of security clearance, 
and random checks, particularly to verify wh ether a person so employed has a 'change of 
circumstances'.  X X X X X 
RN.09 The Commission should launch stud ies on the origin and consequences 
of the loss of control over radioactive sources, on the current status of used and disused sources in the EU and on transport patterns for legal 
uses of radioactive sources. Uncontroversial 
Studies on the origin and consequences on thos e issues are a useful action which will allow 
determining the state of the art, the gaps and the needs. At this stage it is known that there is a 
high potential that sources are 'lost', i.e. di sappear from regulatory control, due to poor 
accounting and licensing.  X X X X X 
RN.10 The Commission should facilitate  the exchange of experience on 
successful strategies concerning the detection and recovery of orphan 
sources (article 9 of the HASS Directive). Uncontroversial 
The facilitation of exchange is positive, as it w ill allow in particular Member States with less 
experience and capacity to learn from other Memb er States or third countries which are more 
advanced in this area. It would in particular be useful to explore the different approaches adopted 
by the Member States to implement Article 9, as  these may vary greatly - not every country will 
have the same capacity to identify and orpha n sources, as this is also very costly.  X X X X X 
RN.11 Europol should lead an analysis of  losses and thefts of high-risk sources 
in the EU. This analysis should ta ke due account of the nature of 
particular incidents and the nature of the actual source, including orphan 
sources. It could be carried out in cooperation with the IAEA, Interpol and other relevant authorities. It shoul d be made available to the relevant 
national authorities and reviewed regularly. Uncontroversial 
An analysis of the losses and thefts or high-risk sources by Europol, and in particular jointly with 
the IAEA, Interpol and other relevant authorities,  is very positive as will mapping the nature of 
incidents and sources, covering the whole EU and making the information accessible to all 
relevant national authorities. It  would be important, where nece ssary, to secure parts of the 
analysis if this could point at specific national weaknesses, as terrorists and criminals could be 
interested in knowing these.  X X X X X 
4. Contribute to the development of a high security culture of staff 
H.23 The Member States and the Commission should identify, develop and 
spread good practices in security training and education of persons 
working with/having access to or ha ndling high-risk CBRN materials. 
Consideration should also be give n to developing EU guidelines for 
minimum security training requirements for persons working with, having access to, or handling CBRN ma terials, based on the national Uncontroversial 
Developing minimum training requirements and exch anging good practices is beneficial as it will 
ensure increased awareness of  persons working with or ha ving access CBRN materialss on 
specific security issues. It will also allow in pa rticular Member States with less experience and 
capacity to learn from other Member States or th ird countries which are more advanced in this 
area. The exercise will also help to identify gaps and future needs.  X  X  X  X  X  
 
EN 144   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
experience across the EU 27. This could be done by way of a peer 
review process through which experts from the Member States would 
visit each other with a view to learning from their experience and 
exchanging best practices in specific fields. 
H.24 The Member States should deve lop and implement specific training 
programmes for private security staff (in particular those involved in 
guarding specific sources). Uncontroversial 
Developing and implementing specifi c training programmes for privat e security staff will ensure 
the more harmonised guarding of the sources and a common approach to the security of facilities 
handling dangerous substances and materials. Trai ning certificates or other forms of proof could 
be made conditional for private s ecurity firms and staff in order to have permission / be licensed 
to guard certain sources.  X X X X X 
C.19 The Member States and the Commis sion should ensure that the chemical 
industry develops and adopts codes of  conduct concerning awareness of 
security-related issues. Uncontroversial 
The development and adoption of co de of codes of conduct is pos itive as they will contribute to 
increased awareness of security issues. The efforts and costs required will be relatively low. The 
threat of being excluded from a professional a ssociation (already used in some countries) is 
sufficient moral pressure and indeed a strong to ol to make professionals comply with a code. 
There are good examples of national code s of conduct which work very well.  X X X X X 
C.20 The Member States should implement specific security training for staff 
in industry and research, where high risk chemicals are present. Uncontroversial 
The implementation of specific security programmes for staff in industry a nd research will ensure 
a common approach to the security of  facilities handling high risk chemicals.  X X X X X 
B.11 The Commission and the Member States shall encourage professional 
and other relevant associations to de velop and adopt codes of conduct for 
their Members. Uncontroversial 
The development and adoption of co de of codes of conduct is pos itive as they will contribute to 
increased awareness of security issues. Codes of  conduct should be linked to bio-ethics and the 
possible dual use of biological standards. The th reat of being excluded from a professional 
association (already used in some countries) is su fficient moral pressure and indeed a strong tool 
to make professionals comply with a code. The efforts and costs required will be relatively low.  X X X X X 
B.12 The Commission and Member States should define requirements for 
biosafety officers (roles, competences and training). Uncontroversial 
Defining requirements for biosafety officers w ill ensure a harmonised and common approach to 
the roles, competences and training of the officer s responsible for safety of the facilities handling 
biological substances.  X X X X Possibly 
RN.12 The Member States and the Commission should use the capacity planned 
European Security Training Centre (EUSECTRA) to provide nuclear and 
radiological security related traini ng and to support and complement 
such activities at the national level. Uncontroversial 
The use of EUSECTRA is very beneficial as it will prevent duplication of work and efforts. It 
would also ensure a harmonised approach to training.  The Centre's role could mainly be to 'train 
the trainers', to assist in the development of national training programmes, etc.  X X X X X 
RN.13 The Member States and the Commissi on should engage with research 
stakeholders to raise awareness of security issues and facilitate the 
exchange of good practices on dealing with security threats. Particular To be assessed in detail X     X X 
 
EN 145   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
attention should be given to background check requirements for visiting 
researchers/students. This work shou ld lead to an increased security 
culture within the research sector. 
RN.13
a The Commission should launch a study on the implementation in the EU 
Member States of the IAEA Code of  Conduct on the Safety and Security 
of Radioactive Sources. Unfeasible  
Stakeholders did not support this action. Such  a study would indeed not be needed: it might 
require a substantial amount of time to carry out such a study which not bring added value to the 
state of the art which is already known.   X X     
5. Improve the identification and reporting of suspicious transactions and behaviour 
H.25 Member States and the Commission should:  
• identify and exchange good practices on the reporting of suspicious 
transactions in relation to CBRN materials used by private and public 
entities (e.g. industry, medical sector, research). 
• establish modalities for reporting loss or suspicious transactions while 
enhancing awareness of relevant stakeholders about suspicious 
transactions and encourage stakeholde rs to report such transactions to 
law-enforcement authorities To be assessed in detail X    X X X 
H.26 Member States and the Commission should develop guidelines for the 
industry, the medical sector and the research community containing 
criteria identifying the forms of behaviour which may give rise to 
suspicion. Member State authorities should provide guidance to 
stakeholders on what suspicious transactions are. To be assessed in detail X     X X 
6. Enhance the security of transport 
H.27 The Member States and the Commission should establish an ad-hoc 
committee of experts on transport security with regard to CBRN 
materials. This Committee should bring together experts from the 
transport sector, the security servi ces and law enforcement authorities. 
The Committee should address the following issues:  
• Assess whether existing transport security rules fully cover all CBRN 
materials. 
• Identify and exchange good practices in the Member States concerning 
the transport of high-risk CBRN mate rials (e.g. limited quantities in one 
transport; or tracking systems). 
• Identify and exchange current good practices in terms of tracking 
CBRN materials. 
• Requirements for the development of tracking and tracing systems for 
the transport of CBRN materials.  To be assessed in detail X   X X   
 
EN 146   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
• Identify and exchange good practices  concerning the implementation of 
current ADR (and RID and ADN) requirements such as the development 
of security plans.  
• Identify security requirements for logistics enterprises.  
• Consider establishing a notifica tion system for the international 
transport of CBRN materials contained in the CBRN lists (identified 
under the risk-management process) 
• Consider the feasibility and costs/be nefits of introducing a requirement 
that only licensed transporters woul d be used for the transport of 
specifically identified CBRN material s. These licensed transporters 
would be obliged to follow agreed minimum security requirements. 
The work of the Committee should feed  into existing processes such as 
the UNECE Ad-Hoc Working Group. 
H.28 The Member States and the Commission should ensure that links 
between law enforcement authorities a nd transporters of CBRN materials 
are enhanced. Uncontroversial 
Increasing the links between law enforcement authorities and transporters of CBRN materials is 
beneficial as it will enable early identification of  problems and suspicious m ovements. It will also 
clarify who has to be contacted in case of a loss, theft or other type of incident.  X X X X X 
H.29 The Member States should ensure that the training of transport staff 
concerning existing legislative requi rements on the security of CBRN 
materials is improved where appropriate. Regular exercises on transport 
security should be organised. Uncontroversial 
Any exercises concerning the secu re transportation of dangerous CBRN materials are essential, 
in particular, when involving the physical response to an incident to iron out practical delays and 
problems that can only be identified in a practical exercise.  X X X X X 
B.13 The Commission and the Member States should initiate the creation of 
an EU capability and mechanism to  rapidly and safely transport 
biological samples, in accordance with  international regulations, within 
the EU and into the EU. To be assessed in detail X     X X 
RN.14 The Member States and the Comm ission should assess the feasibility and 
potential costs/benefits of creating an electronic system for the control of 
cross-border transfers of high-risk radioactive sources. Uncontroversial 
 An analysis of feasibility will be very positive as  a first step to assess the possibilities to create 
an electronic system for control of high-risk radioactive sources.  X X X X X 
C.20a Based on a risk-management approach , each Member State should work 
toward eliminating the tr ansport of certain high-risk chemicals. This can 
be done by encouraging and suppor ting the development of relevant 
chemical manufacturing facilities at s ites which require such dangerous 
chemicals (rather than transporting them). Enhance links between law 
enforcement authorities and trans porters of chemical agents. Unfeasible 
Stakeholders showed little support for this action.  The first concerns are financial as creating 
such facilities would require substantial investme nts. In addition, creating such facilities might 
potentially be dangerous. For example, the pot ential multiplication of plants dealing with 
dangerous substances would increase the risks.       X X 
C.20.b The Commission and the Member States should establish an ad-hoc 
committee of experts on transport security with regard to CBRN Unfeasible  
These measures were highly supported by stakehol ders. Studies and exchange of good practices X X      
 
EN 147   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
materials. This Committee should bring together experts from the 
transport sector, the security servi ces and law enforcement authorities. 
The Committee should address the following issues:  
Ø Assess whether existing transport s ecurity rules fully cover all high-
risk chemicals. 
Ø Identify good practices in the Member States concerning the transport 
of high-risk CBRN substances (e.g. li mited quantities in one transport; or 
tracking systems). 
Ø Identify current good practices in terms of tracking chemical agents. 
Ø Requirements for the development of tracking and tracing systems for 
the transport of high -risk chemicals.  
Ø Identify good practices concerning the implementation of current 
ADR (and RID and ADN) requirements such as the development of 
security plans.  
Ø Identify security requirements for logistics enterprises.  
Ø Consider establishing a notifica tion system for the international 
transport of high-risk chemicals id entified under the risk-management 
process mentioned in section 1.1.  
Ø Consider the feasibility and co sts/benefits of introducing a 
requirement that only licensed transporters would be used for the 
transport of specifically identified high-risk chemicals. These licensed 
transporters would be obliged to follow agreed minimum security 
requirements. 
The work of the Committee should feed  into existing processes such as 
the UNECE Ad-Hoc Working Group. in relation to transport of chemical materials will  be very useful as a fi rst step to develop new 
measures as well as to inform those Member Stat es which have a capacity less developed in those 
areas. It was however decided to put up the meas ures for further discussions in an ad-hoc 
committee of experts covering transport s ecurity regarding all CBRN materials. 
C.20c Enhance links between law enforcemen t authorities and transporters of 
chemical agents.  Unfeasible  
These measures were highly supported by stakehol ders. Studies and exchange of good practices 
in relation to transport of chemical materials will  be very useful as a fi rst step to develop new 
measures as well as to inform those Member Stat es which have a capacity less developed in those 
areas. It was however decided to put up the meas ures for further discussions in an ad-hoc 
committee of experts covering transport s ecurity regarding all CBRN materials. X    X   
RN.15 The Commission should launch a st udy analysing whether (and how) all 
radioactive sources, and especially those identified as high-risk, are 
covered by existing legal regimes concerning transport. Depending on 
the outcome of the analysis mentione d above, the need for new transport 
rules in relation to high-risk  sources should be assessed. Uncontroversial 
Studies on the coverage of existing legal regime s concerning transport are positive as they will 
allow determining the state of the art, the gaps and the needs for new transport rules.  X X X X X 
7. Improve information Exchange 
 
EN 148   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
H.30 The Member States should analys e whether potential problem areas exist 
in the horizontal and vertical fl ow of information among the entities 
dealing with high-risk CBRN materi als sources both within and across 
the individual Member States. Each Member State should assess whether 
relevant need-to-know info rmation about changing threat levels reaches 
license holders. Uncontroversial 
Analysing the accuracy of the horizontal and ver tical information flows is positive in order to 
ensure that information is indeed communicated and in particular to the relevant persons or 
groups of persons. This is a first step to  improve the communication of information.  X X X X X 
H.31 The Member States should ensure that each party within the supply chain 
informs without delay the relevant na tional authority in the event of any 
theft or loss of any high-risk CBRN materials. The relevant national 
authorities should inform without de lay the relevant law enforcement 
authority responsible for gathering and responding to this information 
where this has not already been done by the party concerned within the 
supply chain. Uncontroversial 
Improving information flow on thef ts or losses of high-risk CBRN materials at the national level 
is positive as it will ensure relevant national and law enforcement authorities to be up to date and 
consider responses. Making supply chain parties aw are of the need to provide any information on 
thefts and losses as soon as possible is essential to ensure a rapid and appropriate response. It 
would be important to ensure that suppl y chain partners know whom to contact.  X X X X X 
H.32 The Member States should ensure a high level of information exchange 
between relevant actors by having a clearly established notification 
mechanism which would allow anyone to  inform the relevant authorities 
about a loss/theft of high-risk CBRN materials or about a suspicious 
transaction. As a minimum require ment, facility security managers 
should have the necessary contact in formation for relevant local law 
enforcement authorities. To be assessed in detail   X   X  X 
C.21 The Member States and the Commission should ensure that public 
authorities provide, as appropriate, ade quate security information to the 
entire supply chain of high-risk chemical agents, first responders (police, 
fire-departments, medical services, and other special units as needed) 
and educational establishments to fo cus attention on issues of concern. Uncontroversial 
Ensuring that information is adequately distri buted to the entire supply chain of high-risk 
chemical agents is positive to ra ise their awareness on issues of concern. It would however be 
important to ensure that such informa tion does not cause overreactions and unrest.  X X X X X 
C.22 The Member States and the Commission should consider establishing an 
alert mechanism in order to quickly tr ansfer security related information 
to security managers in facilities in which high-risk chemicals are 
present. To be assessed in detail   X  X  X   
RN.16 The Member States and the Commission should support the IAEA's 
Illicit Trafficking Database with a view to ensuring real time 
accessibility for law enforcement authorities, ensuring the highest 
possible quality of the recorded data . Enhanced EU cooperation in this 
area should lead to making sure that all relevant losses and recoveries of 
radioactive sources are reported. Uncontroversial 
Supporting the IAEA's Illicit Trafficking Databa se is very positive as it will ensure that 
information is up to date, available and accessibl e to law enforcement authorities to track the 
losses and recovery of radioactive sources.  X X X X X 
RN.16 The Commission should setup an EU Database of Illicit Trafficking Unfeasible    X     X 
 
EN 149   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
a Incidents.  Stakeholders showed little support for this action.  The use of a database of illicit trafficking 
incidents in itself was welcome as being very useful  and beneficial to ensure that information is 
up to date, available and accessible to law en forcement authorities to track the losses and 
recovery of radioactive sources. However, stakeholde rs raised their concerns of duplication of the 
already existing IAEA's Illicit Trafficking Incident s. Using this database and making the most out 
of it would prevent duplication of efforts and w ould allow working on a solid basis which could 
be improved. 
RN.17 The Commission should assess whethe r existing systems, in particular 
the IAEA's ITDB, provides suffi cient information for the law 
enforcement community. Europol shoul d be closely involved in this 
analysis. If the analysis leads to the identification of gaps, further 
feasibility work could be conduc ted on the need to setup a 
complementary EU Database of Illicit Trafficking Incidents. Uncontroversial 
An assessment of existing inform ation-sharing systems is positive in  order to define the gaps and 
the needs for an improved system and potentially assessing the practicalities, costs and benefits 
of setting up a complementary EU Database of Illicit Trafficking Incidents. Whilst the latter 
could be beneficial as EU Member States may be  more open to provide sensitive information into 
an EU database than into a database involvi ng many third countries, there would be a high 
potential for duplication of efforts.  X X X X X 
8. Strengthen the import/export regime 
RN.18 The Commission should assess the need to address the issue of 
import/export rules in relation to poten tial high-risk sources not covered 
by the HASS Directive Uncontroversial 
Assessing the issue of import/export rules not covere d by the HASS directive is very positive, to 
make sure that high-risk sources which are curre ntly not covered are give n appropriate attention.  X X X X X 
RN.19 The Commission should assess to wh at extent the Code of Conduct and 
the IAEA Guidance cover the export and import of all high-risk radioactive sources and how these documents are implemented in the EU 
Member States. Uncontroversial 
An assessment of the coverage of the Code of Conduct and the IAEA  Guidance and of their 
implementation is very positive in order to map the situation in Member States. The exercise 
could also be used to identify good prac tices and to encourage peer learning.  X X X X X 
RN.20 The Commission should examine the need and feasibility of drawing up 
common EU criteria for authorising imports and exports from and to 
third countries, following an assessment of how the EU Member States 
implement the IAEA Guidance on the Import and Export of Radioactive 
Sources. Uncontroversial 
An assessment of the potential and practica lities of drawing up common EU criteria for 
authorising imported and expe rts from and to third countries is a very useful as a first step before 
potentially establishing such criteria.  X X X X X 
 
EN 150   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
9. Strengthen cooperation on the security of nuclear materials 
RN.21 The Member States and the Commission should progress the ratification 
of the amendment to th e CPPNM by the EU Member States/Community. Uncontroversial 
This action is very positive and useful in order to  make sure that the amendments of the CPPNM 
are ratified by all EU Member States. The amendment includes some important new elements, 
for example making it legally binding for States Pa rties to protect nuclear facilities and material 
in peaceful domestic use and providing for e xpanded cooperation between and among States 
regarding rapid measures to locate and recover st olen or smuggled nuclear material, mitigate any 
radiological consequences of sabotage, a nd prevent and combat related offences.  X X X X X 
RN.22 The Member States and the Co mmission should facilitate discussion 
among regulators, security specialists and performance assessment experts from the EU Member States, as well as the IAEA, in order to 
discuss progress on the implementa tion of the amended Convention and 
identify and exchange good practices  concerning physical protection 
measures. Existing forums should con tinue to be used as appropriate. Uncontroversial 
Facilitating discussion to discuss progress on the implementation of the amended Convention is 
positive in order to get an overview of state of the art in Member States. Identifying and 
exchanging good practices  concerning physical protection measures , is positives it will allow in 
particular Member States with less experien ce and capacity to easily access information from 
other Member States which are more advanced in this area.  X X X X X 
3) Detection strand 
No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
1. Establish a scenario-based/modelling approach to id entifying work priorities in the detection field 
H.33 The Member States and the Commis sion should develop scenarios at EU 
level (including events with cross- border effects) building on national 
experience while using the "black box" mechanism, including the challenge of the time of det ection and false alarm rates. Uncontroversial 
Developing scenarios at the EU level will be positiv e as they will enable an enhanced level of 
awareness of the impact of such an event, and consequently in the method to be adopted to detect 
the substance which caused the damage. It will be specifically important to take account of cross-
border effects. The black-box mechanism will help  to secure the information that is to be 
provided to inform the scenarios.  X X  X X X 
H.34 The Member States should strengthen and support:  
• the exchange of methodologies for developing scenarios;  To be assessed in detail X     X X 
 
EN 151   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
• networking of detectors at national level (centralising the analysis of 
detection data);  
• the exchange of information and data  regarding broader trends of what 
has been detected;  
• the exchange and coordination of  information on exercises among the 
Member States and other stakeholders when relevant. 
H.35 The Member States and the Commiss ion should develop a mechanism for 
information exchange among Member States on scenario development related to detection. Prepare an ove rview of Member State activities in 
this area. Uncontroversial 
A mechanism to exchange information on scenario  development related to detection , based on 
the mapping of existing national activities, is positive as it will allow in particular Member States 
with less experience and capacity to easily access information from other Member States which 
are more advanced in this area . It may also assist in the id entification of gaps and needs.  X X X X X 
H.36 The Member States and the Commission should carry out a gap analysis 
by creating a matrix for each develope d scenario of what is needed to 
identify CBRN materials and the detec tion technology already available. Uncontroversial 
A gap analysis of state of the art with rega rd to CBRN materials under specific scenarios and 
specific detection technology is positive as it allows making the most out of the available technology and using the most a ppropriate detection technology in  case of an emergency. This 
will increase the efficiency and effectiveness of deploying detection technologies, increasing 
their targeted use. It will also  help to identif y further needs.  X X X X X 
B.14 The Member States and the Commissi on should develop detection models 
for different biological pathogens a nd toxins, considering distribution, 
possible vectors, infec tious dose and stability. To be assessed in detail X  X   X  
2. Develop minimum detection standards 
H.37 The Member States and the Commission should develop minimum 
detection standards (including within  the context of border monitoring) 
based on relevant scenarios and threat assessments while building on 
existing work (e.g.: CEN). When developing such standardisation 
activities, adequate engagement of th e private sector should be ensured 
and legal requirements for evidence considered. To be assessed in detail X  X  X X   
B.15 Member States and the Commission should develop reference material of 
biological agents for both clinical and environmental samples (according 
to internationally accepted standard s) in order to achieve quality 
assurance in detection. Uncontroversial 
Developing reference material would allow laborat ories and other actors i nvolved in detection to 
use the most up to date and efficient material . This will ensure the best quality possible for 
detection and harm onisation amongst Member States.  X X  X X X 
B.16 Member States and the Commission should set requirements for the 
detection, identification and monitori ng of pathogens and toxins within a 
civilian security context at the EU level To be assessed in detail X     X  X 
3. Establish trialling, testing and certificat ion schemes for CBRN detection in the EU 
 
EN 152   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
H.38 The Member States and the Commission should:  
• Map out and document the technica l requirements necessary for the 
detection of CBRN materials, according to the field of application of the 
devices. 
• Establish an EU wide certification sc heme to evaluate whether detection 
systems and tools meet set require ments relying on existing capabilities 
and facilities. 
• Establish an EU wide testing scheme  for detection tools and systems to 
assess the performance and quality of solutions relying on existing 
capabilities and facilities. 
• Establish an EU wide trialling sche me to evaluate the quality of both 
detection tools and systems in pr actical field operations relying on 
existing capabilities and facilities.  
• Exchange good practices, approach es to and methodologies on quality 
assurance in CBRN in Member States. To be assessed in detail X  X   X   
B.17 Member States and the Commission should establish: 
• Sets of relevant simulants of biologi cal agents for field tests, practical 
exercises and field technology triallin g at national level and EU level, 
where appropriate; 
• Criteria for method validation acros s detection of human, animal and 
crop threats. Uncontroversial 
Establishing sets of simulants for field tests and criteria for detection is positive as it will ensure a 
common, harmonised and validated approach acro ss the EU and Member States. The simulants 
will also help to better understand the climate, c ontextual and geographical differences within the 
EU. X X   X X 
4. Identify good practices related to detection of  CBRN materials, awareness raising and training 
H.39 The Member States and the Commi ssion should assess the feasibility of 
EU handbooks on detection of CBRN materials for practitioners (e.g. 
operators of detection devices) in  view of the creation of joint 
investigation teams as well as an action card for first responders, building on existing work done at the EU level and within the Member States. This 
handbook should be translated into  all official EU languages. Uncontroversial 
An assessment of the potential and practicalitie s of establishing a handbook on detection of 
CBRN materials in order to create joint investigatio n teams is very useful as a first step before 
potentially establishing such a handbook. Some stakeholders considered that there may be 
security risks involved.  X X X X X 
H.40 Member States and the Commission should enhance and support the 
cooperation between forensic laborat ories, reference and specialised 
laboratories on CBRN materials. Uncontroversial 
The Commission could have an important role in enhancing and supporting the cooperation of 
forensic, reference and specialised laboratories, as it would be very useful to develop an EU 
overview as well as promoting links between la boratories at national and EU levels. Whilst 
several cooperation structures between laboratorie s exist, these usually concern very specific 
areas and do not link the reference / specialised la boratories to those that deal with forensics.  X X X X X 
H.41 The Member States and the Commission should:  
• Establish a mechanism of exchanging best practises in the field of Uncontroversial 
A system to exchange good prac tices in the field of training an d exercise, on the calibration of X X X X Possibly 
 
EN 153   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
training and exercises, in cluding awareness raising of front line officers;  
• Support EU and national projects aime d at calibrating detection devices 
in specific environments. Cooperatio n and information exchange among 
the Member States on such projects should be enhanced. 
• Support the exchange of good practices on how to respond when CBRN 
materials are detected; 
• Exchange good practices on det ection methods and processes; detection devices in specific environment on th e appropriate response when CBRN materials are 
detected and on detection methods and processes is positive, as it will allow in particular Member 
States with less experience and capacity to easily access information from other Member States which are more advanced in this area. The m echanism and good practice exchanges will also be 
useful to identifying gaps and upcoming needs.  
H 42 The Commission should: 
• Launch a study on what is curren tly in place in terms of CBRN border 
monitoring in the EU; 
• Elaborate guidelines on optimal lo calisation of detection equipment Uncontroversial 
Stock-taking exercise/study  led by the Commission. Such an assessment is positive in order to 
define the gaps. It will allow mapping th e existing border monitoring arrangements. X X X X X 
B.18 Member States and the Commission should initiate: 
• The development of mobile dete ction, identification and sampling 
capabilities at the EU level to be undert aken by commercial enterprises, 
research institutions and universities,  and support mobile bio-forensic 
capabilities; 
• The establishment and maintenance of a network of reference 
laboratories within the EU (if not yet done so). To be assessed in detail  X   X X 
B.19 Member States and the Commission should enhance and support: 
• Cooperation among laboratories assigned to deal with unknown 
pathogens and toxins at national level;  
• Support networking among existing la boratories which are competent 
and have capacity across the EU specia lising in specific biological agents 
(particularly agents which will be iden tified on the EU Bio-security list).  Uncontroversial 
The central role to be played by the Commissi on in the networking of laboratories is very 
positive as it will allow a centralised and impr oved coordination of wo rks and exchange of 
information between the releva nt laboratories under EU responsibility. Member States will 
support in this at the national level.  X X X X Possibly 
RN.23 The Member States and the Commi ssion should develop an adequate and 
sustainable training programme at EU level for front line officers. The 
EU-SECTRA can play an import ant part in this process. Uncontroversial 
A training programme at the EU level is positive as it will ensure a common and harmonised 
approach to the work of front line officers. The EU-SECTRA centre will have an important role 
in terms of developing training progr ammes, training the trainers, etc.  X X X X X 
5. Improve the exchange of information 
C.23 The Member States and the Commission should communicate the 
technical requirements of detection devices to the private sector. They 
should acquire knowledge of availabl e capabilities and future research 
plans of the private sector. Uncontroversial 
Cooperation with the private sector with regard to  technical requirements of detection devices is 
essential, as it would help to better match supply with the specific demand. It would also help to 
identify areas where further research and develo pment is required. Member States would also 
have a better understanding of what the detection industry can provide in terms of technologies 
and systems. It would be important  to address issues such as the security of information that is X X X X X 
 
EN 154   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
provided to industry and the po ssibility of 'unfair competition'.  
B.20 Members States and the Commission should support: 
• EU and national projects performi ng measurements of biological 
background at specific areas, and e nhance cooperation and information 
exchange among Member States on such projects; 
• Exchange good practices among Member States on cases and processes 
when a dangerous biological substance is detected. To be assessed in detail X     X   
RN.24 The Member States and the Commission should promote and support EU 
and national projects performing mon itoring of radiation for security 
purposes. Cooperation and informa tion exchange among the Member 
States on such projects should be enhanced. Uncontroversial 
Promoting and supporting pr ojects on monitoring of radiation for security purposes is positive as 
it will allow increasing the knowledge and capability in this area. Cooperation and exchange will 
in particular beneficial for those Member States which have a less developed capacity.  X X X X X 
4) Preparedness and response strand  
No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
1. Improve emergency planning 
H.43 Each Member State should inte grate CBRN emergencies into its 
response plans (where applicable into both national and local plans). The requirements of possible criminal investigations and 
forensics should be fully taken into account in these plans. Uncontroversial 
Integrating CBRN emerge ncies into response plans with a particular focus on criminal 
investigations and forensic in positive as it w ill allow a better and more coordinate response to 
respond to those emergencies and to prevent i nvestigative problems and possible damage to 
forensic evidence.  X X X   X 
H.44 Each Member State should asse ss whether all operators handling 
high-risk CBRN materials possess emergency response plans. The 
feasibility of extending, wher e needed, emergency plan 
requirements to such operators should be assessed. Gaps in existing regulations should be identified. Uncontroversial 
An assessment of emergency plans is positive in or der to update the plans in light with gaps and 
needs identified.  X X  X X X 
H.45 The Member States and the Commission should develop and To be assessed in detail X X   X   
 
EN 155   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
conduct regular exercises and training at all levels (national, 
European and international), invol ving and testing cooperation of 
all relevant organisations, particul arly of health, first responders, 
security and judicial authorities; involvement of private sector in 
such exercises should be foreseen. Possible criminal investigations 
and forensics should be part of these regular exercises. The 
Commission should ensure coordina tion of relevant exercises at 
EU level. 
H.46 The Commission should launch a study concerning the 
organisation of State structures  concerning CBRN incidents. The 
results of the study should be shared across the EU. Uncontroversial 
An assessment of the State structures concer ning CBRN incidents is positive as it will allow 
mapping the existing preparedness and response systems in Member States. Sharing the results 
will be particularly beneficial to those Member States who have less deve loped capacity in this 
area. Issues in relation to the sensitivity of information should be taken into account.  X X X X X 
B.21 Member States and the Commission should constitute an EU level 
working group to consider:  
• Better cooperation among relevant agencies in crisis and 
consequence management, response and recovery management; it 
should develop a bio-specific checklist of requirements for 
consequence management, response and recovery. 
• Good practices on responding to security incidents involving the 
facilities possessing any of the biol ogical agents and toxins on the 
EU biosecurity list; To be assessed in detail   X X X   
RN.25 Each Member State should a ssess whether emergency plans exist 
for high risk public locations and high-risk public events. Uncontroversial  
Assessing the extent to which emergency plans exis t for high risk public locations and high-risk 
public events is a useful action which will allow de termining the state of the art, the gaps and the 
needs. This action would be very beneficial if it were to cover all CBRN issues  X X  X X X 
RN.25a Raise awareness among the public of radiological hazards, 
radioactivity and its effects on human beings and on the 
environment, the various types of radiological emergencies and 
their consequences for the population and the environment. 
Information should also be provi ded on the emergency measures 
envisaged to alert, protect and assi st the population in the event of 
a radiological emergency as well as on action to be taken by the 
population in the event of a radiological emergency. Unfeasible 
The need to inform the general public was not sup ported by stakeholders as they did not see an 
added value in the preparedness and very little in th e response. It might be too risky to inform the 
public about issues which can appear to be dange rous in their everyday life and their direct 
environment. This might create unneeded panic of the general public which might become 
suspicious and scared of potential events. In  addition, the emergency plans might not be 
improved as the general public might not nece ssarily be well trained or aware and might 
overreact as a consequence of accumulated panic.      X     
RN.25b Develop plans on how to orga nise the dissemination of 
information in the event of a radiological emergency and Unfeasible  
This action received little stakeholder support and rais ed subsidiarity issues. The first concern is     X     
 
EN 156   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
determine the content of the inform ation. In order to ensure that 
the general public takes the message seriously without 
exaggerating the scale of the hazard, the information should be 
credible and allow the general pu blic to see that the emergency 
plans drawn up would be implemented in the event of a real 
emergency. the selection the information which can be diffus ed to the general public, within a "reasonable" 
scale and scope. It would also require finding a ri ght balance to inform and ensure an efficient 
implementation of the emergency plans without causing panic and fear. The second point raised 
by stakeholders was that it should be the respons ibility of each Member State to define whether 
and how to inform its general public according to  its own experiences and procedures. Only the 
Member States can assess what the costs and bene fits associated to do so are and take the 
responsibility for it. 
2. Strengthen the EU's countermeasure capacity 
H.47 Each Member State should:  
• Assess the required amount s and types of medical 
countermeasures in case of a incident involving high-risk CBRN 
materials; 
• Assess the availability of hospita l beds and hospitals able to 
carry out the decontamination of  victims, the availability of 
medical and paramedical personnel,  transport possibilities and of 
required countermeasures in the form of technical CBRN 
equipment.; 
• Assess the possibility of sharing medical counter-measures 
across borders in case of an incident. To be assessed in detail   X X X   
H.48 The Commission should collect and disseminate good practices 
among the Member States concerning the ways in which medical 
staff can receive guidance on dealin g with large scale emergencies 
and a rapid increase of the number of patients. Uncontroversial 
The exchange of good practices on the guidance that  should be provided to medical staff in case 
of large scale emergencies is positive, as it will allow in particular Member States with less 
experience to learn from other Member States  which are more advanced in this area.  X X X X X 
B.22 The Health Security Committee should consider: 
• The possibilities to a) estab lish therapeutics and vaccine 
stockpiles towards the known threat of biological agents and 
toxins, and determine the necessary  auxiliary medical supplies to 
stockpile (gloves, masks, syringes, etc.); b) establish a standby 
capacity to produce therapeutics,  including vaccines, and c) 
establish sustained funding for a technology platform to secure 
countermeasures towards biological agents and toxins that are 
unknown today (public-private  experts working group); 
• The possibilities to scale up the diagnostic capacity in crises 
situations. Involvement of the private sector in the working group 
should be considered. 
• Ensuring a sufficient amount of medical products to combat an To be assessed in detail X   X X   
 
EN 157   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
eventual threat;  
• Build an EU wide coordinated approach to access medical 
countermeasures allowing adequate protection of the EU 
population, based on risk assessment. 
B.23 The Commission and Member States should consider the creation 
of mechanisms for rapid licensing procedures of drugs and 
vaccines in crisis situations and possible exemptions from 
licensing procedures, taking existing work into consideration. To be assessed in detail X X   X   
3. Improve domestic and international info rmation flows in case of CBRN emergencies 
H.49 Member States should exchange information on emergency plans 
regarding CBRN incidents, involvi ng all relevant agencies.  To be assessed in detail   X X X   
H.50 Member States and the Commission should setup an CBRN 
special units' network with a view to enhancing the exchange of 
information and good practices within the law-enforcement community dealing with CBRN threats Uncontroversial 
The exchange of information and good practices  on the guidance among the special units is 
positive, as it will allow in particular Member States with less experien ce to learn from other 
Member States which are more advanced in this area.  X X X X X 
RN.26 Each Member State should ensu re that public authorities provide 
relevant security information on a need to know basis to the entire 
supply chain of radioactive sources and nuclear materials, first 
responders (police, fire-departments, and medical services) and educational establishments in order to enhance preparedness levels. Uncontroversial 
Ensuring that information is adequately distribut ed to groups who might be involved in an event 
involving radioactive/nuclear materials is ve ry positive as it will ensure high level of 
preparedness from those groups. I ssues in relation to the sensitiv ity of the information to be 
provided are to be taken into account. Also, di fferent groups will require different forms of 
information.  X X X   X 
RN.27 The Member States and the Commission should consider 
integrating and building upon exis ting platforms for international 
exchange of information during nuc lear emergency situations, as 
well as assessing their applicability to all radiological and nuclear 
incidents of concern (scenario-based).  An effort should be made to 
assess the possibilities of streamlining alert messages going 
through different rapid alert systems. To be assessed in detail   X X X   
RN.28 The Member States and the Commission should establish a 
process in order to develop gene ric scenarios illustrating the law 
enforcement response to a potential event involving radioactive/nuclear materials at the national and the international 
level. This process should in particular identify the relevant 
stakeholders who need to be info rmed about a particular situation 
and the applicable thresholds for triggering information exchange Uncontroversial 
Creating scenarios setting out the response of law enforcement to an event involving radioactive 
materials is positive, as it helps to determine wh ich steps are to be taken and who is to be 
involved, at which level, thus increasing the re sponse capacity. Whilst some Member States have 
advanced scenarios in place, other countries  have much less experience in this area.  X X X X X 
 
EN 158   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
procedures. The process should at least involve representatives of 
the Member States, the Commission and Europol. 
4. Develop improved modelling tools a nd strengthen decontamination capacity 
H.51 The Commission should fund an assessment of existing modelling 
tools for the purpose of seeing whether there is need to invest in 
further research. The validation of existing modelling tools could 
be undertaken by the Commission's Joint Research Centre 
(possibly through the European Reference Network for Critical Infrastructure Protection). This work should include the 
organisation of meetings of modelling experts and emergency 
response personnel from EU Member States in order to assess practical requirements for modelling tools. Based on this analysis 
funding could be provided for further research into the 
development of robust modelling tools applicable to events involving dangerous substances. The Commission should fund an 
assessment of the role of mode lling tools for either pre-event 
scenario studies or as decision-support systems. Uncontroversial 
An assessment of the available modelling tools is  very positive as it will allow update the existing 
ones in light of recent developments and to pr opose further investments where needed. Experts 
and Member States should be involved in all stag es of the work so that they can ensure the 
practical implementation of the tools and also point out their specific needs and requirements.  X X X X X 
H.52 The Commission should facilita te the preparation of an 
Emergency Response Guidebook (for  first responders) applicable 
to the context of CBRN emergencie s in the European Union. The 
guidebook would be provided to the Member States free of charge 
and could be translated into all of ficial EU languages. As part of 
the process of preparing an Emergency Response Guidebook, a 
stocktaking of existing docu ments/guidebooks should be 
conducted. Uncontroversial 
Creating a guidebook on CBRN emergencies is positiv e is order to present the common EU 
approach to respond to those emergencies and to gu ide on the steps to be followed in case of such 
an event. It will in particular  be very beneficial for those Member States which have a less 
developed capability in this area.    X X X X 
H.53 Each Member should conduct a regular assessment of the 
available means for effective d econtamination and their capacity 
to deal with mass casualties with reference to high-risk CBRN 
materials. Information about cu rrent decontamination solutions 
should be shared with all Member States. Uncontroversial 
Regular assessments of capacity a nd capability do deal with contamin ation is positive in order to 
ensure that Member States check  their capacity to deal with decontamination and mass casualties 
and make adjustments where necessary. In add ition, information shar ing will benefit those 
Member States with a less developed technical decontamination capacity and knowledge of risks.  X X  X  X X 
H.54 The Commission should:  
• Launch a study on the economic and social consequences of a 
CBRN terrorism incident and identify practical and action-oriented responses,  
• Launch a study on rehabilitation of contaminated areas following 
malevolent dispersal of CBRN materi als, which also addresses the Uncontroversial 
 
The mentioned studies will be very useful in or der to assess and model the actual consequences 
following the use by terrorists of CBRN wea pons, and start envisaging the most adequate 
measures to limit contamination at the same time as limiting the damages to forensic work.  X X X X X 
 
EN 159   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
question of acceptable levels of residual contamination. 
• Launch a study on decontamin ation procedures which do not 
damage forensic evidence. 
RN.29 The Commission should further i nvestigate the possibility of using 
the RODOS and ARGOS DSS to address CBRN releases (e.g. radiological dispersal devices, events such as the polonium 
incident in 2006, etc.), as well as the development of transport and dispersion models for large buildings (e.g.: airports, railway stations) and underground systems. Uncontroversial 
Investigating in the possibility of  using International information exchange tools is very positive 
to foster the exchange of expertise and knowle dge amongst Member States and to inform those 
which have a less developed capacity in some areas. RODOS and ARGOS in particular will be 
useful to get an overview of the situation, create a prognosis on the evolution and calculate the 
consequences of the incidents. The expanded use of  a software could be looked into in order to 
improve access to information.  X X  X X X 
5. Improve the capacity to conduct criminal investigations 
H.55 Each Member State should ensure that first responders receive 
training on forensic awareness in a CBRN crime-scene. Uncontroversial 
Training of first responders of forensic awarene ss will limit the loss of fo rensic evidence within 
the specificities of each Member State. It would be  beneficial to include some EU level guidance 
as to the content of such training.  X X X   X 
H.56 The Commission should analyse th e issue of potential problems in 
the transport of CBRN contaminated materials across borders within the context of criminal  investigations and emergency 
situations in general. Uncontroversial 
The analysis of potential problems in the transpor t of CBRN contaminated material will be very 
positive in order to prepare the most adequate response in case of an emergency and to help 
forensic work.  X X X   X 
H.57 Euro just should develop recommendations on ensuring that 
collected forensic evidence in a CBRN crime-scene is of a high 
enough quality to be admissible in  court proceedings in the EU 
Member States. Eurojust, Europol, the European Network of Forensic Science Institutes, JRC-ITU and other relevant 
organisations should contribute to establishing laboratory 
practices such that results can be used during legal prosecution 
(e.g.: accredited measurement pro cedures; chain of custody). The 
exchange of experience and good practice concerning the 
transport, handling, and forensic analysis of contaminated 
materials in the context of criminal investigations should be 
pursued. Uncontroversial 
Recommendations of forensic bodies of the EU w ith regard to the quality of evidence is positive 
and very beneficial as their experience as well as  the exchange of practices will provide useful 
insight in order to set quality standards for forens ic evidence so that such  evidence is admissible 
in national courts in other EU countries. At pr esent, such possibilities ha rdly exist also because 
Member States have different approach es to forensic laboratory practices.  X X X X   
RN.30 The Commission should support the networking of forensic 
laboratories and laboratories equi pped for measurement/analysis 
of radioactive material Uncontroversial 
The central role to be played by the Commissi on in the networking of laboratories is very 
positive as it will allow a centralised and impr oved coordination of works and exchange of 
information between the relevant  laboratories under EU responsib ility. The networking will also 
improve the mutual recognition of forensic evidence as well as he lp to increase common X X X X   
 
EN 160   EN No. Policy action First screening Strong stakeholder 
support Positive overall effects Low financial costs High EU added value / 
rationale No subsidiarity / 
proportionality issues 
laboratory practices.