Commission staff working document - Accompanying document to the Communication from the Commission to the European Parliament and the Council on Strengthening Chemical, Biological, Radiological and Nuclear Security in the European Union : an EU CRBN Action Plan - Impact assessment {COM(2009) 273 final} {SEC(2009) 791}
Date: 2009-06-24
Institutions: European Commission
Subjects: energy consumption, energy policy, energy saving, nuclear energy, nuclear safety, radiobiology, report

EN 

   EN 

 
 
COMMISSION OF THE EUROPEAN 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, Biological, Radiological and Nuclear Security in the European 
Union – an EU CRBN Action Plan  

IMPACT ASSESSMENT  

{COM(2009) 273 final} 
{SEC(2009) 791} 

EN 

   EN 

 
 
 
  
 
 
 
 
 
 
1. 

2. 

2.1. 

2.2. 

2.3. 

3. 

3.1. 

3.2. 

3.3. 

3.4. 

Introduction .................................................................................................................. 4 

Procedural issues and consultation of interested parties .............................................. 4 

Organisation and timing............................................................................................... 4 

The Impact Assessment Board..................................................................................... 5 

Consultation process .................................................................................................... 5 

Problem definition........................................................................................................ 7 

The overall level of threat associated with CBRN materials ....................................... 7 

The potential costs of CBRN attacks ........................................................................... 9 

Problem definition...................................................................................................... 10 

Scope of the problem ................................................................................................. 13 

3.4.1.  The chemical industry ................................................................................................ 14 

3.4.2.  The biological market ................................................................................................ 14 

3.4.3.  The Radiological and Nuclear industry...................................................................... 14 

3.5. 

3.6. 

4. 

5. 

5.1. 

5.2. 

Status quo, existing gaps ............................................................................................ 15 

Subsidiarity and proportionality principles................................................................ 20 

Policy Objectives ....................................................................................................... 22 

Policy options and their Assessment.......................................................................... 22 

Baseline scenario or status quo .................................................................................. 24 

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. 

6.1. 

6.2. 

7. 

Preferred Policy Option (CBRN Action Plan) ........................................................... 87 

Summary of relevance, feasibility and expected impacts .......................................... 89 

Assessment of the EU added value .......................................................................... 104 

Monitoring and evaluation ....................................................................................... 107 

Annex 1: CBRN glossary....................................................................................................... 109 

Annex 2: Examples of incidents, military and terrorist attacks involving CBRN materials . 114 

EN 

2 

   EN 

 
Annex 3:  Non-exhaustive list of international and European legislation and non-binding 

frameworks currently in place.................................................................................. 128 

Annex 4: First screening of identified CBRN actions to be undertaken................................ 131 

EN 

3 

   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 being taken at Member State level, to address 
gaps  in  the  field  and  to  promote  the  sharing  of  information  and  exchanges  of  best 
practices  between  Member  States.  The  policy  package  should  also  assist  in  the 
identification of measures to reduce the terrorist threat that apply horizontally, as well as 
individually across the chemical, biological, radiological and nuclear domains. The focus 
of the package will be on tangible deliverables within the "prevent, protect and respond" 
strands  of  the  EU  Counter-terrorism  Strategy  adopted  by  the  Council  on  1  December 
2005.3 

2. 

PROCEDURAL ISSUES AND CONSULTATION 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,  pandemics  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,  biological,  radiological  or  nuclear  terrorist 
threats" in December 20025. The 2004 progress report on this Programme6 confirmed that 
the threat of CBRN terrorism justified continued attention at EU level. The Programme 
was  superseded  by  the  Council  and  Commission'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  overall  Strategy  and  Action  Plan  on  Combating 
Terrorism established in 2005 after the London attacks.8 

1 
2 
3 
4 
5 
6 
7 
8 

A CBRN glossary can be found in Annex 1. 
16589/07, of 17 December 2007 
15708/03. 
SN 4292/01 REV 2. 
14627/02. 
8988/05. 
15480/04. 
14469/4/05, paras 20 and 31. 

EN 

4 

   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  destruction  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  Board  of  the  European  Commission  (IAB) 
delivered  its  opinion  regarding  a  preliminary  version  of  this  Impact  Assessment  report. 
The Board stressed that although the Impact assessment report is a long document, this is 
understandable due to the complexity of the subject raised. 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  identifies  actions  should  be  assessed  not  only 

qualitatively but also quantitatively. 

In  addition  the  IAB  stated  that  the  IA  report  would  be  usefully  complemented  by 
including  a  more  thorough  analysis  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  Assessment  report  has  been  revised  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, representatives of regional authorities, the private sector, and 
research and academia were received. A synthesis of the replies to both green papers has 

9 
10 
11 

SN 400/03, no 68. See also infra, para 6. 
COM(2006) 474 final. 
COM(2007) 399 final. 

EN 

5 

   EN 

 
                                                 
been published in 2008.12 The results of the consultation on the green papers were used 
as the departing point for further discussions in the CBRN Task force. 

The  main  driving  force  behind  the  formulation  of  the  specific  CBRN  activities  to  be 
undertaken  has  been  the  CBRN  Task  force.  The  Task  force,  which  was  established  in 
February  2008,  consisted  of  more  than  200  members  that  arrived  from  national 
authorities  and  organisations,  ranging  from  many  different  Ministries  such  as  Internal 
Affairs,  Justice,  Defence  and  Health, 
to  representatives  of  national  response 
organisations, civil defence and other first responders, as well as forensic institutes and 
nuclear  safeguards  authorities.  Representatives  of  the  private  sector,  academia  and 
international  organisations  also  participated,  in  particular  Europol  and  Eurojust.  The 
participation demonstrated the strong interest of many stakeholders in being involved in 
the development of further policy measures at the European level. 

Furthermore, several Commission services have been actively involved in the work of the 
CBRN Task force. Among all the DGs involved in this exercise, DG ENTR, DG SANCO 
and  DG  TREN/JRC  played  a  particularly  active  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 different 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 animals, 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 radiological/nuclear prevention, detection and response; 

•  The  chemical  sub-group  held  a  series  of  seminars  and  workshops  throughout  2008 

dedicated to chemical prevention, detection and response issues. 

The  work  of  all  groups  was  based  on  discussion  documents  put  forward  by  the 
Commission,  which  included  possible  recommendations  to  improve  the  existing 
situation. These documents were adapted through an interactive process. The final report 
of  the  Task  Force  was  published  in  January  2009  and  discussed  at  a  comprehensive 
conference in Prague that officially 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, confirming not only that there is still a lot of work to be done, 
but also that there is a strong consensus amongst experts on how the existing issues could 
best be tackled. 

In addition, 6 meetings of the CBRN Inter-service group meetings 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 

6 

   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, and SG. Their opinions have been taken on board already 
at the preparation phase of the CBRN package. This broad consultation process and its 
input form the basis for this Impact Assessment, as well as for the CBRN Package itself. 

3. 

PROBLEM DEFINITION 

When defining the CBRN related problem in the EU, a series a variables, including the 
overall level of the CBRN threat and the potential cost of using CBRN materials have to 
be taken into consideration. 

3.1. 

The overall level of threat associated 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 resort to such weapons of mass destruction,14 these 
arguments were revised after evidence on efforts from terrorist organisations, notably Al-
Qaeda, to use CBRN materials came to light.15 

The range of possibilities for terrorist attacks involving CBRN materials 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 chemicals or biological agents; 

•  spreading chemical or biological agents on surfaces to poison via skin contact; 

•  releasing  gaseous  chemicals,  vaporised  biological  agents  or  radiological  sources  in 

buildings or public transport infrastructure; 

13 

14 

15 

in: 

Bruce 

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://www.rand.org/ise/projects/terrorismdatabase/. 
E.g. Brian Michael Jenkins, “International Terrorism: A New Mode of Conflict” in: International 
Terrorism and World Security (London, 1975), or Walter Laqueur, “Terrorism” (London, 1977) - 
cited 
Post-9/11” 
(http://fletcher.tufts.edu/jebsencenter/researchbriefs/JCCTS_Hoffman_CBRN_01-2007.pdf). 
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  Arrangements”)  of  November 
2007,  it  is  said  that  “the  UK  faces  threats,  such  as  from  organised  crime  and  terrorism,  of  an 
unprecedented level of virulence, sophistication and variety. The determination and capability of 
such  groups  are  greater 
the  potential  consequences  more 
serious.”http://www.cabinetoffice.gov.uk/media/cabinetoffice/corp/assets/publications/reports/bor
der_review.pdf. 

than  ever  before  and 

Terrorism 

Hoffman, 

“CBRN 

EN 

7 

   EN 

 
                                                 
•  releasing  large  quantities  of  high-risk  substances  (gaseous  or  liquid)  into  the 
environment  via  an  attack  on  a  production  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 radiation by hiding unsealed radioactive or nuclear material in 

public places (passive dispersion); 

•  contaminating  areas  with  radioactive  material  by  using  an  explosive  radiological 

dispersion device (RDD, or ‘dirty bomb’); 

•  triggering  a  nuclear  explosion  by  using  a  (stolen)  nuclear  weapon  or  an  improvised 

nuclear device (IND)16. 

Incidents  involving  the  use  of  CBRN  materials  for  malicious  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 

B 

RN 

On  20  March  1995,  probes  of  the  chemical  weapon  Sarin  (NATO  designation:  ‘GB’) 
were  released  at  different  locations  within  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. 

In  October  2001,  envelopes  containing  bacillus  anthracis  (anthrax)  spores  were 
dispatched through the US postal 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 measure. Some harmless hoax ‘anthrax letters’ 
were  sent  to  government  and  private  persons  in  the  aftermath,  inflicting  panic  and 
disruption of day-to-day work. 

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  travelled  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 

17 

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 weapon-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 dispersal of nuclear material would render the public 
space a “no go” area for a considerable amount of time 
A non-exhaustive list of more incidents involving CBRN material can be found in Annex 2. 

EN 

8 

   EN 

 
                                                 
3.2. 

The potential costs of CBRN attacks 

Whilst  the  occurrence  and  probability  of  CBRN  attacks  might  be  limited,  the  social, 
environmental and economic costs incurred in case of an incident would be severe and 
would  persist  over  several  years,  especially  if  major  transport  nodes  (such  as  ports  or 
airports) or centres of economic activity are targeted (financial and commercial centres). 
The main cost factors in case of a major incident are usually: 

•  the value of loss of life and temporary or persistent health conditions leading to lower 

employability and a lower quality of life; 

•  effects of the disruption of economic activities and destruction and/or contamination 

of infrastructure; 

•  social  disruption  and  an  overall  public  perception  of  being  unsafe,  also  having  an 

effect on overall public health and wellbeing. 

Many analyses examined the costs of simulated 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 mentioning that such estimates 

18 

3,  No. 

$42-420. 

2,  April–June 

Infectious  Diseases,  Vol. 

For a detailed analysis, see for example: 
Kaufmann, Arnold F. et al., “The Economic Impact of a Bioterrorist Attack: Are Prevention and 
Post-attack  Intervention  Programs  Justifiable?”  (Analysis  of  large  scale  aerosol  releases  of 
Bacillus  anthracis,  Brucella  melitensis,  and  Francisella  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 
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 billion 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: 
billionhttp://abtassociates.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  use  of  a  radiological  weapon  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/Homeland-Security/doc_files/costs_terrorist.pdf  
United  States  Center  for  Homeland  Security  and  Defence  (CDHS).  According  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_2009/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 successful terrorist attack with a weapon of mass 

EN 

9 

   EN 

 
                                                 
generally  focus  on  very  large  scale  CBRN  incidents.  Consequently,  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 specific 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  capacity  of  the  EU  to  respond  to  the  CBRN 
threats with regard to prevention, detection and response.  

Table 2 sets out the main problems, with a synthesis of key issues identified specific to 
C, B, or RN areas. 

Table 2: Main problems and a synthesis of key issues identified specific to C, B, or RN areas 

Specific problems 

1) Horizontal issues 

Key issues 

Problem  1.1:  A  wealth  of  international  and  EU 
legislation  and  agreements  in  place  but  differences 
in implementation 

setting  out 

A  pool  of  legislation  and  international  conventions 
cover  CBRN  materials, 
rules  and 
requirements  at  different  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 is a body of international and EU legislation which overall appears to focus 
more  on  safety  than  security  (with  the  exception  of  nuclear  materials,  where  the 
security  aspect 
legislation  and 
conventions).  In  addition,  international  and  EU  legislation  only  rarely  uses  a 
comprehensive approach to all CBRN materials. 

is  adequately  addressed  by 

international 

There are differences in national transposition and implementation of international 
and  EU  legislation,  in  terms  of  quality,  elaboration  and  coverage,  as  well  as 
operational  and  functional  arrangements  in  place.  Terrorists  and  criminals  could 
take advantage of less developed and secure national contexts. 

Problem  1.2:  Gaps  and  duplications  in  current 
information sharing and cooperation initiatives 

There are many different formal and informal, 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. 

sharing 

information 

Multiple 
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 lead to information gaps and 
lack of opportunities for effective early warning. 

and 

The  current  mechanisms  and  initiatives  are  not  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. 

There  is  no  adequate  early  warning  mechanism  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  shipping  container  could  amount  to  $1  trillion  if 
subsequent draconian security measures were adopted that impeded trade. An efficient release of a 
to  $750  billion. 
biological  agent 
http://www.brook.edu/fp/projects/homeland/chapter1.pdf. 

in  a  major  urban  area  could 

inflict  costs  of  up 

EN 

10 

   EN 

 
 
                                                                                                                                                 
Specific problems 

Key issues 

transaction, especially in the chemical 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. 

Problem  1.3:  Constraints  due  to  differences  in 
practical  and  legal  arrangements  in  the  Member 
States 

Mutual  recognition  of  forensic  evidence  is  not  ensured  within  the  EU.  Moreover, 
regulations, standards and practical arrangements concerning procedures and rules 
on dealing with forensic evidence in case of CBRN events vary significantly. 

There are various legal and practical constraints to EU 
cooperation to combating CBRN terrorist threats.  

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, Eurojust) differs between the Member States. 

Most  security  clearances  and  background  checks  undertaken  in  one  Member  State 
are not recognised in other Member States. 

Problem  1.4:  Problems  with  regard  to  personnel 
security 

Not all personnel which may handle or have access to CBRN materials is adequately 
checked.  There  may  also  be  potential  personnel  security  issues  in  facilities  where 
dangerous agents and toxins are handled on an occasional basis. 

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  number  of  persons  having  access  to  or 
handling CBRN materials across the entire supply chain (especially in the chemical 
sector), there is a need for a graduated approach. 

Problem 1.5: Insufficient research and development 
to  prevent,  detect,  prepare  and  respond  to  CBRN 
incidents 

A  number  of  research  needs  has  been  identified  at  the  EU  level  in  the  field  of 
prevention, detection, response and technology research. 

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 developed significant research programmes in the 
security area, corresponding activities 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. 

Problem  1.6:  Publication  and  funding  programmes 
do not sufficiently take security issues into account 

The  public  dissemination  of  certain  findings  from  research  constitutes  a  potential 
risk as terrorists and criminals might use these findings to produce CBRN weapons. 
The risk is particularly significant in the biological area. 

The  open-source  publication  of  scientific  findings  and 
research funding practices do not sufficiently take into 
account security issues. 

Organisations  funding  research  do  not  sufficiently  consider  the  potential  risks  of 
misuse in their decisions to finance projects. 

2) Prevention issues 

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  radiological  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. 

The extent to which various type of CBRN material is available and used in Europe 
differs, but the overall scale of use of chemical, biological, radiological and nuclear 
material is large. A huge number of economic actors and individuals have access to 
these. European competitiveness depends to a great extent on CBRN materials. 

A  number  of  CBRN  materials  can  be  turned  into  weapons  by  terrorists  and 
criminals.  There  is  often  no  need  for  well-equipped  laboratories  to  handle  and/or 
prepare  highly  toxic  chemical  compounds,  improvised  radiological  dispersion 
devices  (RDDs)  or  to  manipulate  biological  agents  and  toxins.  There  is  also  the 
growing issue of new, genetically 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 potentially dangerous materials in some Member 
States remains insufficient, thus rendering the coordinated control of CBRN markets 
difficult. 

EN 

11 

   EN 

 
Specific problems 

Key issues 

There is insufficient coordinated control of the markets 
for  CBRN  materials  and  Member  States  have  varying 
approaches and standards with regard to the monitoring 
and  surveillance  of  CBRN  materials  and  transactions 
The  level  of  awareness  of  the  dangers  of  CBRN 
substances also varies across the production and supply 
chain. 

3) Detection issues 

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  terrorist  threat  do  not  have 
adequate  technical  resources  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/threat 
is  not  adequate 
everywhere in Europe. 

Problem  3.2:  Duplication  of  efforts  in  standards, 
testing trialling and certification 

There are no harmonised minimum detection standards 
on which Member States could build and no European 
testing and trialling and certification scheme exists yet. 
The  effectiveness  of  detection  equipment  procured  (in 
combination  with  systems  setup  and  training)  may  be 
inadequate. 

4) Preparedness and response issues 

Licensing  requirements  and  the  quality  of  follow-up  monitoring  and  control 
arrangements are less developed in some Member States. 

Member States have different procedures for tracking CBRN materials and activities 
and  reporting  thefts/losses.  Electronic  tracking  systems  for  high-risk  sources 
(including cross-border transport) have not been introduced. There is also an overall 
lack  of  awareness  of  suspicious  transactions  and  behaviour  for  personnel  working 
with CBRN materials. Tracking biological substances can prove difficult as these are 
living organisms that can easily increase or reduce in numbers. 

There is a lack of dialogue between law enforcement and facilities (and their security 
managers)  notably  in  the  chemical  and  radiological/nuclear  field  in  some  Member 
States. 

There is a lack of security awareness amongst users of CBRN materials (including 
equipment  with  radiological  sources)  in  certain  Member  States.  Education  and 
training curricula do often not address these issues sufficiently. 

There  are  gaps  amongst  European  stakeholders  (national  agencies,  emergency 
services,  industry  actors)  in  understanding  current  CBRN  threats  and  risks  and 
defining on that basis concrete detection requirements. 

Currently, technologies and tools are insufficiently 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 general lack of overview across law enforcement bodies and other 
relevant actors of good methods and equipment. Information sharing arrangements 
are not in place or not working efficiently. A scope for duplication exists in research 
efforts. 

There are certain gaps in the CBRN awareness 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  informed  on  the  current  level  of 
threat, especially on current trends and concrete risks. 

A  common  set  of  minimum  CBRN  detection  requirements,  based  on  performance 
tested (trialled) under real life circumstances, 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. 

Linked  to  the  lack  of  a  European  system  of  standards  for  detection  equipment  and 
systems,  there  is  also  no  European  testing,  trialling  and  certification  of  detection 
systems and equipment. 

Problem  4.1:  Mechanisms  and  procedures  to  deal 
with incidents are not in place or not effective 

When available, response and emergency plans in Member States do not sufficiently 
take account of the EU or international dimension of an incident. Similarly, they do 
not take account of the possible terrorist and intentional nature of the incident. 

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 

12 

   EN 

 
 
Specific problems 

Key issues 

critical  infrastructure  operators.  The  security  aspects 
are often not explicit or not well integrated in the plans. 

Problem  4.2:  Gaps 
first 
in 
responders,  including  lack  of  awareness  of  forensic 
and cross-border issues 

training  of 

the 

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. 

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.  

When available, response and emergency plans in Member States do not include pre-
defined protocols which set out information 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. 

Not  all  high-risk  locations  (critical  infrastructure,  public  transport  companies)  or 
operators  handling  high-risk  CBRN  materials  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, training 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 focusing on cross-border issues and cooperation 
in the event of a CBRN event. 

to 

training  within 

With  regard 
facilities  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 
stockpiles/banks and manipulated agents and toxins are of great concern. 

threats,  not  all  Member  States  have  vaccine 

to  biological 

Having  appropriate  countermeasures  in  place  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  the  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. 

Many Member States would not have sufficient decontamination capacity, especially 
in the case of release of nuclear or radiological materials, which requires isolation 
of victims. 

3.4. 

Scope of the problem 

The  threat  from  CBRN  materials  affects  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 sector is substantial. 

EN 

13 

   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  chemicals  industry  contributed  2%  of  total 
economy GDP19. 

The  geographical  location  of  the  EU  chemicals  industry  is  mainly  concentrated  in  four 
countries20.  Germany  is  the  largest  European  producing  country  (26.1%),  followed  by 
France  (13.0%),  Italy  (12.5%)  and  the  United  Kingdom  (11.7%).  The  EU  chemicals 
in  2004  comprised  27,000  enterprises21  which  collectively  employed 
industry 
approximately 1.2 million people22. 

3.4.2.  The biological market 

Nearly  all  biological  agents  and  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 nuclear, 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,  including  the  agro–industry,  the  pharmaceutical 
industry and in the medical sector in general. 

Some  biological  substances  can  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 facilities, usually referred as to P3 and P4.23 While 
highly  harmful  animal  substances  and  harmful  human  substances can  be  handled  in  P3 
laboratories, substances causing highly harmful human diseases can be handled only in 
P4  laboratories.  Biosafety-Europe24,  a  project  funded  by  the  Commission,  conducted  a 
survey  of  all  P3  and  P4  laboratories  in  the  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 radioactive materials, such as: 

19 
20 
21 
22 

23 

24 

CEFIC (2005), Facts & Figures: The European Chemical Industry in a Worldwide Perspective. 
Ibid 
Commission Staff Working Paper: REACH – An Extended Impact Assessment 
CEFIC (2008) The European chemical industry A global leader in innovation, supporting growth 
and well-being in Europe. 
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) 
http://www.biosafety-europe.eu/  

EN 

14 

   EN 

 
                                                 
•  accelerators used in research (subatomic research, 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 radiation (e.g. radiographs, locating or 
controlling  hidden  levels  of  solids  and  liquids),  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 for 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 coherent 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  materials  does  already  exist.  In  the  biological 
field,  whilst  there  are  some  legislative  instruments  specifically  focusing  on  security 
(potential  terrorist  threat),  the  bulk  of  international  and  EU  legislation  is  safety  driven. 
The  only  exception  is  the  nuclear  field,  where  there  already  exists  a  strong  focus  on 
security. 

Table 3: Non-exhaustive list of key EU legislation and non-binding frameworks25 

European legislation 

C 

Council  Directive 96/82/EC  of  9  December  1996  on  the  control  of  major-accident 
hazards 
the 
consequences of accidents. It focuses on safety, the formulation of emergency plans, and 
information exchange in case of incident. 

involving  dangerous  substances (Seveso  II)  aims  at  mitigating 

25 

For a comprehensive list of legislation and non-binding frameworks currently in place, see Annex 
3.  

EN 

15 

   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 risks to their safety and health arising, or 
likely to arise, from the effects of chemical agents 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. 

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. 

B 

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.  

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  nuclear  materials  and  thereby  enhancing  the  security  of 
sources to reduce the risk of radioactive sources being misused. 

RN 

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) 
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 

EN 

This directive creates a compulsory notification system: when an outbreak occurs, Member States 
have to notify the Commission. Member States have also to notify the Commission when there is 
goods, 
customs 
an 
http://europa.eu/scadplus/leg/en/lvb/f85001.htm 

imported/exported 

interception 

the 

on 

at 

16 

   EN 

 
                                                 
Directive 2004/37/EC of the European Parliament and the Council of 29 April 2004 
on  the  protection  of  workers  from  the  risks  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 sectors, in all EU Member States. 

In addition to current legislation focusing primarily 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 

implementation  of 
international  and  EU  legislation,  in  terms  of  quality,  elaboration  and  coverage. 
Terrorists and criminals could take advantage of less secure national contexts;27  

in  national  transposition  and 

•  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  prevention,  detection  and  response  actions  at 
different levels (national, regional, local), operators of critical infrastructure and first 
responders have to comply with a variety of rules and systems; 

•  Insufficient  awareness  of 

information  exchange  mechanisms  amongst 
stakeholders.  Especially,  the  involvement  of  private  sector  stakeholders  is  rather 
limited;28  

27 

Overall, as concerns the implementation of the legislation, 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 

17 

   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 transactions. As a consequence, emergency 
responders  and  anti-terror  coordinators  do  not  have  single  automatic  access  to 
information  on  incidents  and  stolen  or  lost  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  highly  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  material  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  relatively  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 

29 

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,  the  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. 
The Rapid Alert System for Biological, Chemical and Chemical Terrorist Events (RAS BICHAT) 
for  example  is  the  rapid  alert  system  used  for  exchanging  information  on  health  threats  due  to 
deliberate  release  of  chemical,  biological  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  Warning  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 and other events leading to release of chemicals, 
and consultation and coordination of counter-measures. 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 States in order to inform about the current and foreseeable status of 
the  accident,  radiological  status  of  the  environment,  meteorological  conditions,  national 
countermeasures taken, etc.  

EN 

18 

   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,  storing  or  distributing  CBRN  materials.  Whilst 
safety  standards  for  facilities  handling  CBRN  materials,  especially  those  that  could 
potentially  be  very  dangerous,  are  covered  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, for example with regard to overall security 
plans  for  facilities  and  the  appointment  of  security  managers;  security  procedures 
within facilities and communication between relevant stakeholders (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  ‘priority  substance  lists’  which 
have  been  created  at  national,  EU  and  international  levels.  Table  4  below  provides 
several examples of such lists. 

Table 4: Examples of priority lists 

List 

Level  

Purpose 

Type 
CBRN 

of 

Chemical Weapons Convention 

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 

World Organisation for Animal Health 

International 

Safety 

The IAEA Code of Conduct on the Safety and Security of 
Radioactive Sources 

International 

Safety 

International Air Transport Association 

International 

Transport 

International  Carriage  of  Dangerous  Goods  by  Road 
(ADR) 

International 

Transport 

Regulation  EC  1334/2000  on  setting  up  a  Community 
regime  for  the  control  of  exports  of  dual-use  items  and 
technology 

European 

Export 

Common Military List of the European Union 

European 

Export 

CB 

B 

RN 

CBRN 

CBRN 

CBRN 
(products  and 
technologies) 

CBRN 
(weapons) 

Council Directive 2008/68/EC on the inland transport of 
dangerous goods 

European 

Transport 

CBRN 

EN 

19 

   EN 

 
Council Directive 96/82/EC (Seveso II) 

European 

Public health 

Regulation EC 1907/2006 (REACH) 

European 

Safety 

Council  Directive  2000/54/EC  (protection  of  workers 
from  risks  related  to  exposure  to  biological  agents  at 
work) 

European 

Safety 

Council  Directive  2000/29/EC  (protective  measures 
against the introduction into the Community of organisms 
harmful  to  plants  or  plant  products  and  against  their 
spread within the Community) 

European 

Safety 

Matrix currently under development by DG SANCO 

European 

Security 

Council  Directive  2003/122/Euratom  (on  the  Control  of 
High Activity Sealed Radioactive Sources) 

European 

Safety 

Centre for Disease Control and Prevention (USA) 

National 

Bioterrorism  

Schedule 5 pathogens and toxins (UK) 

National 

Security  

C 

C 

B 

B 

B 

RN 

B 

B 

Dutch priority list (under preparation) (Netherlands) 

National  

Security  

CBRN 

Biological  Materials  Ordinance  of  27  Jan  1999  as 
amended (Germany) 

National 

Safety  

Foreign  Trade  and  Payments  Act  of  28  Apr  1961; 
Foreign Trade and Payments Ordinance Of 18 Dec 1986 
(Germany) 

National 

Export 

List of War Weapons Control Act, § 20(Germany) 

National 

Security  

Protection  against  Infection  Act  of  20  Jul  2000 
(Germany) 

National 

Public health 

B 

B 

B 

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 specifically aimed at security. 

3.6. 

Subsidiarity and proportionality 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  international  phenomenon  and  many  of  the 

existing security initiatives and legislation are international in character; 

EN 

20 

   EN 

 
 
•  a  number  of  problems  related  to  CBRN  materials  are  equally  international  in 
character.  These  include  for  example  the  exchange  of  information  among  Member 
States, cooperation between Member States and transport security; 

•  a variety of security measures currently exist 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 enforcement 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 this cooperation, and activities 
in the CBRN field are in accordance with the subsidiarity principle, especially insofar as 
they  help  reinforce  the  channels  for  bilateral  and  multilateral  cooperation  between 
Member States. At the same time international cooperation needs 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  fear  generated  is  strong  and  induces  indirect 
damage to well-being way beyond the loss of life, injury and property. The reactions of 
security agencies to terrorism may themselves induce negative effects on citizens.  

in 

losses, 

On  the  other  hand,  the  potential  negative  effects  of  a  terrorist  attack  using  CBRN 
materials  are  significant, 
longer-term  economic 
terms  of  financial 
consequences, losses of life and casualties and social disruption and overall well-being. 
Well targeted and relevant action in this field to prevent such attacks from happening, to 
identify planned attacks and to appropriately deal with the consequences of an attack is 
therefore justified. In these circumstances EU activities in the protection against potential 
CBRN incidents, especially taking into consideration the existing security gaps, the fact 
that  a  difference  needs  to  be  made  between  high-risk  CBRN  materials  and  CBRN 
materials in general, and the fact 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, possibly reflecting the fact that the measures taken 
to protect explosives in Spain are stricter than those taken in France.  

EN 

21 

   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 and 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 

2. To increase the 
security of CBRN 
materials and the 
safety of citizens 
and possible 
targets  

2.1 To prevent 
access to 
legitimately 
produced and used 
CBRN materials by 
terrorists or other 
criminals  

3. To increase the 
chances of 
detection and 
identification of 
CBRN materials 
before and after 
terrorist 
incidents 

3.1 To improve 
detection and 
identification 
capacity and 
capability 

4. To reduce to a 
minimum the 
effects of terrorist 
incidents 
involving CBRN 
materials  

4.1 To improve 
response and 
emergency 
planning and 
protocols, also at 
the EU level 

3.2 To develop an 
EU approach 
towards detection 
and identification 

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 To develop an 
EU approach 
towards response 
and emergency 
planning 

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 

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  options  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 

22 

   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 basis of the first screening of all identified 
actions  that  can  be  found  in  Annex  4.  The  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. The screening criteria include: 

1. 

2. 

3. 

4. 

5. 

stakeholders' support through consultation of the Task Force; 

positive or at least no negative economic, social and environmental 
impacts and effects on fundamental rights; 

limited financial costs; 

high EU value added, strong EU rationale; 

no issues in relation to subsidiarity 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 acceptable and meeting at least 4 screening 

criteria. 

–  controversial actions possibly raising 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  controversial  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 

23 

   EN 

 
0 

1 

2 

3 

4 

5 

Baseline/No 
impact 

Very 
impact 

small 

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 
impact 

/  no 

Small  positive 
impact 

Positive impact 

5.1. 

Baseline scenario or status quo 

Table 6: Status Quo 

Assessment Criteria 

Rating 
(from -, 0 
- 5) 

1.1 To increase effective 
international cooperation, 
coordination and dialogue on 
CBRN 

0 

1.2 To raise awareness and 
increase knowledge and 
information sharing on CBRN 

0 

Motivation of the rating and aspects of the policy action necessary to achieve the impact 

Relevance 

Current international, cooperation and dialogue would be continued. As 
elaborated  in  the  problem  assessment,  this  would  continue  to  suffer 
from  inefficiencies  and  possible  duplication  of  efforts.  It  would  not 
involve all Member States and it would lack a common EU position in 
some cases whether this would be strongly 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. 

Under the status quo, a great deal of stakeholders would continue to be 
unaware  of  at  least  part  of  the  cooperation  structures  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 

24 

   EN 

 
 
                                                 
Assessment Criteria 

Rating 
(from -, 0 
- 5) 

Motivation of the rating and aspects of the policy action necessary to achieve the impact 

1.3 To reduce, where possible, 
judicial, legal, jurisdictional 
barriers and constraints 

1.4 To improve personnel 
security 

0 

0 

1.5 To strengthen and prioritise 
research on CBRN 

0 

1.6 To increase awareness of 
security implications in funding 
decisions 

1.7 To increase awareness of 
security aspects in publishing 

2.1 To prevent access to 
legitimately produced and used 
CBRN materials by terrorists or 
other criminals  

0 

0 

0 

2.2 To improve monitoring and 
control over CBRN materials  

0 

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 that such materials may represent. 

Differences in practices and legislation 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  CBRN  acts  or  may  not  cover  these 
adequately, with the potential of legal loopholes. 

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  and  vetting  procedures,  whilst  in 
other countries no such screening would exist or only for persons which 
require a very high level of security clearance (e.g. in P4 laboratories). 
This  will  lead  to  important  differences  which  terrorists  could  use  to 
gain access to CBRN materials. 

Current  research  efforts  would  continue.  This  includes  national-level 
research projects as well as research undertaken as part of the Research 
and  Development  Framework  Programmes  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 already being undertaken in other national contexts, 
and what the upcoming research needs would be. 

No changes would occur, some funding organisations, especially those 
based  in  the  US,  would  review  security  implications  whilst  other 
organisations will not pay attention to such issues. 

No  changes  would  occur.  The  publication  of  research  through  open-
source  literature  would  continue.  Some  publishers,  for  example  in  the 
US, would discuss possible security issues with authors whilst in other 
countries no such check would take place. 

CBRN materials would continue 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. 

Monitoring and control of CBRN materials 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 

25 

   EN 

 
Assessment Criteria 

Rating 
(from -, 0 
- 5) 

Motivation of the rating and aspects of the policy action necessary to achieve the impact 

2.3 To improve overall 
awareness of the potential 
dangers and risks, contributing to 
a high 'security culture' 

0 

3.1 To improve detection and 
identification capacity and 
capability 

3.2 To develop and EU approach 
towards detection and 
identification 

4.1 To improve response and 
emergency planning and 
protocols, also at the EU level 

4.2 To develop an EU approach 
towards response and emergency 
planning 

4.3 To ensure ongoing 
information flows in case of 
CBRN emergencies 

0 

0 

0 

0 

0 

The  opportunity  for  losses  and  thefts  would  remain  the  same  unless 
Member  States  would  launch  improvements,  with  a  real  danger  of 
further  losses  and  thefts.  In  addition,  if  a  theft  or  loss  would  occur, 
many stakeholders would not know to whom they were to report this to. 

The low levels of awareness and understanding of the potential dangers 
and risks of CBRN materials would persist and could deter people from 
noting and reporting suspicious behaviour and transactions. Insufficient 
education,  training  and  other  measures  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.  

Current detection capacity and capability would continue to be low in 
some  Member  States,  with  a  very  low  chance  that  certain  CBRN 
materials are detected. Detection systems and equipment would not be 
used in a targeted way and may not be placed in all relevant locations. 

The differences in the standards for detection systems and equipment, 
as well as different ways of testing, 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. 

Differences  in  CBRN  emergency  planning  would  continue  to  exist  in 
the  Member  States  and,  in  some  national  contexts,  would  take 
insufficient  account  of  intentional  releases  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. 

Response  and  emergency  planning  would  continue  to  be  a  strictly 
national  affair  (with  some  international  guidance  and  cooperation), 
insufficiently  taking  into  account  the  likely  cross-border  effects  of 
CBRN incidents. 

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  adequately  reaching  the  stakeholders 
required and / or not envisaging the 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 

26 

   EN 

 
Assessment Criteria 

Rating 
(from -, 0 
- 5) 

and other criminals 

4.5 To enhance national and EU 
countermeasure capacity 

0 

Financial and economic impacts 

Social impacts 

Environmental impacts 

Impacts on fundamental rights 

0 

0 

0 

0 

Motivation of the rating and aspects of the policy action necessary to achieve the impact 

investigations into emergency response plans, especially if the latter do 
not  sufficiently  take  account  of  malicious  intent.  This  could  lead  to 
important evidence being lost or spoiled. 

Some  Member  States  will  have  good  medical  countermeasures  (in 
terms of drugs, vaccines and therapeutic capacity) and decontamination 
capacity  whilst  others  may  not  prioritise  such  measures  or  lack 
resources  to  put  these  in  place.  It  is  unlikely  that  any  of  the  Member 
States are fully prepared for all types of CBRN materials 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 

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  between  the  countries.  In  case  of  an 
incident, the economic impact could be severe, see section 3.2 

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.  

If the status quo was to continue, the long term environmental impacts 
might  be  negative.  As  there  would  be  no  activities  towards  better 
prevention,  protection  and  response  of/to  CBRN  incidents,  the  risk  of 
such  incidents  occurring  (with  serious  environmental  impacts  such  as 
for example contamination of specific areas) would not be reduced.  

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 presented 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 action. Where possible, an estimation of the 

costs of each action has been provided; 

EN 

27 

   EN 

 
•  where  relevant,  a  description  of  the  potential  social  and  environmental  impacts,  as 
well  as  effects  on  fundamental  rights.  With  respect  to  environmental  impacts,  it  is 
worth  mentioning  that  only  direct  environmental  impacts  of  a  specific  action  are 
considered  in  the  below  assessment.  It  needs  to  be  stressed  however  that  indirect 
positive effects of preventing CBRN incidents are significant and certainly add to the 
positive  environmental  effect  concerning  air  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  most  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 addition, all actions that might 
result  in  separate  legislative  proposals  or  high  costs  in  term  of  resources  at  EU  and/or 
national level will be subject to separate impact assessments or feasibility studies. 

The  chosen  approach  addresses  the  difficulties  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  the  biggest  in  terms  of  costs  or  possibly 
controversial  political  choices  to  be  made.  The  approach  tries  to  combine  and  look  for 
commonalities in more  than  260  actions that have been identified as necessary through 
the work of the CBRN Task force. Issues such as cost-effectiveness, overlaps, synergies, 
duplications  with  already  existing  measures  have  been  discussed  during  this  long 
consultation  phase,  and  are  already  taken  into  consideration  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  letter  H  (for  Horizontal)  are  common  to  all 
CBRN strands (i.e. chemical, biological and radiological/nuclear), actions identified with 
the 
the  chemical,  biological  and 
radiological/nuclear strands respectively.  

letters  C,  B  and  RN  are  applicable 

to 

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 intelligence community). Its 
role  would  be  to  develop  guidelines  and  codes  of  conducts  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. 

Achievement of (relevant) policy objectives 

EN 

28 

   EN 

 
increase 

1.1  To 
effective 
international 
cooperation, 
coordination 
dialogue on CBRN 

and 

raise 
1.2 
To 
and 
awareness 
increase  knowledge 
and 
information 
sharing on CBRN 

2.3  To 
improve 
overall awareness of 
the 
potential 
dangers  and  risks, 
to  a 
contributing 
'security 
high 
culture' 

improve 
4.1  To 
and 
response 
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 require 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. Firstly, establishing a formal and permanent body 
at the EU level might duplicate existing structures. Secondly, the actions received little 
support  from  relevant  stakeholders.  Thirdly,  most  of  the  actions  foreseen  within  this 
network  would  fall  under  Member  States'  responsibility.  Fourthly,  the  network  in  its 
envisaged  form,  would  focus  only  on  the  biological  side,  rather  than  have  a  horizontal 
approach.  

Due to these factors, Action B0 is considered unfeasible. 

Action H.08 (Develop improved information tools for CBRN security) 

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  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 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. 

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 

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 improve information exchanges 
and allow Member States to take the necessary precautions and other steps when threats, 
losses,  thefts  and  suspicious  transactions  are  reported.  Nevertheless,  there  are  several 
issues  to  take  into  account.  Firstly,  several  separate  systems  already  exist,  such  as  the 
existing system functioning between 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 potentially very high, as it would require 
a  sophisticated  system  linking  all  Member  States,  which  should  be  able  to  process 
substantial information up- and downloads. Several countries outside the G6 cooperation 
countries  (DE,  ES,  FR,  IT,  PL,  UK)  already  have  early  warning  systems  operating  for 
individual  CBRN  materials  and  related  threats  (for  example  Austria  or  the  Nordic 
countries).  Interlinking  and  extending  these  would  be  less  burdensome  than  setting  up 
entirely  new  systems.  The  action  would  also  require,  at  national  and  EU  levels, 
continuous  and  updated  inputs.  The  financial  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 between 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 contribute to fighting 
crime and terrorism  and increasing security, by improving  the  exchange of information 
within the law enforcement community. 

Assessment of EU-added value 

EN 

30 

   EN 

 
High  added  value.  CBRN  incidents  and  threats  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 exercises concerning the security of chemical 
facilities in order to test preparedness measures 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 
other 
criminals  

or 

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 regard. The coverage and scale of the action is 
significant, especially when taking into account 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  and  providing  the  training,  to  ensure  a 
harmonised  approach  to  preparedness  overall.  This  may  require  a  mapping  of  current 
training provided and the identification and exchanges 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 chemicals that would be included in the EU priority substances 
list),  this  action  could  be  costly  particularly  for  those  Member  States  which  do  not  yet 
have such training programmes in place. A single 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  Public  health  and  safety,  as  staff  in 
chemical facilities would be better prepared to deal with chemical incidents. Better staff 
preparedness would contribute positively to crime and terrorism prevention and increase 
security. The action would also improve the Standards and rights related to job quality, as 
it would improve the workers' access to continuous training. 

EN 

31 

   EN 

 
Assessment of EU-added value 

Putting  in  place  a  requirement  for  Member  States  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 such training, thus reducing the EU added value 
of this action. 

Action B.03 (Improve training) 

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 
for 
information  and  biological  agents  and 
undergraduate, graduate and postgraduate students. 

toxins  and  bio-ethics 

EN 

32 

   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 
other 
terrorists 
criminals  

or 

2.3  To  improve  overall 
awareness of the potential 
dangers 
risks, 
and 
to  a  high 
contributing 
'security culture' 

4 

2 

4 

Developing minimum training requirements would 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  developed  guidelines  or  approaches  that  can  be 
applied in other countries. It would also useful 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 area 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  costs  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  negatively  affect  Public  health  and 
safety,  as  spreading  information  to  graduate  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 minimum 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  action,  as  ensuring  a  common  set  of  guidelines 
would ensure an EU wide 'interpretation' of minimum training requirements. 

Action H.12 (Strengthening personnel security) 

The  Member  States  and  the  Commission  should  develop  and  introduce  common 
graduated  criteria  for  background  checks  and  vetting  requirements  in  relation  to 
personnel  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 

EN 

33 

   EN 

 
of  a  common  European  list  of  the  most  high-risk  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. 

Achievement of (relevant) policy objectives 

1.4 To improve personnel security 

access 

2.1  To 
to 
prevent 
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 and acceptable. Limiting this to the European 
common  list  is  equally  beneficial.  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  particular  with  regard  to 
chemical substances) could substantially expand the elements of the chain of production, 
storage,  distribution  and  use  to  be  covered.  An  important  additional  factor  to  be 
considered would be the ability of the individual Member State 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 with less developed background checks and 
vetting  processes  will  face  costs  to  meet  the  EU  criteria  that  will  be  put  forward.  The 
financial  inputs  required  will  also  vary  depending  on  the  length  of  the  EU  list  of  most 
high-risk  materials.  A  graduated  approach  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  increases  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  requirements  establish  conditions 
for access to employment in certain areas of the labour market. Thus, an impact on the 

EN 

34 

   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  processing  of  personal  data  by  any  person  whose  activities  are 
governed by Community law. Any collection of, or access to personal data by officials of 
the State about an individual must be duly justified, in line with 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 Convention on Human Rights (ECHR). 

Legal effects: The common criteria may require a legislative instrument at EU level. 

Assessment of EU-added value 

Establishing  common  graduated  criteria  for  background  checks  and  vetting  would 
provide  a  high  added  value,  as  it  would  improve  overall  security  standards  and  levels 
across  the  EU  and  help  Member  States  with  less  developed  approaches  to  make 
improvements.  The  action  would  also  increase  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 balanced 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  only  rarely,  with  high-risk  materials.  Mutual 
recognition of vetting processes would also benefit the individual workers that make use 
of their right to engage in occupation in other Member States. It would reduce costs for 
businesses and administrations as Member States would be able to recognise the vetting 
processes conducted by other Member States. 

Action H.13 (Strengthening personnel security) 

The Member States and the Commission should identify and exchange good practices on 
approaches to security of non-EU visiting staff and students; Member 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 
personnel security 

improve 

2.1  To  prevent  access  to 
produced 
legitimately 
CBRN 
and 
materials  by  terrorists  or 
other criminals  

used 

4 

2 

3 

Assessment of (relevant) effects 

Economic  impacts:  The  costs  for  identifying  good  practices  would  be  low,  involving  a 
mapping study to identify good practices, their validation and organising 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  applied.  The  action  could  however  have  the 

EN 

35 

   EN 

 
negative economic effect of inhibiting excellence 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 the right to private life and personal 
data  protection  of  the  individuals  involved,  equality  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 common procedures, the action could 
have  a  negative  effect  on  the  Non-discrimination  principle.  Also,  any  collection  of,  or 
access to personal data by officials of the State about an individual must be duly justified, 
in line with 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 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  area,  as  it  is  responsible  for  overall  migration 
policy. There are known cases of attempts to infiltrate universities and research institutes. 
Not  all  Member  States  apply  background  checks  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 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.  

Achievement of (relevant) policy objectives 

1.3  To  reduce,  where 
possible,  judicial,  legal, 
jurisdictional 
barriers 
and constraints 

2.1 To prevent access to 
produced 
legitimately 
and 
CBRN 
materials by terrorists or 
other criminals  

used 

To 

2.2 
improve 
monitoring  and  control 
over CBRN materials  

1 

3 

3 

EN 

36 

   EN 

 
Maintaining  a  registry  of  persons  working,  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 registries in place. For those that 
will have to set this up, the financial costs will strongly depend on the length of the EU 
biosecurity  list.  If  all  researchers,  visiting  staff  and  students  who  might  have  access  to 
some  material  will  fall  under  the  scope  of  this  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 effect on private life and personal data 
protection, especially if a high number of people are affected and if access to the registry 
within the law-enforcement authorities would not be properly limited. On the other hand, 
the action increases security, and reduces the possibility of unauthorised access to high-
risk CBRN materials, and thus 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  processing  of  personal  data  by  any  person  whose  activities  are 
governed by Community law. Furthermore, any 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 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. 

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 part 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 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  (from  both  a 
safety and a security perspective) to work on the research the receiver is proposing. Best 

EN 

37 

   EN 

 
practices  of  funding  organisations  should  be  identified  and  exchanged  across  Member 
States. 

Achievement of (relevant) policy objectives 

1.5  To  strengthen  and 
on 
prioritise 
CBRN 

research 

1.6 To increase awareness 
of security implications in 
funding decisions 

1.7 To increase awareness 
in 
of  security  aspects 
publishing 

2 

4 

2 

Assessment of (relevant) effects 

Economic  impacts:  It  is  difficult  to  estimate  the  costs  of  this  action,  as  funding 
organisations  could  be  encouraged  through  several  actions  such  as  the  preparation  of 
guidance  material,  checklists,  detailed  information  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, the action could have negative effects in a 
scenario  where  funding  for  research  presenting  security  risks  would  be  reduced,  for 
example  because,  as  a  result  of  additional  checks  required  on  the  status  and  security 
arrangements  of  funding  applicants,  funding  organisations  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  applicants  presenting  security  risks  would 
have  limited  chances  of  receiving  grants,  harm  equality  of  treatment  and  opportunities. 
On the other hand, it could contribute to increased security and be a step forward towards 
reducing the possibility of crime and terrorism involving CBRN materials. 

Assessment of EU-added value 

There is scope for EU action in this area, as a common message 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 before their publication 

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 

3 

Assessment of relevant effects 

EN 

38 

   EN 

 
Economic impacts: the action might have a negative impact on research. If researchers do 
not  have  assurances  on  the  publication  of  their  studies,  their  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 researchers. 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 

39 

   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  national  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 action is considered unfeasible.  

Action B.06b (Strengthen and prioritise research) 

Publications of studies with sensitive biological dual-use research 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  required  to  publish  two  versions  also  require 
additional inputs and hence costs. 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  subsidiarity,  as  it  would  interfere  with  national 
arrangements  in  place  in  relation  to  the  publication  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 

40 

   EN 

 
5.2.1.  CBRN prevention 

Action  H.20  (Develop  EU  lists  of  high-risk  CBRN  materials  and  risk-based 
approaches to security) 

The Member States and the Commission should establish and regularly update EU lists 
of high-risk chemical agents; biological agents and toxins (biosecurity list); and 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: 

–  Identifying and analysing relevant CBRN materials; 

–  Assessing its potential for being 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 study on these possible measures.  

Achievement of (relevant) policy objectives 

2.2  To 
control over CBRN materials  

improve  monitoring  and 

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  ensure  harmonisation  at  EU  level.  Member 
States  should  be  offered  the  possibility  to  adopt  the  list  but  add  materials  which  are  of 
specific national concern. The latter is particular relevant with regard to biological agents 
and toxins, as their presence strongly depends on contextual, geographical and climatic 
differences of the EU27. 

The list would need ongoing updating. The criteria used for the 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  private  sector  solutions  could  focus  on  the 
prioritised materials. It will also be highly important to ensure that the lists take account 
of  recent  developments,  for  example  of  the  possibility  of  genetic  manipulation  in  the 
biosecurity list. 

Assessment of (relevant) effects 

EN 

41 

   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, subsistence, conference rooms): would approximately 
amount  to  1,000  EUR  per  person.  When  estimating  the  participation  of  40  persons  per 
meeting,  taking  part  in  around  5  meetings,  this  would  amount  to  200,000  EUR.  Expert 
fees  to  support  the  process  (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  incurred  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  intervention,  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.  Furthermore,  identifying  a  number  of  high  risk 
CBRN  materials  at  EU  level  could  certainly  provide  common  EU  ground  for  balanced 
approach to activities at EU level and represent a cornerstone for the implementation of 
the entire Action plan. Broad availability of CBRN materials in the modern world means 
that  it  would  not  be  possible  to  implement  strict  security  measures  concerning  all  such 
materials.  A  certain  prioritisation  is  needed  so  that  public  authorities  and  private 
operators  concentrate  resources  on  securing  only  a  certain  group  of  high-risk  CBRN 
materials. Such an approach would allow the 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  should  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 

To 

access 

2.1 
to 
prevent 
legitimately  produced  and  used 
CBRN  materials  by  terrorists  or 
other criminals  

2.2  To  improve  monitoring  and 
control over CBRN materials  

4 

2 

EN 

42 

   EN 

 
Assessment of (relevant) effects 

Economic  impacts:  The  action  in  itself  would  require  low  financial  inputs,  as  it  would 
mainly concern a mapping exercise, identification of good practices and the preparation 
of a document. Based on similar studies, the mapping exercise of existing criteria would 
amount to around 100,000 EUR per type of material. Additional costs would be required 
for  the  publication  of  the  document  in  all  the  languages  of  the  EU.  If  the  assessment 
criteria  would  become  compulsory,  the  financial  implications  may  be  high  for  some 
Member States and relevant industry to ensure compliance. 

EN 

43 

   EN 

 
Financial costs 

Economic impacts 

1 

0 (- if the assessment criteria would 
become compulsory) 

Social  impacts:  Developing  criteria  on  assessing  security  arrangements  at  high-risk 
CBRN facilities would positively affect the security of CBRN facilities as it might help 
to identify gaps in existing protection measures. 

Assessment of EU-added value 

The  rationale  for  EU  intervention  is  strong,  as  evidence  suggests  that  security 
arrangements  in  some  facilities  may  be  insufficient  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  whether  these  security  plans  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 
control over CBRN materials  

improve  monitoring  and 

4 

3 

Improving  the  security  plans  and  security  management  systems  in  facilities  handling 
high-risk chemicals, involving Member State authorities in checking whether such plans 
satisfy  the  necessary  level  of  protection  requirements,  is  beneficial,  as  it  would  ensure 
that  any  potential  threat  is  taken  into  account.  The  option  is  in  line  with  the  European 
Programme  for  Critical  Infrastructure  Protection,  which  aims  to  improve  the  protection 
of  critical  infrastructure  in  the  EU  through  a  package  of  measures  including  the 
identification  and  designation  of  European  critical  infrastructure  and  accompanying 
financial measures. This addresses critical infrastructure which, if disrupted 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 industrial activities, which looks at protection of facilities and 
plans  from  a  safety  perspective.  The  option  would  benefit  from  action  in  the  field  of 
developing criteria for assessing security arrangements in CBRN facilities and exchanges 
of good practices, as put forward under H.22. 

EN 

44 

   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 establish or further elaborate 
their  security  plans  and  management  systems,  in  particular  in  Member  States  with  less 
advanced  approaches  in  place.  To  mitigate  this,  it  would  be  useful  if  more  developed 
Member States would provide assistance, advice and expertise. High costs would also be 
incurred by national authorities to verify the 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 competitiveness 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  proportionality,  as  security  plans  and 
management  systems  are  a  national  responsibility  of  owners,  operators  and  authorities. 
However, insufficient security plans and management 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 environmental performance, and communication with 
stakeholders.  As  part  of  the  programme,  participating  chemical  companies  are  obliged  to 
document  all  their  deliveries.  The  Responsible  Care  programme  is  an  initiative  of  the  chemical 
industry  which  addresses  issues  such  as  health,  safety  and  environmental  performance,  and 
communication with stakeholders about products and processes 

EN 

45 

   EN 

 
                                                 
Achievement of (relevant) policy objectives 

2.1 To prevent access to 
legitimately  produced 
and 
CBRN 
materials  by  terrorists 
or other criminals  

used 

To 

improve 
2.2 
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 

46 

   EN 

 
Assessment of relevant effects 

Economic  impacts:  whilst  the  costs  for  a  similar  investigation  would  be  relatively  low, 
any  changes  proposed  to  the  programme  could  require  additional  investments  by  the 
companies that are participating in the Responsible Care Programme. As a result of this 
action, participants may also decide 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  relevant,  given  that  the  programme  does  not 
include all relevant stakeholders. In addition, if the investigation would show a need for 
changes  to  the  programme,  the  Commission  could  not  ‘enforce’  such  changes.  Several 
stakeholders doubted  the  usefulness of  a similar investigation. The action also received 
very little support from relevant stakeholders and is thus considered unfeasible. 

Action C.10 (Enhance the security of CBRN materials and facilities) 

The  Member  States  and  the  Commission  should  develop  a  high  level  approach  to 
chemical facility security which identifies key objectives and steps to be taken in order to 
increase security, based on national 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 
control over CBRN materials  

improve  monitoring  and 

3 

3 

Assessment of (relevant) effects 

Economic impacts: The financial implications of developing an EU high level approach 
are  difficult  to  estimate  without  more  detailed  information  as  to  what  kind  of  activities 
this  would  include.  As  a  minimum,  Member  States  and  the  Commission  are  likely  to 
incur costs for meetings to agree on the common objectives and steps. Further costs could 
be incurred for the preparation of a document setting out the high level approach. 

Financial costs 

Economic impacts 

1 

0 

EN 

47 

   EN 

 
Social  impacts:  Developing  a  high  level  approach  to  the  security  arrangements  of 
chemical facilities would positively affect the security of CBRN facilities as it might help 
to identify gaps in existing protection 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  owners,  operators  and  authorities.  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  possessing  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  diagnostic  laboratories  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; 

Most  Member  States  have  an  overview  of  relevant  facilities  but  some  do  not  have  a 
centralised  list  of  all  relevant  ones.  Developing  secure  registries  is  beneficial  and  in 
particular  would  assist  in  enabling  local  law  enforcement  and  security  officials  to  pay 
closer  attention  to  facilities  containing  particularly  hazardous  biological  agents  and 
toxins.  The  registries  would  enable  countries  to  monitor  such  facilities  and  to  quickly 
follow-up any suspicious activity. The joint experience of the Member States could serve 
as  a  very  useful  basis  for  enhancing  the  security  arrangements  facilities.  Whilst  some 
Member  States  face  less  of  an  immediate  security  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 should 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 
control over CBRN materials  

improve  monitoring  and 

EN 

48 

   EN 

 
by terrorists or other criminals  

4 

4 

Assessment of (relevant) effects 

Economic  impacts:  The  action,  in  its  entirety,  is  potentially  very  costly  especially  for 
Member States which have less developed systems in place (for example, if they face less 
criminal  or  terrorist  threats).  Particularly  resource-intensive  activities  relate  to  the 
development  and  maintenance  of  registries  (securing,  updating,  checking,  etc),  the 
creation  of  the  mechanism  and  the  development  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 refrain from handling certain 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  hence  the  economic  effects  will  also  be  of  a 
smaller scale. This could make the investments 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 dangerous biological agents and toxins. 

Legal effects: The process to verify security arrangements and the mechanism to review 
the  need  for  such  biological  agents  and  toxins  may  need  to  be  supported  by  further 
legislation. 

Assessment of EU-added value 

The  rationale  for  EU  intervention  is  strong,  as  evidence  suggests  that  security 
arrangements  in  some  facilities  may  be  insufficient  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 establishments 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 
control over CBRN materials  

improve  monitoring  and 

4 

4 

EN 

49 

   EN 

 
Assessment of relevant effects 

Economic  impacts:  There  are  relatively  high  costs  associated  with  accreditation  in 
general.  The  action  could  have  negative  effects  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  them  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 processes and setting up the system would also 
need considerable time to be completed. 

EN 

50 

   EN 

 
Financial costs 

Economic impacts 

3 

- 

Assessment of EU added value 

The EU added value is rather low, as a number of Member States already have national 
licensing  and  authorisation  procedures  in  place  which  also  include  security  standards. 
Stakeholders  considered  that  the  action  would  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  together  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. 

2. 

3. 

The  responsibility  of  an  authority  to  assess  the  security  measures  in  place  for 
various types sources;  

Linking  the  results  of  the  above  mentioned  security  assessment  to  the 
licensing/registration procedure;  

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.  

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 
other 
criminals  

or 

To 

2.2 
improve 
monitoring  and  control 
over CBRN materials  

3 

3 

1 

Assessment of relevant effects 

Economic impacts: The costs for developing a good practice guideline are low and would 
mainly  relate  to  the  identification  and  selection  of  good  practices,  meetings  between 
Member States, the preparation of the guideline and its dissemination. 

Financial costs 

Economic impacts 

EN 

51 

   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 already developed a set of very useful guidelines on which any 
further work could be based. There are, in addition, 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  determine  whether  these  should  be  linked  to 
licensing/registration procedures.  

Due to these factors and low stakeholder' support, the action is considered unfeasible. 

Action RN.06 (Enhance control over CBRN substances) 

The  Member  States  should  launch  recovery  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). 

Achievement of (relevant) policy objectives 

access 

2.1  To 
to 
prevent 
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  registration  is  insufficiently  controlled.  Knowing 
where disused high-risk sources are, and in whose possession, is essential to prevent their 
use  for  malicious  purposes  (the  materials  could  potentially  be  used  in  a  “dirty  bomb”) 
and  to  ensure  appropriate  safety  levels.  There  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  leaving  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-activity 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 

52 

   EN 

 
higher  costs.  However,  important  financial  gains  could  be  achieved  through  the 
development  of  the  source  exchange  programme  among  Member  States,  which  would 
allow  for  the  sources  to  be  used  again,  rather  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 availability, 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 the launch of recovery programmes, based on 
early Euratom agreements and legislation. The 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 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. 

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 
in 
of  security  aspects 
publishing 

3 

2 

4 

Assessment of (relevant) effects 

Economic  impacts:  The  costs  for  identifying  good  practices  would  be  low,  involving  a 
mapping study to identify good practices, their validation and organising the exchanges. 
A  study  to  identify  good  practices  would  amount  to  approximately  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 compiling the good practices in an online forum or 
in a publication, etc. 

Financial costs 

Economic impacts 

EN 

53 

   EN 

 
1-2 

-  

Social  impacts:  The  action  could  negatively  affect  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  third  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 require a legislative instrument. 

Assessment of EU-added value 

The  EU  has  a  strong  role  to  play  in  this  area,  as  it  is  responsible  for  overall  migration 
policy. There are known cases of attempts to infiltrate universities and research institutes. 
Not  all  Member  States  apply  background  checks  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 implementation 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 
'security 
culture' 

to  a  high 

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 

54 

   EN 

 
The  rationale  for  EU  intervention  is  weak.  Stakeholders  stressed  that  sufficient 
information was already available at this stage on the implementation of the IAEA Code 
of Conduct and that undertaking a study would 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 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  stakeholders  to  report  such  transactions  to  law-enforcement 
authorities 

Achievement of (relevant) policy objectives 

2.2  To 
control over CBRN materials  

improve  monitoring  and 

2.3 To improve overall awareness of 
the  potential  dangers  and 
risks, 
contributing 
'security 
culture' 

to  a  high 

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 study in the approximate amount of 200.000 
EUR. 

Financial costs 

Economic impacts 

1 

0 

Social impacts: The action could interfere with the right 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  purposes  and  how  this  information  would  be 
processed,  and  which  safeguards  for  individuals  are  provided.  The  action  could  also 
increase  the  public  perception  of  un-safety.  On  the  other  hand,  the  action  increases 
security, and improves the control over high-risk CBRN materials and thus reduces the 
possibility  of  thus  crime  and  terrorism.  The  action  could  also  contribute  to  raising 
standards related to job quality, as it would increase the access of relevant personnel to 
continuous training. 

EN 

55 

   EN 

 
Fundamental  rights:  Reporting  losses  or  suspicious  transactions  might  require  the 
processing  of  personal  data.  The  personal  data  protection  principles  apply  to  all 
processing of personal data by any person whose activities are governed by Community 
law.  Furthermore,  any  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 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 Article 8 ECHR rights. 

Assessment of EU-added value 

There is great scope for EU action in this area, as the EU could steer the identification 
and exchanges of good practices, as well as the development of adequate modalities, thus 
ensuring a more harmonised approach. 

EN 

56 

   EN 

 
Action  H.26  (Improve  the  identification  and  reporting  of  suspicious  transactions 
and behaviour) 

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. 

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, 
'security 
contributing  to  a  high 
culture' 

3 

3 

Assessment of (relevant) effects 

Economic impacts: The costs of this action are medium. The development of guidelines 
would  require  a  mapping  of  criteria  currently  used  in  the  Member  States  and  their 
elaboration  into  an  EU  document.  Member  States  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  provided  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 public perception of unsafety. It would 
be important to emphasise that the criteria concern suspicious behaviour in transactions, 
and  not  behaviour  by  colleagues  or  relatives.  On  the  other  hand,  the  action  could 
certainly contribute to raising security and possibly also to raising 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 area, as the EU could steer the development of 
common  criteria,  ensuring  a  more  harmonised  approach  to  what  constitutes  suspicious 
behaviour and transactions. 

EN 

57 

   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  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  security  rules  fully  cover  all  CBRN 

materials. 

–  Identify  and  exchange  good  practices  in  the  Member  States  concerning  the 
transport  of  high-risk  CBRN  materials  (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 system for the international transport  of 
CBRN  materials  contained  in  the  CBRN  lists  (identified  under  the  risk-
management process). 

–  Consider  the  feasibility  and  costs/benefits  of  introducing  a  requirement  that 
only  licensed  transporters  would  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. 

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 

58 

   EN 

 
Economic impacts: The costs of this action would be low, consisting of fees for expert 
inputs  and  facilitation  and  travel  expenses.  Possibly  additional  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 level 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 encouraging 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  transport  biological  samples,  in  accordance  with 
international regulations, within 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 
'security 
culture' 

to  a  high 

4 

4 

Having  an  EU  capability  and  a  mechanism  to  rapidly  and  safely  transport  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.  Consideration  would  have  to  be  given  to  the  appropriate 
security of such transport. 

The  mechanism  would  need  to  be  accompanied  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  indeed  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 laboratory receiving such 
samples  would  have  to  maintain  an  equally  high  level  of  security.  At  present,  some 
countries experience great difficulties in organising transport, as some carriers refuse to 
handle dangerous substances.  

Assessment of (relevant) effects 

EN 

59 

   EN 

 
Economic  impacts:  The  costs  of  this  action  would  depend  on  its  exact  content.  For 
example,  several  different  activities  could  be  included,  such  as  the  mapping  of 
laboratories  and  their  specific  capacity  to  handle  certain  samples,  the  identification  of 
appropriate carriers, in line with international regulations, as well as agreements between 
the Member States on protocols and transport modalities. The action would bring some 
efficiency  gains  as  some  transport  would  be  dealt  with  centrally,  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  environmental  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 this 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 experienced 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 certain high-risk chemicals. This can be done by encouraging 
and  supporting  the  development  of  relevant  chemical  manufacturing  facilities  at  sites 
which require such  dangerous  chemicals (rather than transporting them).  Enhance links 
between law enforcement authorities and 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 require very substantial investments 
from both relevant Member States and industry, 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 

60 

   EN 

 
Financial costs 

Economic impacts 

3 

-- 

Environmental  impacts:  The  potential  multiplication  of  plans  manufacturing  dangerous 
substances  would  have  negative  environmental  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 action 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 considered 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  chemical  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.  limited  quantities  in  one  transport;  or 
tracking systems). 

–  Identify current good practices in terms 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 system for the international transport  of 
high-risk chemicals identified under the risk-management process mentioned 
in section 1.1.  

–  Consider  the  feasibility  and  costs/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. 

EN 

61 

   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  travel  expenses.  Possibly  additional  procurement  would  be 
required for the feasibility and cost/benefits studies, the identification and exchanges of 
good practices and other analytical tasks. 

EN 

62 

   EN 

 
Financial costs 

Economic impacts 

1 

0 

Assessment of EU added value 

The Committee would be established at EU level and address issues of international and 
EU  concern.  It  would  enhance  the  development  of  a  common  EU  position  and  help  to 
further  harmonise  national  approaches  to  transport.  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  authorities  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' 

Assessment of relevant effects 

3 

1 

Economic impacts: the costs of this action would depend on the arrangements in place at 
national  level.  Whilst  some  countries  already  have  good  links  in  place,  other  Member 
States may have to invest in enforcing such links. This could require some investments 
from  both  transporters  and  law  enforcement,  in  terms  of  setting  up  communication 
protocols and tools, reporting 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, which is highly necessary 
considering the many intra-Community movements 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 

63 

   EN 

 
Because of the above reasons and potentially high cost for some stakeholders, the action 
is considered unfeasible. 

EN 

64 

   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 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 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 
risks, 
and 
dangers 
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 States 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 raising campaigns, the establishment of a toll-
free national number, etc. 

Financial costs 

Economic impacts 

1 

0 

Social impacts: The option could also increase the public perception of un-safety. On the 
other  hand,  a  successful  notification  mechanism  could  help  to  prevent  serious  harm  to 
public health and security. 

Environmental effects: The action could possibly have positive environmental effects, as 
it  would  reduce  the  likelihood  and  scale  of  environmental  risks,  by  improving  the 
information flow between relevant authorities on for example the transport of dangerous 
CBRN materials. 

Assessment of EU-added value 

Several notification mechanisms exist at international and national levels, but most focus 
on notification of (accidental) releases rather than on thefts and losses. Encouraging the 
Member States to set up notification mechanisms covering all CBRN materials, to report 
on  thefts,  losses  and  suspicious  transactions  would  be  highly  beneficial,  as  it  would 
contribute to establishing clear protocols across and entire production and supply chain. 
This  would  strongly  improve  response  capacity  and  ensure  a  higher  level  playing  field 
with regard to notification in the EU. Therefore, there is scope to encourage the Member 

EN 

65 

   EN 

 
States  to  deal  with  CBRN  threats  in  a  comprehensive  manner  and  to  establish  clear 
mechanisms  to  respond  to  losses,  thefts  and  suspicious  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  related  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  mechanism  would  require  continuous 
monitoring, updating and ongoing assessments of whether and when 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  receive  timely  information  from 
relevant authorities on security issues which may affect the chemical facilities they work 
in.  This  would  be  very  beneficial,  as  it  would  allow  for  precautionary  measures  to  be 
taken,  such  as  increased  security  controls  or  even  an  interruption  of  activity.  The 
effective  implementation  of  this  option  could  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  should  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 Database of Illicit Trafficking Incidents 

Achievement of (relevant) policy objectives 

EN 

66 

   EN 

 
2.2  To  improve  monitoring  and 
control over CBRN materials  

2.3 To improve overall awareness of 
the  potential  dangers  and  risks, 
contributing 
'security 
culture' 

to  a  high 

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 control 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 Incidents database). There would be more scope 
in improving the functioning of the 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 details 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 stakeholders when relevant. 

Achievement of (relevant) policy objectives 

3.1 To improve detection and 

3.2 To develop an EU approach 

EN 

67 

   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  relatively  low,  and  would  concern  mainly  the 
coordination  costs,  costs  for  meetings,  identification  of  suitable  methodologies  and 
possibly publication costs. In addition, these activities would lead to cost-efficiencies in 
the  longer  term,  as  Member  States  would  have  more  targeted  detection  work  priorities 
and as industry could better respond their specific needs. 

However, one element of this option could potentially 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 hardware 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  strong,  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 should develop detection  models for  different 
biological  pathogens  and  toxins,  considering  distribution,  possible  vectors,  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 

68 

   EN 

 
sharing  the  work  on  modelling  between  the  EU  Member  States,  important  cost-savings 
can be made.  

Financial costs 

Economic impacts 

3 

0 

Assessment of EU-added value 

As  to  the  development  of  models,  each  biological  agent  has  its  own  characteristics  in 
terms of rapidity of spread, potential coverage and duration of activity. It would therefore 
be very useful to develop specific models for 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 collected 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  should  develop  minimum  detection  standards 
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. 

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  minimum  detection  standards  can  be 
undertaken  at  a  relatively  low  cost.  It  involves,  possibly,  some  financial  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  made.  The  private  sector  would  only  have  to 
comply with a single set of EU standards rather than many specific national ones. They 
would  know,  for  example,  the  specific  design  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 

69 

   EN 

 
Whilst there are clear benefits of an EU approach 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  should  set  requirements  for  the  detection, 
identification and monitoring of pathogens and toxins 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 

70 

   EN 

 
Assessment of (relevant) effects 

Economic  impacts:  The  action  would  require  low  set-up  costs,  but  meeting  the  EU 
minimum requirements might require substantial 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  cater  detection  needs  and  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  minimum  requirements  for 
detection, 
identification  and  monitoring  from  a  quality  and  cost-effectiveness 
perspective, as well as in the light of cross-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,  testing  and  certification  schemes  for  CBRN 
detection in the EU) 

The Member States and the Commission should: 

–  Map out and document the technical requirements 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 requirements 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  scheme  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 

71 

   EN 

 
capability 

identification 

4 

4 

A  common  certification  scheme  would  improve  the  efficiency  of  validating  and 
approving  detection  tools  and  methodologies,  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 creation of a certification, it would be important to 
build  on  the  experiences  in  the  Member  States  and  to  develop  a  scheme  to  which  all 
countries are willing to commit.  

A  common  testing  scheme  would  ensure  harmonisation  of  methodologies  and  tools  for 
detection,  as  all  Member  States  would  effectively  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  development  costs  and  help  stimulate  research, 
innovations  and  improvements,  thus  contributing  to  increased  detection  probability  and 
increased prevention and intervention opportunities.  

EU wide trialling would enable Member States to share information and data and would 
improve  the  overall  effectiveness  and  quality  of  detection.  At  present,  Member  States 
carry out trialling individually, hence a common scheme would 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 potentially 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 natural and geographical differences 
between the Member States. In the longer term, the action could lead to important cost 
savings,  if  Member  States  would  mutually  accept  certification,  testing  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 development of legislation especially to 
ensure mutual recognition of results. 

Assessment of EU-added value 

There  is  a  strong  rationale  for  EU  intervention  in  this  area,  as  common  certification, 
testing  and  trialling  could  increase  the  overall  level  and  quality  of  detection  across  the 

EN 

72 

   EN 

 
EU  and  encourage  a  more  harmonised  approach.  However,  ultimately  the  choice, 
purchasing  and  deployment  of  detection  systems  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  would  lead  to  an  EU  overview  and  learning 
between Member States. 

Action  B.18  (Identify  good  practices  related  to  detection  of  CBRN  materials, 
awareness raising and training) 

Member States and the Commission should initiate: 

–  The  development  of  mobile  detection, 

identification  and  sampling 
capabilities  at  the  EU  level  to  be  undertaken  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). 

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,  particularly  if  it  becomes  apparent  that  an  outbreak  was 
caused  deliberately,  would  prove  invaluable  in  responding  to,  and  at  least  initially 
identifying  the  use  of  a  particular  biological  agent,  thus  reducing  the  amount  of  time 
before appropriate medical and other responses can be initiated and increasing the chance 
of  finding  forensic  clues.  Whilst  having  a  mobile  solution  for  sampling  and  initial 
detection  could  be  very  useful  in  certain  cases,  further  detection,  identification  and 
analyses could take place in the most appropriate 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  laboratory  facilities.  Consideration  would  also 
have to be given to the appropriate security of such mobile laboratories. Developing such 
capability at the EU level would ensure the centralisation 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  representatives.  A  mobile  detection  capability,  able  to 
deal with all biological substances, is potentially very costly. Several industrial solutions 
currently exist, but these do not do not yet cover the full spectrum. 

Financial costs 

Economic impacts 

EN 

73 

   EN 

 
3 

0 

Environmental  impacts:  Possibly  positive  impacts  as  the  mobile  unit  may  reduce 
transport needs and if the network would assist in the identification of the closest most 
relevant reference laboratory. 

EN 

74 

   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 capacities. The mobile unit could be deployable 
throughout  the  EU  and  address  emergency  situations.  This  would  in  particular  help 
Member States with less 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 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. 

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  locations,  particularly  when  deployed  covertly, 
allows the ability to check for biological agents and maintain security, while minimising 
any inconvenience or delays to both the public and commercial trade. The exchange of 
such knowledge and technology amongst Member States, if carefully controlled to ensure 
the maintenance of security, would prove equally 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  security  relevant  areas  requires  potentially 
high levels of funding. Relatively lower levels of financial inputs would be required for 
the  exchanges  of  best  practices,  in  relation  to  the  identification  of  the  good  practices, 
their compilation and their exchange, for example through events or papers, etc. 

Financial costs 

Economic impacts 

3 

0 

Social impacts: There is a remote possibility, depending on the location of the 'security 
relevant  areas',  the  measures  could  inhibit  free  movement  and  /or  target  specific  social 

EN 

75 

   EN 

 
groups.  On  the  other  hand,  the  action  would  increase  public  security,  and  improve  the 
chances of the detection of material that could be used for criminal or terrorist purposes. 

EN 

76 

   EN 

 
Assessment of EU-added value 

EU level projects performing measurements of biological background at security relevant 
areas  and  exchanges  of  good  practices  would  increase  overall  security  levels  and 
harmonise approaches, national projects could, on the other hand, increase fragmentation. 

5.2.3.  CBRN preparedness and response 

Action H.45 (Improve response plans) 

The  Member  States  and  the  Commission  should  develop  and  conduct  regular  exercises 
and  training  at  all  levels  (national,  European  and  international),  involving  and  testing 
cooperation of all relevant organisations, particularly 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 coordination 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 exercises and training, these may not cover the full 
CBRN spectrum or specifically target security issues (as opposed 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  preparedness  of  relevant  personnel,  the  action  could  also 
contribute  to  raising  standards  related  to  job  quality,  as  it  would  increase  the  access  of 
relevant personnel to continuous training and exercises. 

Assessment of EU-added value 

The EU has an important role to play in ensuring that exercises and training are provided 
in all Member States, that they include some common elements and that they cover EU-

EN 

77 

   EN 

 
wide  or  cross-border  elements.  This  also  justifies  the  proposal  to  assign  a  coordinating 
role to the Commission of relevant exercises. 

EN 

78 

   EN 

 
Action B.21 (Improve response plans) 

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; 

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  working  group  and  to  ensure  regular 
communication  opportunities  (meetings,  virtual  exchanges,  etc)  are  low.  For  example, 
the  set  up  and  preparatory  work:  (e.g.  background  study,  identification  of  experts,  etc) 
would amount to around 200,000 EUR, the creation of a website / virtual forum would 
cost around 20,000 EUR and inputs to the development of the bio-checklist 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  four  meetings  per  year  of  a  group  of  30 
persons:  (e.g.  travel,  subsistence,  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  field  is  to  be  considered,  specifically  as 
many  of  the  elements  proposed  are  already  covered  through  more  general  actions 
addressing  all  CBRN  materials.  Whilst  biological  agents  and  toxins  have  very  specific 
features,  there  would  still  be  scope  in  addressing  CBRN  as  a  whole  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 

79 

   EN 

 
Awareness should be raised 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 provided on the emergency measures envisaged to alert, protect and assist 
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. 

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 posters to national television 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 environment could 
create the perception of low security and lead 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 stakeholder support, it is considered 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 see that the emergency plans drawn up would be implemented 
in the event of a real emergency. 

EN 

80 

   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  require  higher  investments,  depending  on  the 
modalities of its organisation. 

Financial costs 

Economic impacts 

1-2 

0 

Social  impacts:  The  action  could  have  negative  social  effects,  as  it  could  create  a 
perception  of  low  security  and  lead  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 option received very little stakeholder support and raises some subsidiarity issues. It 
is  in  principle  the  responsibility  of  the  Member  States  to  define  whether  and  how  to 
inform the public based on national experience and procedures.  

Due to these factors, the action 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  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. 

Achievement of (relevant) policy objectives 

EN 

81 

   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  the  action  would  include  mapping,  analysis  and 
reporting.  Any  additional  steps,  for  example  Member  States  increasing  their  vaccine 
stockpiling, would be very costly. For example, the 2009 US Strategic National Stockpile 
(SNS), the main program for vaccine, medication, 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 amount 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 the 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 several assessments without specifying the role of 
the EU or the possible next steps following these assessments. 

Action B.22 (Strengthen the EU’s countermeasure) 

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 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  eventual 

threat; 

EN 

82 

   EN 

 
–  Build  an EU  wide coordinated approach 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  are  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  exploring  an  EU  approach  towards  medical  countermeasure 
capacity, in particular if the assessments proposed under Action H.46 would confirm the 
need. An EU approach would also help Member States to share the potential burden. 

Action B.23 (Strengthen the EU’s countermeasure capacity) 

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. 

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 

83 

   EN 

 
Economic  impacts:  The  costs  for  setting  up  the  mechanisms  for  rapid  licensing  and 
exemptions  are  relatively  low  and  would  mainly  be  administrative.  There  could  be 
negative  economic  effects  on  competition  and  the  functioning  of  the  internal  market 
should the mechanism be activated, given that certain pharmaceutical companies would 
be  exempted  from  standard  procedures  and  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 reduce deaths and injuries and increase the security of citizens. 

Legal effects: Additional legislation might be required to create the mechanisms for rapid 
licensing procedures. 

EN 

84 

   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  mechanism,  especially  because  some  Member 
States will have a better capacity than others to effectively produce the required medical 
products. 

Action  H.49  (Improve  domestic  and  international  information  flows  in  case  of 
CBRN emergencies) 

Member  States  should  exchange  information  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 information 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 reduce 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 States are mainly a national affair. 

Action  R.27  (Improve  domestic  and  international  information  flows  in  case  of 
CBRN emergencies) 

The Member States and the Commission should consider integrating and building upon 
existing  platforms  for  international  exchange  of  information  during  nuclear  emergency 
situations, as well as assessing their applicability to all radiological and nuclear incidents 

EN 

85 

   EN 

 
of  concern  (scenario-based).  An  effort  should  be  made  to  assess  the  possibilities  of 
streamlining alert messages going through different rapid alert systems. 

EN 

86 

   EN 

 
Achievement of (relevant) policy objectives 

4.1  To 
emergency 
protocols, also at the EU level 

improve  response  and 
and 

planning 

ensure 

4.3 
To 
information  flows 
CBRN emergencies 

ongoing 
in  case  of 

4 

4 

Assessment of (relevant) effects 

Economic impacts: The costs of reviewing existing platforms for international exchanges 
of  information  would  be  relatively  low,  as  this  would  imply  a  mapping  and  possibly 
some  discussions  with  relevant  organisations  responsible  on  their  scope  and  coverage. 
The  effective  streamlining  of  rapid  alert  systems,  in  terms  of  adapting,  expanding  and 
maintaining  these,  could  require  relatively  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 reduce deaths and injuries. It would also increase the security 
of citizens.  

Assessment of EU-added value 

The  EU  rationale  for  this  action  is  to  be  considered.  The  platforms  and  systems  under 
consideration  are  international  and  it  may  therefore  not  be  possible  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  actions  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 and 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  into  the  four  main  strands 
(Actions  applicable  to  prevention,  detection  and  response;  Prevention;  Detection;  and 
Preparedness and Response). A schematic overview is presented below. 

EN 

87 

   EN 

 
Due to the fact that the current situation and differences between Member States is not 
completely clear at this stage, many of the proposed actions will require a mapping study, 
before its implementation starts. 

EN 

88 

   EN 

 
Table 7: Actions by strand and type 

Actions applicable to 
prevention, detection, 
and response 

Prevention 

Detection 

Preparedness and 
response 

Total 

Horizon
tal 

C 

B 

R/N 

Total 

19

13

10

5

17

1

15  

6

7

7

3

57

23

23

1 

21 

2 

6 

30 

31

58

20

24

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 policy actions necessary to achieve the impact 

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 effectiveness of international 
cooperation,  coordination  and  dialogue  on  CBRN.  Several  of  the  actions  included  in  the  Action  Plan,  across  the 
various strands, would in particular, lead to: 

Relevance 

– 

increased mapping of existing international cooperation and coordination mechanisms addressing CBRN issues, 
thus providing an opportunity to identify gaps, possible areas of duplication and new opportunities. 

–  more focused coordination and cooperation 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,  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; 

taking  the  first  steps  towards  a  common  EU  position  on  certain  issues  in  international  forums,  as  well  as 
working  towards  the  achievement  of  common  EU  objectives.  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  guidelines  for  communication  and  their  integration  into 
emergency plans. 

The  positive  impacts  will  apply  to  all  Member  States,  especially  to  those  that  so  far  have  been  less  engaged  in 
international  coordination  and  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  awareness  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 

89 

   EN 

 
 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

Relevance 

–  map, identify and exchange good practices on security; 

–  map  existing  international  and  EU  legislative  instruments  with  a  view  to  verifying  whether  these  adequately 

cover terrorist or criminal acts related to CBRN materials; 

–  develop inventories or libraries of resources on CBRN materials, so that relevant actors can quickly have access 

to good-quality information; 

– 

– 

establish  an  Early  Warning  System  on  CBRN-related  incidents  as  well  as  other  ensuring  other  information 
flows, making sure that all relevant EU and national actors are informed of threats, losses, thefts, etc enabling 
them to undertake timely action;. 

training  of  various  stakeholder  groups,  including  first  responders,  local  authorities,  EOD  experts,  laboratory 
staff,  facility  managers  and  other  employees,  etc,  to  make  them  understand  the  potential  dangers  of  CBRN 
materials and to improve their capacity to prevent, identify and respond to incidents involving CBRN materials. 

The positive effects would benefit all Member States,  as all countries would benefit from 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 prevented, identified and responded to. 
Some of the actions may encounter some level of reluctance, 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 specific 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  would  help  to  address  some  barriers  and  obstacles  which 
currently inhibit European common 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 mutual recognition of forensic evidence; 

assess the possibility to encourage mutual recognition in the area of personnel vetting. 

Other actions included in the preferred policy option would also help to further this objective, such 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, legal and practical barriers and constraints can be effectively attained heavily depends 
on the commitment of the Member  States. However, several international and EU developments in this area  have 
proven  that  there  is  an  interest  in  at least  harmonising  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  materials  throughout  the  supply  chain  are  verified,  thus 
reducing the possibility of criminals and terrorists gaining access; 

improved  identification  and  exchanges  of  good  practices  in  the  area  of  security  checks  with  international, 
European and national partners, enabling in particular Member States with less advanced approaches and less 

EN 

90 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

capacity to learn from countries with more experience and expertise; 

Relevance 

– 

strengthened  management  structures  in  CBRN  facilities,  so  that  personnel  are  adequately  and  regularly 
appraised and monitored; 

–  The establishment of registries of personnel having access to or information 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  development  of  minimum  training 

requirements and guidelines for persons working with, having access to or handling CBRN materials. 

–  Education and training of various stakeholder groups laboratory 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 advanced 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 contribute to this specific objective include actions 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 existing 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 research, 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 partners 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,  detection  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 force as particularly relevant. 

All Member States would greatly benefit from increased research efforts at the European level, in particular those 
that may not have sufficient resources available to launch research projects themselves. The increased mapping and 
cooperation will strongly help to prioritise research and select the most relevant and urgent projects. 

Actions  that  would  in  particular  contribute  to  this  specific  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 the security implications in 
funding decisions and scientific research projects and activities. This would be beneficial as knowledge of what the 
potential  security  aspects  are  can  help  funding  organisations  and  other  stakeholders  to,  where  necessary,  take 
precautions. 

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.18 

The action that would in particular contribute to this specific objective is H.17 

EN 

91 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

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,  mainly  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 and used CBRN materials, for example by: 

Relevance 

2.2 To improve monitoring 
and control over CBRN 
materials  

4 

–  developing EU lists of high-risk CBRN materials, based on a risk-management analyses, to focus measures on 

substances of specific security concern; 

– 

– 

enhancing  the  security  of  CBRN  materials  within  facilities,  through  the  development  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 security arrangements in high-risk CBRN facilities, improving 
links  to  law  enforcement  authorities,  improving  licensing  requirements  and  laboratory  standards  related  to 
security; 

– 

encouraging the chemical industry to replace, where possible, high-risk chemicals with suitable alternatives; 

– 

identification and exchanges of good practices in these areas. 

The  actions  would  help  the  Member  States  to  target  their  efforts  to  increase  the  security  on  the  most  relevant 
materials and facilities. They would also help to harmonise the current national approaches to facility and material 
security, by working towards common requirements and standards. 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 therefore strongly depend on their national willingness and 
commitment. 

Actions that would in particular contribute to this specific 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. 

The  preferred  policy  option  includes  a  number  of  actions,  mainly  under  the  Prevention  strand,  which  would 
contribute  to  improved  monitoring  and  control  over  CBRN  materials  (in  particular  chemical  and  radioactive 
materials, as these are most traded and transported), in particular in terms of accounting, information exchanges and 
reporting on threats, losses and other incidents, transport and import and export. Relevant action proposed include: 

– 

– 

– 

– 

increased compliance with international 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  ensure  that  CBRN  substances  are  appropriately  recorded 
and monitored and to reduce the chances of such materials being lost or stolen; 

improved  communication  and  information  exchange  on  threat  levels,  thefts,  losses  and  incidents,  through  the 
development of links to authorities, 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 includes 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  hands.  The  actions  would  also  help  to  harmonise  the 
current national approaches, by promoting good practices and exploring the adoption of international or EU tools, 
standards  and  requirements.  A  number  of  actions  mainly  consist  of  action  to  be  taken  at  Member  State  level  and 
their success would therefore strongly depend on their national willingness and commitment. 

Actions that would in particular contribute to this specific objective include actions C.15, RN.5, C.16, RN.6, C.17, 

EN 

92 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy 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. 

improve 

overall 
2.3  To 
awareness  of 
the  potential 
dangers and risks, contributing 
to a high 'security culture' 

3 

There  are  several  actions,  mainly  under  the  Prevention  strand  which  would  contribute  towards  a  high  ‘security 
culture’, with persons working with and having access to CBRN materials being 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 area of suspicious transactions and behaviour, in terms 
of reporting and modalities for reporting; 

the  development  of  specific  security  training  on  radiological  and  nuclear  materials  and  for  private  sector 
security staff. 

The actions would encourage Member States to improve their current training and awareness-raising activities, as 
well as to place increased focus on suspicious transactions and behaviour, in terms of reporting and modalities for 
reporting. The actions would also help to harmonise the current national approaches, by promoting good practices 
and exploring the adoption of international or EU programmes and requirements.  

Actions that would in particular contribute to this specific 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  and  identification  capacity  and 
capability, through a combination of measures focused on: 

– 

– 

the  identification  and  exchanges  of  good  practices  in  the  area  of  awareness  raising,  training  and  exercises, 
exchanges of scenario and modelling approaches and information between the Member States; 

improving  communication  and  information  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 their 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 overall, as the area to be covered by detection is very 
wide, as well as enable Member States with less advanced approaches to learn from their peers.  

Actions that would in particular contribute to this specific 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,  would  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 information, 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 certification 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  and  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 

93 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

B.17, H.39, B.18, RN.23, B.19 

Relevance 

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 option, in particular as part of the Preparedness and Response 
strand,  will  contribute  to  improving  response  and  emergency  planning  at  both  national  and  EU  levels.  The  most 
relevant activities proposed include: 

– 

a  mapping  of  existing  state  structures  and  identification  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 stakeholders involved in emergency and response plans. 

The actions would improve overall response 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 their success would therefore strongly depend 
on their national willingness and commitment. 

Actions that would in particular contribute to this specific 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,  mainly  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 exercise at EU level to improve overall response plans, as well as the provision 

of guidance to medical staff. 

–  Exchanges  of  information  on  emergency  plans,  also  taking  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 integration with international platforms. 

Actions that would in particular contribute to this specific 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  Preparedness  and  Response  strand,  which  would  increase  the 
effectiveness of domestic and international information flows in case of CBRN emergencies, such as: 

– 

increased  exchanges  of  information  between  the  Member  States  on  their  approaches  to  handling  CBRN 
emergencies; 

–  measures  to  improve  information  flows  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  protocols  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  therefore  strongly  depend  on  their  national  willingness  and 
commitment. 

Actions that would in particular contribute to this 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 forensic approaches, for example through: 

– 

encouraging  Member  States  to  increase  forensic  awareness  of  in  particular  first  responders  in  a  CBRN  crime 
scene, thus ensuring that important evidence is not destroyed; 

EN 

94 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy 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 and 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 specific 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,  mainly  within  the  Preparedness  and  Response  strand,  which 
would  increase  national  and  EU  countermeasure  capacity  in  terms  of  therapeutics,  vaccines,  diagnostics, 
decontamination and overall medical capacity, for example by: 

– 

– 

– 

encouraging  Member  States  to  review  their  countermeasures  and  overall  medical  capacity  in  order  to  assess 
their possible needs in case of a CBRN incident, as well as the exchange of good practices in this regard. This 
would  also  include  assessing  the  possible  sharing  of  medical  countermeasures  and  the  development  of  rapid 
licensing mechanisms; 

the involvement of the Health Security Committee to further study the establishment of therapeutics and vaccine 
stockpiling, scaling up diagnostic capacity and EU coordination in the field of medical countermeasures; 

increasing the decontamination capacity of Member States, through assessing the available means and capacity 
and studying further decontamination 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 specific objective include actions H.46, H.47, B.22, B.23, H.49, 
H.51, H.51 

Expected impacts 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

Rating 
(from 
Low 
High) 

to 

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  stakeholders.  Such  costs  would  relate,  for  example,  to  studies, 
mapping activities, identification and dissemination of good practices, participation in networks, meetings and other 
events.  

It is estimated that around 18 actions could potentially imply high financial costs. These relate, for example, to the 
funding  of  new  research  in  all  CBRN  areas,  the  establishment  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, trialling and certification schemes for detection systems and equipment. The exact 
costs are difficult to estimate at this  stage. However, costly 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 implementation of the Action plan are difficult to assess precisely, as these will depend on 
several factors, e.g. the length of the EU lists. It is worth noting however that even if the aggregate costs of these 
actions could run into several tens of millions euro, this would be divided between different 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 time to adequately plan 

Assessment Criteria 

Financial and economic 
impacts 

EN 

95 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

Social impacts 

Medium 

Environmental impacts 

Very low 

Impacts on fundamental rights 

Low 

Relevance 

for  such  costs.  In  addition,  the  existing  financial  programmes,  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 programmes 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 effects in terms of competitiveness or the internal market 
of a minor number of actions (not more than 5) relating to rapid licensing, increased screening of visiting staff from 
third  countries,  funding  organisations  having  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 such as Sustainable Development Strategy or Strategy for 
Growth and Jobs. 

The  majority  of  actions  included  in  the  preferred  policy  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  perception  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 also 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  social  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 screening of staff from third countries 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 and 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. 

The assessment of the preferred policy options does not consider indirect environmental effects for each proposed 
action. Nevertheless, it needs to be stressed that the consequences of a potential CBRN incident could be devastating 
for the environment. Improving the prevention, 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 impacts could be positive. This concerns a positive environmental impact if an 
action  putting  additional  security  requirements  for  laboratories  dealing  with  high-risk  agents  and  toxins  would 
reduce the number of laboratories handling such substances, and a positive effect if an EU mechanism would ensure 
the rapid and safe transport of biological samples. A potential negative environmental impact was identified in the 
case  of  large-scale  trialling,  and  to  a  lesser  extent  testing,  of  detection  equipment  and  systems,  which  could  have 
negative effects on the environment or bring certain risks to the environment. 

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-discrimination  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 recognition of vetting procedures throughout the EU could facilitate 
taking up work in similar areas in other Member States. 

There are also 3 actions which deal with notifying and reporting suspicious transactions. These might represent an 
interference with the concerned person’s private life and his or her right to protection of personal data (Articles 8 
ECHR, Article 7 and 8 EUChFR) and must be duly justified and 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 ECHR will be considered to be an acceptable limitation by the State of an individual’s Article 8 
ECHR. Provided that adequate protection of personal data is ensured, the content and actual implementation of the 
actions can however be such that these effects do not occur at all.  

EN 

96 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Impacts on EU legislation 

Low 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

Relevance 

Ten actions could, depending on the chosen modalities of implementation, require 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 costs for having to deal with different sets of standards 
and  certification),  as  well  as  a  security  rationale  (some  Member  States  do  not  have  any  standards  in  place  and  in 
others these are insufficient, hence increasing the chances of CBRN materials 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 legislation, but of practices based 
on national legislation. For example, there 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  whether  such  acts  are,  and  are 
appropriately, penalised in the Member States. 

Actions that could potentially require legislation at EU level 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  these  would  lead  to  rigid  background  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  identification  and  reporting  of  suspicious  transactions.  Due 
care should be given that transactions requested from certain 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, also 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 investments 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 current 27 different sets of requirements.  

Feasibility 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

The implementation of the preferred policy option is considered to be overall feasible. The Action Plan is based on a 
thorough,  long-term  consultation  exercise  through  expert  groups,  green  papers,  workshops  and  the  CBRN  Task 
Force. This has helped to gain momentum and to create overall consensus on the need to address CBRN threats. 

The  structure  of  the  Action  Plan  is  graduated,  as  it  envisages  different  implementation  periods  for  different 
individual  actions.  Whilst  some  may  seem  relatively  ambitious,  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  individual  actions,  could  be  very 
challenging. A multitude of activities across the different strands and for different 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 relevant stakeholders involved 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  regular  updates  of  activities  within  their  strand  or  group  of 

Assessment Criteria 

Implementation feasibility 

Rating 
(from 
Low 
High) 

to 

Medium 
to High 

EN 

97 

   EN 

 
Assessment Criteria 

Rating 
(from 0 - 
5) 

Motivation of the rating and aspects of the policy actions necessary to achieve the impact 

actions. 

Relevance 

Financial feasibility 

Medium 
to High 

As highlighted under the section discussing the financial and economic impacts, the Preferred policy option will, as 
a  whole,  require  some  financial  inputs  to  start  up  and  run  the  activities  planned  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 different implementation levels (EU, Member States, public and private actors); 

– 

the costs would be spread over several years; 

– 

there are important financial gains to be made on the longer term 

– 

a significant part of the financing will be provided by the EU financial 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  consultation  exercise  between  Member 
States, experts and private sector. The Green papers provided 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  political  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  that  representatives  were  closely  liaising  with  their 
national partners and that, on a regular basis, 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  identified  (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 current situation and differences between Member States is not 
completely clear at this stage, many of the proposed actions will require a mapping study, 
before its implementation starts. 

The  following  table  presents  a  summarised  description  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 

98 

   EN 

 
No. 

Policy action 

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  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  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. 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

Exchange  of 
information 

From 
2009 

Commission  X 

C.03  The  Member  States  should  organise  regular  exercises  concerning  the 
security of chemical facilities in order to test preparedness measures in 
place and raise awareness among staff. 

Organisation 
of exercises 

From 
2010 

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 and postgraduate students. 

H.12  The Member States and the Commission should develop and introduce 
common  graduated  criteria  for  background  checks  and  vetting 
requirements in relation to personnel 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-risk  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. 
H.13  The Member States and the Commission should identify and exchange 
good practices on approaches to security of non-EU visiting staff and 
students; Member States should aim at common procedures across the 
EU. 

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.  

Identification 
of 
best 
practices 

2010-
2012 

X 

Member 
States, 
Commission 
Member 
States, 
Commission, 
relevant 
stakeholders 

Potentially 
legislative 

From 
2011 

Member 
States, 
Commission, 
EU agencies 

Potentially 
legislative 

2010-
2012 

Member 
States, 
Commission 

2010-
2011 

Member 
States 

EN 

99 

   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 other publications into account, as well 
as  the  suitability  of  the  funds  receiver  (from  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. 

Funding  of 
research  

From 
2010 

Member 
States, 
Commission, 
relevant 
stakeholders 

2) Prevention strand 

N
o. 

H.
20 

H.
22 

C.
07 

C.
10 

B.
08 

R
N.
06 

Policy action 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

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. 

From 
2010 

Potentiall
y 
legislativ
e 

Member 
States, 
Commiss
ion,  EU 
agencies 

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. 
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. 

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  whether 
these security plans satisfy the necessary level of protection requirements. 
The  Member  States  and  the  Commission  should  develop  a  high  level 
approach  to  chemical  facility  security  which  identifies  key  objectives  and 
steps  to  be  taken  in  order  to  increase  security,  based  on  national  risk 
assessment approaches. 

 The Member States should establish:  
• A secure registry of facilities possessing 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 diagnostic laboratories 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;  
The Member States should launch recovery 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).  

2011-
2015 

From 
2010 

2011-
2015 

2010-
2014 

Member 
States, 
Commiss
ion,  EU 
agencies 
Member 
States 

Member 
States, 
Commiss
ion,  EU 
agencies 
Member 
States, 
Commiss
ion, 
relevant 
stakehold
ers 

X 

X 

2011-
2015 

Member 
State, 

X 

Identifica
tion 
of 
good 
practices 

Potentiall
y 
legislativ
e 

Potentiall
y 
legislativ
e 

Potentiall
y 
legislativ
e 

Coordina
tion  and 
informati
on 
exchange 

R

The  Member  States  and  the  Commission  should  engage  with  research  Potentiall

From 

Member 

EN 

100 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
N
o. 

N.
13 

H.
25 

H.
26 

H.
27 

B.
13 

H.
32 

Policy action 

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. 
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 stakeholders to report such transactions to law-enforcement 
authorities 
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. 

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  services  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  materials  (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 system for the international transport 
of CBRN materials contained in the CBRN lists (identified under the risk-
management process) 
•  Consider  the  feasibility  and  costs/benefits  of  introducing  a  requirement 
that  only  licensed  transporters  would  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. 
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. 
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 information for relevant local law enforcement 
authorities. 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

2010 

y 
legislativ
e 

From 
2010 

Identifica
tion 
of 
best 
practices 

From 
2010 

2011-
2015 

Identifica
of 
tion 
best 
practices, 
developi
ng 
guideline
s 
Identifica
tion 
of 
best 
practices 

States, 
Commiss
ion,  EU 
agencies 

Member 
States, 
Commiss
ion,  EU 
agencies 

Member 
States, 
Commiss
ion,  EU 
agencies 

Member 
States, 
Commiss
ion,  EU 
agencies 

Potentiall
y 
legislativ
e 
Informati
on 
exchange 

2010-
2014  

2011-
2012 

Member 
States, 
Commiss
ion 
Member 
States, 
Commiss
ion,  EU 
agencies 

EN 

101 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Policy action 

N
o. 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

C.
22 

The  Member  States  and  the  Commission  should  consider  establishing  an 
alert mechanism in order to quickly transfer security related information to 
security managers in facilities in which high-risk chemicals are present. 

Informati
on 
exchange 

2011-
2012 

Member 
States, 
Commiss
ion,  EU 
agencies 

3) Detection strand 

No. 

Policy action 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

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 

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 

H.37  The  Member  States  and  the  Commission  should  develop  minimum 
the  context  of  border 
detection  standards 
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. 

(including  within 

Minimum 
standards 
development 

2012-
2014 

Member 
States, 
Commission, 
EU agencies 

Member 
States, 
Commission 
Member 
States, 
Commission 

B.16  Member  States  and  the  Commission  should  set  requirements  for  the 
detection,  identification  and  monitoring  of  pathogens  and  toxins 
within a civilian security context at the EU level 

Development 
of standards 

2012-
2014 

Member 
States, 
Commission 

Potentially 
legislative 

From 
2011 

X 

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 set requirements 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 scheme 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. 

B.18  Member States and the Commission should initiate: 

•  The  development  of  mobile  detection,  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 

102 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
•  The  establishment  and  maintenance  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. 

4) Preparedness and response strand  

No. 

Policy action 

H.45 

B.21 

H.47 

B.22 

B.23 

The  Member  States  and  the  Commission  should  develop  and 
conduct  regular  exercises  and  training  at  all  levels  (national, 
European and international), involving and testing cooperation of all 
relevant  organisations,  particularly  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 coordination of relevant exercises at EU 
level. 
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; 
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  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. 
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 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 
eventual threat;  
•  Build  an  EU  wide  coordinated  approach  to  access  medical 
countermeasures allowing adequate protection of the EU population, 
based on risk assessment. 
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. 

Exchange  of 
good 
practices 

From 
2010 

Member 
States, 
Commission 

T
y
p
e

o
f
a
c
t
i
o
n

i

T
m
e
o
f

i

m
p
l
e
m
e
n
t
a
t
i
o
n

R
e
l
e
v
a
n
t
a
c
t
o
r
s

P
o
t
e
n
t
i
a
l
l
y
c
o
s
t
l
y

Organisation 
of exercises 

From 
2010 

X 

Member 
States, 
Commission, 
EU agencies 

Development 
of 
good 
practices 

2011-
2014 

Problem 
identification 

2011 

Coordination 

2011-
2014 

Member 
States, 
Commission, 
relevant 
stakeholders 

Member 
States 
supported  by 
the 
Commission 

Member 
States, 
Commission, 
relevant 
stakeholders 

Potentially 
legislative 

2012 

Member 
States, 
Commission, 
relevant 

EN 

103 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
H.49 

Member  States  should  exchange  information  on  emergency  plans 
regarding CBRN incidents, involving all relevant agencies.  

Information 
exchange 

RN.27  The Member States and the Commission should consider integrating 
and  building  upon  existing  platforms  for  international  exchange  of 
information  during  nuclear  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. 

Information 
exchange 

From 
2010 

stakeholders 

Ongoing  Member 

States, 
Commission 
Member 
States, 
Commission, 
EU agencies 

As mentioned earlier, actions involving legislative 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 option on actions involving cooperation between 
Member  State  authorities  and  other  stakeholders,  cooperation  with  international 
stakeholders and cooperation within Member States. The EU is well placed to lead and to 
act  as  a  catalyst  for  this  cooperation.  It  would  also  favour  the  development  of  an  EU 
position in the international arena. 

The cooperation proposed ranges from the exchanges of experiences and good practices 
in some actions to exchanges of information and intelligence that could have operational 
significance  in  others.  These  actions  could  all  help  reinforce  channels  for  bilateral  and 
multilateral cooperation between Member States. 

In  some  cases  the  cooperation  concerns  the  exchange  of  experience  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 between 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  proposed  build  upon  existing  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,  psychological  effect,  etc,  the  actions  targeted  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  approach  is  needed.  Information  on  existing 
vulnerabilities in Europe is of course classified, however based on the last reports on the 
CBRN  threat,  evidence  of  such  possibilities  does  exist.  There  are  several  examples 
among  the  actions  proposed,  where  a  cross-border/EU  element  is  obvious.  These  for 

EN 

104 

   EN 

 
 
 
example include activities related to information exchange, international co-operation or 
transport security, and security vetting. Furthermore, many of the measures proposed are 
based on the internal market principle. Proposing an EU approach 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  Preferred  policy  option  involve,  are  or  likely  to 
includes  funding  for  cooperation,  mapping  and 
involve  EU  expenditure.  This 
identification  of  good  practices,  working  groups,  research  and  the  development  of 
testing,  trialling  and  certification  schemes  for  detection  systems  and  equipment.  Whilst 
normally  the  costs  of  the  latter  would  be  met  by  producers,  there  is  a  strong  public 
interest in ensuring that detection equipment and systems work in practices. 

Expected take-up among relevant stakeholders 

The  expected  take  up  among  relevant  stakeholders  is  very  high,  due  to  the  fact  that  all 
actors  that  will  have  to  implement  the  Action  Plan  participated  actively  in  its 
development through the wide EU consultation, 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 and private experts from all relevant sectors 
and  from  all  Member  States.  The  experts  have,  together  with  the  Commission,  already 
extensively discussed the possible 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 inclusion in the Action Plan.  

All actions that are presented  and assessed in this report have already been extensively 
reviewed,  further  shaped  and  validated  by  experts  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 consultation phase, and have led to discarding a 
number of actions from the preferred policy option.  

Such  an  approach  has  ensured  that  ownership  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, which will assist in providing advice on 
the implementation of the Action Plan. Other relevant 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 been identified as necessary 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 

105 

   EN 

 
used across the board. A prime example of the benefits of a coordinated approach relates 
to security vetting for those persons who have access to CBRN  materials  –  clearly  this 
requires  a  consistent  approach  for  all  materials.  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 materials which are the easiest to obtain. The 
approach  taken  avoids  the  possibilities  of  a  fragmented  approach  towards  different 
sources  of  threats  and  relevant  stakeholders,  for  example  prevention  planners,  first 
responders,  critical  infrastructure  operators,  complying  with  different  sets  of  rules  and 
different systems. 

EN 

106 

   EN 

 
7. 

MONITORING AND EVALUATION 

The  timeframe  proposed  for  the  initial  implementation  of  the  CBRN  Action  Plan  is  3 
years. This period should be long enough for significant 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 first evaluation takes place. 

Due to the nature of CBRN threats, the implementation 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 start immediately following its adoption by the 
Council.  The  implementation  of  the  vast  majority  of  measures  identified  in  the  CBRN 
Action Plan will be completed or underway in the period 2010-2013.  

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, which will assist in providing advice on the implementation of 
the  Action  Plan.  Over  the  course  of  the  initial  three  year  period,  regular  reporting  and 
monitoring of the implementation will also take place through the continued involvement 
of relevant Council Working Group(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  and  define  the  implementation  priorities  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 applicable 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 details (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.  Additional  indicators  could 
relate  to  the  implementation  of  security  plans  at  CBRN  facilities,  as  well  as  measures 
adopted to increase the security of transport, the adoption of codes of conduct etc.  

The  main  monitoring  and  evaluation  arrangement  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 

107 

   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 

108 

   EN 

 
ANNEX 1: CBRN GLOSSARY 

AAAS 

ACDP 

ADN 

American Association for the Advancement of Science 

Advisory Committee on Dangerous Pathogens 

International  Carriage  of  Dangerous  Goods  by 
Waterway Regulations 

Inland 

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  Guidance  System  -  Decision  Support 

System 

BSS 

Basic Safety Standards 

BTWC 

Biological and Toxin Weapons Convention 

BWC 

CA 

Biological Weapons Convention 

Competent Authority 

CBRN 

Chemical, Biological, Radiological and Nuclear 

CCPNM 

Convention on the Physical Protection of Nuclear Material  

CCS 

Civil Contingency Secretariat (UK) 

CDHS 

United States Center for Homeland Security and Defence 

CEFIC 

European Chemical Industry Council 

CEN 

COBRA 

European Committee for Standardisation (Comité Européen de 
Normalisation) 

Civil  contingencies  committee  leading  responses  to  national 
crises (UK) 

COSHH 

Control of Substances Hazardous to Health Regulations 

CPS&Q 

Consumer Products Safety & Quality 

EN 

109 

   EN 

 
CWC 

Defra 

Chemical Weapons Convention 

Department of the Environment, Food and Rural Affairs (UK) 

DG ENTR 

Directorate-General  for  Enterprise  and  Industry  of 
European Commission 

the 

DG JLS 

DG RTD  

Directorate-General  for  Justice,  Freedom  and  Security  of  the 
European Commission 

Directorate-General 
Development of the European Commission 

for  Research 

and  Technological 

DG SANCO 

European  Commission’s  Directorate  General  for  Health  and 
Consumer Affairs 

DG TREN 

Directorate-General  Energy  and  transport  of  the  European 
Commission  

DGSE 

EBDS 

EBSA 

Direction Générale de la Sécurité Extérieure  

European Bomb Data System 

European Biosafety Association 

EUChFR 

Charter of Fundamental Rights of the European Union 

ECHR 

ECDC 

ECURIE  

EDA 

EEA 

ENAC 

EPCIP 

ESCON 

European Convention on Human Rights 

European Centre for Disease Prevention and Control 

European  Community  Urgent  Radiological 
Exchange for Nuclear Emergencies 

Information 

European Defence Agency 

European Economic Area 

Emergency Notification and Assistance Convention 

European Programme for Critical Infrastructure Protection 

Epidemiological  Surveillance  Component  of  the  Community 
Network 

ESRAB 

European Security Research Advisory Board 

ESRIF 

European Security Research and Innovation Forum 

EN 

110 

   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  Framework  Programme  for  research  and 
technological development 

FVO 

GHSI 

Food and Veterinary Office of the EU 

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 

HSC 

IAEA 

IFCS 

Highly Enriched Uranium 

European Commission’s Health Security Committee 

International Atomic Energy Agency 

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 Radiation Detection Assessment Programme 

JRC 

Joint Research Centre 

NATO 

North Atlantic Treaty Organization 

NORM 

Naturally Occurring Radioactive Materials 

NPR 

Non-Proliferation Regime 

EN 

111 

   EN 

 
NPT 

Treaty on the Non-Proliferation 

NSABB 

National Science Advisory Board for Biosecurity 

OECD 

Organisation for Economic Co-operation and Development 

OIE 

World Organisation for Animal Health 

OPCW 

Organisation for the Prohibition of Chemical Weapons 

PAHO 

Pan American Health Organization 

RAS 
BICHAT 

Rapid  Alert  System  for  Biological,  Chemical  and  Chemical 
Terrorist Events 

RAS-CHEM  Rapid Alert System for Chemicals 

RDD 

Radiological Dispersion Device 

REACH 

RID 

European  Union  Regulation  on  Registration,  Evaluation, 
Authorisation and restriction of Chemicals 

International  Carriage  of  Dangerous  Goods  by  Rail 
Regulations 

RITNUM 

Response to Illicit Trafficking of Nuclear Material 

RPG 

RPM 

SAGAS 
Group 

SAPO 

SARS 

SGDN 

Rocket-Propelled Grenade 

Radiation Portal Monitor 

Stakeholders Advisory Group on Aviation Security 

Specified Animal Pathogens Order 

Severe Acute Respiratory Syndrome 

General  Secretariat  of  National  Defence  (Secrétariat  Général 
de la Défense Nationale, France) 

SitCen 

EU Joint Situation Centre 

SÜG 

Security  Vetting  Act 
Germany) 

(Sicherheitsüberprüfungsgesetz, 

TIC 

toxic industrial chemicals 

TRACES 

Community Trade Control and Expert System 

EN 

112 

   EN 

 
UN FAO 

Food and Agriculture Organization of the United Nations 

US GAO 

US Government Accountability Office 

WHO 

WMD 

World Health Organisation 

Weapons of Mass Destruction 

EN 

113 

   EN 

 
ANNEX 2: EXAMPLES OF INCIDENTS, MILITARY AND TERRORIST ATTACKS INVOLVING CBRN MATERIALS 

Attacks involving biological substances 

Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Large-scale attack plans 

Biological Agent 

Comments 

Damage/ Casualties 

Attacks 

1982- 
Onwards 

The  Civil  Cooperation 
Bureau  (CCB)  of  South 
African 
Military 
Intelligence  

South Africa, various 

Bacteria: Anthrax 

Bacillus anthracis 

March  1988  - 
onwards  

Iraqi Authorities 

various 
And 
Biological Agents 

other 

(Salman 

Bacteria: Anthrax 

Bacillus anthracis;  

Bacteria: Gas gangrene  

Clostridium perfringens 

Al-Salman 
Pak),  

al-Taji and 

al-Hakam, 

Iraq  

The South African Apartheid regime established a covert 
biological warfare unit 

‘Project Coast’ was covertly established, developing biological 
weapons which were used in assassinations  

Following  its  Chemical  warfare  capabilities,  Saddam 
Hussein’s regime began developing biological weapons  

Failed attacks 

1972 

1992 

Order of the Rising Sun / 
extreme 
right  wing 
terrorists 

Chicago,  St.  Louis  and 
other major cities,  

Bacteria: Typhoid 

Salmonella typhi; 

Planned 
pathogens 

to  poison  water  supplies 

to  disseminate 

Conspiracy foiled by authorities 

United States 

Japanese Aum Shinrikyo 
religious  cult  /  terrorist 
group 

Zaire and Kamikuishiki 
Japan 

Various  other  Biological 
Agents 

Virus: Ebola  

(Filovirus 
haemorrhagic fever) 

causing 

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 laboratory technician and white extremist, Larry Harris,  Conspiracy foiled by authorities 

EN 

114 

EN

 
  
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Biological Agent 

Comments 

Damage/ Casualties 

extreme 
right 
supremacist / Laboratory 
Technician  

Small-scale attacks 

United States  

Yersinia pestis 

used false letterhead to obtain three vials of Plague  

Attacks 

1970s 

Soviet Military Research 
Scientists 

Vozrozhdeniye 
‘Renaissance’ 
Aral Sea, Central Asia 

Island, 

Bacteria: Anthrax 

Secret trials using Anthrax and other biological agents  

Still contaminated with Anthrax spores to a high degree 

Bacillus anthracis 

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  preventing  deep  penetration  and 
wax covering of Ricin failing to melt  

September 

1978 

Bulgarian  KDS  Secret 
Police  

Waterloo 
London, England  

Bridge, 

Cytotoxin: Ricin  

Bulgarian exile 

(Produced  from  mash  left 
after  processing  of  Castor 
oil beans) 

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 
/ 
religious cult 

Rajneesh 

Wasco, Oregon,  

Bacteria: Salmonella  

United States  

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 ) 

October 2001 

Believed disgruntled  

Military 
Scientist  

Research 

Senate 
Building 
Washington  &  New 
York media offices 

Bacteria: Anthrax 

Bacillus anthracis 

Military 

grade 

‘Ames’ 

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  

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 

115 

EN

 
  
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Biological Agent 

Comments 

Damage/ Casualties 

Failed attacks 

1979 

Central 
Rhodesian 
Intelligence Organisation  

London 

strain  spores  mixed  with 
prevent 
to 
Bentonite 
clumping 

Cytotoxin: Ricin  

(Produced  from  mash  left 
after  processing  of  Castor 
oil beans) 

1980s 

1991 

German  Red  Army 
Faction / 

Extreme left terrorists  

Minnesota 
Patriots 
Council  /  extreme  right 
militia  

December 
16th 2002 

January 2003 

Algerian 
GSPC 
extremists  linked  to  the 
Al  Qaeda  network 
/ 
terrorist group 

Algerian 
extremists 
linked  to  the  Al  Qaeda 
network / terrorist group 

Paris, France 

Neurotoxin: Botulinum 

(produced  by  Bacteria: 
Clostridium botulinum ) 

Minnesota, 

Cytotoxin: Ricin 

United States  

Paris, France  

(Produced  from  mash  left 
after  processing  of  Castor 
oil beans) 

Believed  various  Chemical 
weapons and toxins 

Wood Green, London  

Cytotoxin: Ricin 

Manchester  

(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 

A large amount of the Botulinum toxin was found in the 
groups Parisian safe house 

Planned to smear Ricin on door handles in attacks on local 
police & tax officers 

Conspiracy foiled by authorities 

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  

Conspiracy  to  create  Ricin,  possibly  to  smear  it  on  door 
and car handles to kill members of the public 

foiled  by 

Conspiracy 
‘Operation 
Springbourne’  but  not  without  the  murder  of  Detective 
Stephen Oake 

authorities 

the 

in 

Accidents 

1971 

Soviet Accident 

1972 

Soviet Accident  

EN 

Aralsk,  Aral 
Central Asia 

Sea, 

Virus: Smallpox 

Variola virus 

Aral 
Sea, 
Vozrozhdeniye 
‘Renaissance’ 

near 

Bacteria: Plague 

Island, 

Yersinia pestis 

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 

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 

116 

EN

 
  
 
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Central Asia  

Biological Agent 

Comments 

Damage/ Casualties 

1977  

British Accident 

United Kingdom 

Virus: Smallpox 

Accidental release of virus from a research laboratory  

One research scientist died 

April 2nd 1979  Soviet Accident 

Variola virus 

Soviet 
Microbiology  

Institute 

of 

Bacteria: Anthrax 

Bacillus anthracis 

& Virology,  

Sverdlovsk, 
(Yekaterinburg) 

Russia 

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 
1988 

13th 

Soviet Accident  

Vektor  Viral  Research 
Centre, 
Koltsovo, 
Siberia, Russia 

Virus: Marburg 

(Filovirus 
haemorrhagic fever) 

causing 

A biological warfare scientist was accidently injected with 
the virus 

One 
research 
haemorrhagic fever  

scientist,  Nikolai  Ustinov  died 

from 

Attacks involving chemical agents 

Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Large-scale attack plans 

Chemical agent 

Comments 

Damage/ Casualties 

Late  1940s- 
early 1950s 

British Forces  

Malaya various 

Trichlorophenoxyacetic 
Acid / 245 T 

Defoliant: Herbicide killing crops and vegetation. 

NA 

During  Malayan  Campaign  245  T  was  used  to  try  and 
starve Communist Guerrillas 

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 

117 

EN

 
  
 
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

located 
in 
mountains 

the  Ural 

Chemical agent 

Comments 

Damage/ Casualties 

with organs, leading to overstimulation and death 

In  order  to  compensate  for  the  US  advantage  in  Nuclear 
weaponry,  the  Soviet  Union  developed  stockpiles  of 
various chemicals including Soman  

1950s to early 
1960s  

American Experts  

Various  US  Research 
locations 

BZ 
Agent 
Quinuclidinyl 
(QNB BZ) 

3-
/ 
benzilate 

Incapacitant:  Affects  the  peripheral  and  central  nervous 
systems, 
hallucinations, 
confusion and the effects associated with a drugs ‘trip’ 

incapacitation, 

producing 

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 

1960s to early 
1970s 

US Military  

South 
Vietnam, 
Cambodia  

East 

Asia: 
Laos  & 

South 
Vietnam, 
Cambodia 

East 

Asia: 
Laos  & 

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  

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.  

Agent  CS  /  CS  Gas  /  2-
Chlorobenzalmalononitrile 

Incapacitant:  Causes  stinging  and  burning  of  eyes  and 
skin, runny nose, sneezing and coughing 

While not fatal, a high level of exposure, particularly in a non-
ventilated area could cause longer term problems. 

Used by the US military during the war in Southeast Asia, 
in particular to flush Viet Cong out of tunnel complexes. 

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 

While not fatal, a high level of exposure, particularly in a non-
ventilated area could cause longer term problems. 

Regularly used by British Military against riots during the 
‘Troubles’ in Northern Ireland.  

1980- 1988 

Iraqi Military  

Iran-Iraq border areas   Mustard  Gas  (H)  /  ‘Sulfur 
/  Dichlorethyl 
Mustard’ 
Sulphide 
Nerve 
Agents, Tabun (GA), Sarin 
(GB) 

and 

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 available, one figure quoted by a 
US  source  estimated  that  around  20,000  Iranian  soldiers  had 
been killed in Iraqi chemical attacks. 

EN 

118 

EN

 
  
 
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Chemical agent 

Comments 

Damage/ Casualties 

March 1988 

Iraqi Military  

Halabja, 
region, Northern Iraq 

Kurdish 

Mixture  of  :  Mustard  Gas 
and  Hydrogen  Cyanide 
(AC)  

2001-2 

Al- Qaeda (AQ) 

Kandahar  and  other 
locations 
in 
Afghanistan  

Cyanide  

Blister and Blood Agents 

Between  3500  and  5000  Kurdish  villagers  were  killed  during 
the attack and 10,000 injured.  

During  its  attacks  against  the  Iraqi  Kurds,  the  Iraqi  Air 
Force attacked Halabja with Chemicals 

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  forces  discovered  drums  of 
Cyanide in AQ tunnels by Kandahar airport and videos of 
dogs being gassed. 

Believed AQ attempted to develop a Chemical capability. 

2003 onwards 

Tawhid  Wal  Jihad  /  al-
Qaeda in Iraq  

Iraq, various locations 

Chlorine Gas (CL)  

Pulmonary  /  Choking  Agent:  Attacks  lining  of  lungs 
leading to pulmonary oedema and ‘land drowning’ 

Coalition Forces and Iraqi civilians 

e.g.  three  in 
February 
2007  

April 2003 

During  the  course  of  the  ongoing  conflict  in  Iraq, 
insurgents  have  enhanced  their  bomb  attacks  by  utilising 
chlorine  gas  tankers  to  create  a  cloud  of  gas  engulfing 
survivors and rescuers. 

Possible  extreme  right 
wing. 
Three 
conspirators, no target or 
motive  known:  William 
Krar,  Judith  Bruey  & 
Edward Feltus 

Noonday, 
Texas, USA 

Eastern 

Sodium  cyanide  (800gms) 
& 
(hydrochloric, 
acids 
nitric & acetic) 

To be used to make Cyanide gas (highly lethal) 

Potentially could have killed “thousands” 

As well as the chemicals, police recovered 65 pipebombs, 
guns  &  1m  rounds  of  ammunition,  forged  official  passes 
to the UN & the DEA 

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 

119 

EN

 
  
 
 
 
 
Date 

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 

German  technical  specialist  Horst  Schwirkmann  had  severe 
chemical burns to his buttocks and backs of thighs. 

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.  

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 

Extremists linked to the Juhayman movement who had seized 
the Grand Mosque. 

On  20th  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.  

November 
1976 

The “Alphabet Bomber”  

Los Angeles, USA 

Sodium cyanide 

(Muharem  Kurbegovic  – 
lone actor) 

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  

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 

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 

Highly  detailed  &  initially  credible  threats  to  release 
dioxin  unless  $15m  is  paid  by  the  Cypriot  government. 
Cited  1976  Seveso  incident  as  a  consequence  of  dioxin 
release. 

No casualties 

Panos  Koupparis  arrested  on  May  14th  1987  in  London 
along  with  two  members  of  his  family  (one  a  chemistry 
student at university) 

EN 

120 

EN

 
  
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Chemical agent 

Comments 

Damage/ Casualties 

June 1990  

Liberation  Tigers 
Tamil Eelam (LTTE)  

of 

East  Kiran  Sri  Linkan 
Special Forces base. 

Chlorine Gas (CL)  

Pulmonary  /  Choking  Agent:  Attacks  lining  of  lungs 
leading to pulmonary oedema and ‘land drowning’ 

Sri Lankan Army special forces.  

June 
1994 

27th 

Aum Shinrikiyo Cult  

Matsumoto, Japan 

Sarin (GB)  

Kamikuishiki, Japan  

December 
1994 

Aum Shinrikiyo Cult 

Japan  

Agent VX  

20th  March 
1995  

Aum Shinrikiyo Cult 

Tokyo 
system, Japan.  

underground 

Sarin (GB)  

Attacking  a  military  base,  the  LTTE  placed  drums  of 
chlorine  around  the  perimeter  and  released  it  when  the 
wind direction was correct 

Nerve  Agent: 
Interferes  with  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  

Interferes  with  acetylcholinesterase, 
Nerve  Agent: 
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.  

Nerve  Agent: 
Interferes  with  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 

The Matsumoto attack killed seven and injured three hundred.  

In  Kamikuishiki,  no  deaths  but  several  people  suffered 
identical symptoms to Matsumoto 

The victim died from exposure to Nerve Agent. 

Twelve people died and over five thousand were injured.  

October 2002   Russian  Army  Special 
Forces 

Dubrovka 
Moscow 

Theatre, 

Believed  Halothene 
Fentanyl 

or 

Anaesthetic: Believed based around Opiate/Morphine 

Chechen  extremists  were  knocked  unconscious  and  then  shot 
by members of Russian Alpha & Vympel Special Forces units. 

This gas knocked out the terrorists and stopped detonation 
of their suicide bombs, but lack of care left 155 hostages 
dead. 

EN 

121 

EN

 
  
 
 
 
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Chemical agent 

Comments 

Damage/ Casualties 

September 

2004 

Possibly 
Ukrainian 
officials with links to the 
Federalnoye 
Russian 
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 
USA 

Arkansas, 

Potassium cyanide  

was  to  be  used  to  poison  the  water  supply  to  a  city 
(believed to be Washington) 

No casualties caused 

The CSA had accumulated/manufactured 30 gallons of it 
in their own facility 

23rd 
1997 

April 

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 

Believed terrorists planning to attack US Embassy staff 

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.  

April 2004 

Kataeb al Tawhid  

Amman, Jordan 

to 

“AQ 

(linked 
Mesopotamia”- 
Abu Musab Zarqawi 

in 
led  by 

Chemical  mix  containing 
sulphuric 
blister, 
acid, 
choking & nerve agents 

Three  specially  adapted  vehicles  carrying  20  tons  of 
“chemical mix” containing sulphuric acid, blister, choking 
& nerve agents 

If it had gone ahead as planned & intended, Jordanian officials 
estimated up to 80 000 casualties and very many deaths 

Was  to  have  been  series  of  suicide  attacks  on  HQ  of 
Jordanian  security  service,  PM  office,  US  Embassy  & 
others. Vehicles stopped & arrests made. 

EN 

122 

EN

 
  
 
 
Date 

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 oedema and ‘land drowning’ 

Believed  terrorists  planned  the  use  of  chlorine  tankers  as 
improvised chemical weapons  

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  

Accidents 

1952-61 

British experts 

1952 

British experts 

Porton  Down  research 
establishment, 
Salisbury 
Plain, 
Wiltshire  /  Nancekuke 
production 
site, 
Cornwall  

Plant 
Laboratory, 
Chemical 
(ICI)  

Protection 
Imperial 
Industries 

Sarin (GB)  

Nerve  Agent: 
Interferes  with  acetylcholinesterase, 
disrupting  the  mechanism  by  which  nerves  communicate 
with organs, leading to overstimulation and death  

Three  staff  left  permanently  affected  by  exposure  and 
invalided and one serviceman acting as a ‘guinea pig’ killed by 
a drop of Nerve Agent applied to his forearm.  

Four  accidents  during 
maintenance involving Nerve Agents.  

test  experiments  or  facility 

Agent VX  

Nerve  Agent: 
Interferes  with  acetylcholinesterase, 
disrupting  the  mechanism  by  which  nerves  communicate 
with organs, leading to overstimulation and death 

NA 

While attempting to develop a new pesticide, Dr. Ranajit 
Ghosh discovers a more viscous and more powerful liquid 
nerve agent than the German ‘G’ series. 

1976 

Industrial accident 

Seveso, Italy 

Dioxin  

Release of dioxin from chemical plant after an accidental 
explosion 

Italian authorities forced to slaughter 80 000 domestic animals 
as a protective measure 

3rd  December 
1984 

Union Carbide Accident   Union  Carbide  Plant, 

Methyl Isocyanate (MIC)  

Bhopal, India 

Pulmonary  /  Choking  Agent:  Attacks  lining  of  lungs 
leading to pulmonary oedema and ‘land drowning’ 

Although  no  exact  figures  are  available,  it  is  estimated  that 
anywhere  up  to  5000  local  people  died,  and  thousands  more 
were seriously injured.  

After  water  entered  one  of  the  plants  storage  tanks,  42 
tonnes of the gas were accidentally released, affecting the 
nearby town. 

Burns, sores on the skin in several residents near the plant. 
Symptoms  of  fatigue,  loss  of  appetite  &  nervousness  in 
many more 

EN 

123 

EN

 
  
 
 
 
 
Date 

Organisation/ 
Perpetrators 

Location/ 
Country 

Chemical agent 

Comments 

Damage/ Casualties 

January 1997 

Onwards 

Not  known  but  believed 
to  be  same  perpetrator 
(lone actor?) 

Sydney, Australia 

Chlorine  and  Sulphuric 
Acid 

Devices designed to release quantities of Chlorine (x2) or 
Sulphuric Acid 

Injuries  to  11  (sulphuric  acid),  20  and  4  (chlorine)  from 
inhalation of fumes 

Three locations 

No explosives involved. 

2000 

Striking 
Employees 

Cellatex 

Cellatex 
Ardennes, France 

Factory, 

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 materials and arrests 

May 1992 

March 1993 

EN 

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 
Uranium (HEU) (90%) 

Enriched 

Source of HEU was a State Research Institute in Russia 

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 

124 

EN

 
  
 
 
May 1993 

July 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 

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 airfield 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 

May 1994 

June 1994 

July 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 

Seizure  by  police  in  Tengen,  Germany  as  a  result  of  a 
possible “red mercury” scam 

0.006kgs Plutonium-239 

Source unknown 

(99.75% purity) 

Seizure by police in Landshut, Germany as the result of an 
undercover operation 

0.0008kgs HEU (87.8%) 

Russian sourced material 

Seizure  of  12  kgs  of  Uranium,  Istanbul.  Seven  Turks 
arrested 

12  kgs  Uranium,  weapons 
grade, 
in 
Azerbaijan 

originating 

July 1994 

Seizure by police in Germany 

0.00024kgs Plutonium 

Russian sourced material 

August 1994 

October 1994 

December 1994 

Seizure  by  police  at  Munich  Airport,  Germany. 
Individuals  involved  came  from  Spain  and  Colombia. 
Arrests also made in Moscow. 

0.4 kgs Plutonium 

Russian sourced material 

(plus 200gms of Lithium) 

Bulgaria.  Suspected  radioactive  material  seized  off  a  bus 
en route to Turkey 

No further details 

Seized in the Czech Republic when attempts were made to 
sell it. Three “nuclear workers” arrested. 

2.7 kgs HEU (87.7%) 

Russia 

EN 

125 

EN

 
  
 
 
 
February 1996 

in 
Failed  attempt 
Switzerland  leads  to  a  large  seizure  and  eight  arrests  in 
Turkey 

to  sell  highly  enriched  uranium 

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 & heat resistant coating in nuclear 
missile warheads 

June 1998 

July 1998 

Seizure  in  Bursa,  near  Istanbul,  Turkey  of  Antimony, 
Bismuth and Scanium. Three Turks arrested 

Smuggled into Turkey from Azerbaijan 

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,  Turkey  of  Uranium  and  Plutonium. 
Nine arrests made 

4.5 kgs of Uranium 

Believed  to  have  been  smuggled  in  from  Russia.  Legitimate  value  of  over 
$3m, asking price $1m 

6 gms Plutonium 

May 1999 

Seizure  by  Bulgarian  Customs  at  the  border.  Turkish 
national arrested 

0.004 kgs HEU  

Russia 

October 1999 

Seizure as a result of attempted 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 

126 

EN

 
  
 
 
 
 
2003 

2006 

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 

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 Bratislava, Slovakia and one in Hungary on 
suspicion of trying to sell nuclear material for $1m. 

Unconfirmed  but  reported  as 
2.2 
enriched 
Uranium 

pounds 

of 

July 2008 

Accident 

December 2000 

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 

Germany.  Radioactive  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 

November 1995 

Incident 

Material 

Comment 

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  Chechens  could  strike  in  Moscow  if  they 
wished 

December 1998 

Argun,  Chechnya.  A  container  with  radioactive  material 
inside and rigged to a landmine was found and defused 

EN 

127 

EN

 
  
 
 
 
ANNEX 3: 

NON-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)  

The NATO International Task Force (ITF-
25)  

Harmonised 

Global 
of 
Classification  and  Labelling  of  Chemicals 
(GHS)  

System 

The Australia Group 

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 

Radiological and nuclear threats 

International Atomic Energy Agency 

International Atomic Energy Agency 

The IAEA Convention on Nuclear Safety  

The 
IAEA  Convention 
Notification of a Nuclear Accident  

on  Early 

Code  of  Conduct  on 
the  Safety  and 
Security  of  Radioactive  Sources,  and 
supplementary Guidance on the Import and 
Export of Radioactive Sources 

The  IAEA  Convention  on  the  Physical 
Protection of Nuclear Material 

Code of Conduct on the Safety of Research 
Reactors 

The IAEA Convention for the Suppression 
of Acts of Nuclear Terrorism 

Guidance  on  the  import  and  export  of 
radiactive sources 

Emergency 

The 
Assistance Convention (ENAC) 

Notification 

and 

Safety  Requirements  on  Preparedness  and 
Response  to  a  Nuclear  or  Radiological 
Emergency 

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 

Guidance  and  considerations 
the 
implementation  of  INFCIRC/225/Rev.4, 
The  Physical  Protection  of  Nuclear 
Material and Nuclear Facilities 

for 

EN 

128 

   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 control 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  standard  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/Euratom of 22 December 2003 on the control of high-activity 
sealed radioactive sources and orphan 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 radioactive waste and spent fuel  

33 

For a comprehensive CBRN inventory, see the Council document 10382/08. 

EN 

129 

   EN 

 
 
 
                                                 
Council  Regulation  93/1493/  Euratom  of  8  June  1993  on  shipments  of  radioactive 
substances between Member States („Shipment of Radioactive Substances” 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 common rules in the field of civil aviation 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 

130 

   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 outcomes 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 divided by strand, namely 1) Actions applicable to CBRN prevention, detection and response; 2) Prevention; 3) 
Detection and 4) Preparedness and Response.34  

No. 

Policy action 

First screening 

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  expertise  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  conducts  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 develop guidelines and codes of conduct and to promote and support the 
development  of  bio-standards  would  take  the form  of  a  formal  and  permanent  body  at  the EU 
level. This would necessitate the setting up of a whole administrative and managerial structure, 
leading to financial and responsibility issues and concerns. In addition, such 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. 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y

i
s
s
u
e
s

  X 

X 

1. Enhance international cooperation 
H.01 

The Member States and the Commission should continue to strengthen the 
international  exchange  of  good  practices  with  external  partners 
concerning staff-awareness and training. 

Uncontroversial 
The  further  development  of  exchange  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. 

X 

X 

X 

X 

X 

34 

EN 

The actions applying to the horizontal strand are marked by the letter H, chemical strand – letter C, biological strand – letter B, radiological/nuclear strand – letter RN. 

131 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
H.02 

The  Member  States  and  the  Commission  should,  where  appropriate, 
exchange  information  on  their  participation  in  various  international 
forums  and  should  strive  towards  coordination  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  terrorism.  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  particular  CBRN  events)  with  a  view  to 
encouraging  the  spread  of  good  practices  concerning  communication 
strategies. 
The  Member  States  and  the  Commission  should  review  existing 
international  guidelines  and  incorporate  appropriate  existing  procedures 
or, when needed, should establish new guidelines for the development of 
security  communication  strategies  involving  CBRN  incidents,  which 
could  be 
and 
emergency  planning 
existing 
communications strategies, and would involve all relevant agencies. 
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. 

integrated  with 

H.04 

H.05 

C.01 

The  Member  States  and  the  Commission  should  establish  guidelines  for 
the development of chemical security communication strategies 

B.01 

Member States and relevant organisations should develop awareness and 
crisis communication strategies for the public living close to any facilities 
possessing any of the biological agents and toxins on the EU biosecurity 
list.  

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. 

H.07 

The  Commission  should  establish  a  library  of  resources  which  could  be 
used  by  the  relevant  authorities  (in  particular  the  law  enforcement 
community  and  public  health  authorities).  Such  a  library  would  contain 
applicable information about the nature of CBRN agents and how to deal 
with  them.  This  library  could  include  national  contributions  from  the 
Member States. 

Uncontroversial 
The  exchange  of  good  practices  of  communication  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. 
Uncontroversial 
The  compilation  of  existing  international  guidelines  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. 

Uncontroversial 
Making  use  of  existing  validated  good  practices  on  communication  with  the  public  and  the 
media is positive, as it will build on proven expertise and allow in particular Member States with 
less experience to learn from other Member States which are more advanced in this area.  
Uncontroversial 
Establishing  guidelines  for  the  communication  strategies  is  positive  as  it  will  support  the 
development of communication strategies at the national level which follow a common approach 
to the management of public crises. 
Uncontroversial 
A specific communication strategy with the main aim of informing and 'tranquilising' the public 
living  close  to  facilities  processing  biological  agents  and  toxins  on  the  EU  priority  list  is 
beneficial, as in the case of an incident their behaviour will be key in order to reduce the spread 
(if any) to other areas. 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

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. 
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  agents,  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 

X 

X 

X 

X 

X 

EN 

132 

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  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 
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 

H.10 

C.02 

C.03 

B.02 

B.03 

The  EOD  Network  should  address  the  need  for  developing  minimum 
standards of CBRN training for EOD specialists. The applicability of the 
standards  developed  by  the  EDA  to  the  non-military  context  may  be 
assessed in this regard. Training should be provided to EOD personnel in 
terms of contacting relevant CBRN specialists and on forensic awareness. 
The  Member  States  should  ensure  that  CBRN  information,  including  on 
EOD  matters,  is  integrated  into  training  programmes  for  relevant  first 
responders  and  local  authority  personnel.  The  Member  States  and  the 
Commission  should  ensure  that  emergency  response  personnel  receive 
training concerning available modelling tools. 
The  Commission  should  provide  support  for  the  organisation  of  specific 
HazMat specialist trainings. 

The  Member  States  should  organise  regular  exercises  concerning  the 
security  of  chemical  facilities  in  order  to  test  preparedness  measures  in 
place and raise awareness among staff. 
Member States and the Commission should identify and spread:  
• Good practices on well targeted training for and education of individuals 
working with, having access to or handling 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. 
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 and postgraduate students. 

Uncontroversial 
This  action  is  positive  as  it  aims  at  ensuring  that  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  context  and  adapted  to  the  civilian 
context, will avoid duplication of efforts and help to develop targeted training.  
Uncontroversial 
It is very positive to ensure that CBRN information is included in the training of first responders 
and  local  authority  personal  as  their  actions  will  have  an  important  impact  on  the  immediate 
response as well as on investigative and forensic activities. 

Uncontroversial 
Supporting the organisation of training of HazMat specialists is positive as it will ensure that the 
training targeted at handling and dealing with specific chemical substances is of high quality. 
To be assessed in detail 

Uncontroversial 
Identifying  and  disseminating  good  practices  on  training  and  education  within  academia  and 
laboratories  will  ensure  a  more  harmonised  approach  in  the  EU  Member  States  and  enable 
counties with little experience in this area to learn from their peers.  

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

 X 

X 

X 

X 

X 

X 

X 

X 

To be assessed in detail 

X 

X 

X 

5. Strengthen personnel security 

EN 

133 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
H.11 

Member States and the Commission should analyse the need to establish a 
system  of  mutual  recognition  of  security  vetting  processes  for  certain 
categories of personnel. 

H.12 

H.13 

C.04 

B.04 

The  Member  States  and  the  Commission  should  develop  and  introduce 
for  background  checks  and  vetting 
common  graduated  criteria 
requirements  in  relation  to  personnel  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-risk  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. 
The  Member  States  and  the  Commission  should  identify  and  exchange 
good  practices  on  approaches  to  security  of  non-EU  visiting  staff  and 
students;  Member  States  should  aim  at  common  procedures  across  the 
EU. 
The  Member  States  and  the  Commission  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 

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.  

B.04a  Developing mandatory professional code of conducts at EU level 

B.05 

The  Member  States  and  the  Commission  should  identify  and  exchange 
good practices on robust management structures at commercial, industrial 
and research facilities possessing biological agents and toxins on the EU 
biosecurity list ensuring regular appraisal of the staff and its monitoring. 

Uncontroversial 

X 

 X 

X 

X 

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.  

To be assessed in detail 

X 

X 

To be assessed in detail 

X 

X 

X 

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  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 whether a person so employed has a 'change of circumstances'.  
To be assessed in detail 

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. 
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  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 whether a person so employed has a 'change of circumstances'.  

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

EN 

134 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
6. Strengthen and prioritise research 
H.14 

H.15 

H.16 

H.17 

H.18 

C.05 

The Member States and the Commission 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  conferences  and  setting  up  a  dedicated 
research  web-portal  (for  all  of  CBRN  security)  which  would  contain  a 
summary of the relevant research projects and contact information where 
further details can be obtained, as well as opportunities for future research 
collaboration and work. 
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 JRC 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  periodic  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. 
The  Member  States  and  the  Commission  should  improve  the  use  of 
existing scientific networks to enhance work in the detection area. 

The  Commission  should  launch  a  study  on  the  necessity  and  impacts  of 
assessing  scientific  research  and  scientific  publications  against  security 
aspects.  

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  (from  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. 
The Commission and the Member States should support research into the 
following areas:  
• Prevention:  
1. Development of low-risk alternatives to high-risk chemicals.  
• Detection: 
1. Ensuring interoperability and network application of detection devices 
in view of joint team operations; 
2. Improving the presentation of detection 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 
Improving  aggregation  and  dissemination  of  research  and  especially  for  unclassified  material, 
will  give  a  single  access  to  existing  research,  state  of  the  art  and  prospects  for  new  research, 
bringing together the work of researchers throughout 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 assessed, given that conferences and a web-portal could 
require medium initial investments. 

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  meetings  of  CBRN  experts  will  further  help  to 
inform Member States and to encourage them to engage in further research cooperation. 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Uncontroversial 
Improving  the  use  of  existing  scientific  networks  is  positive  in  order  to  make  the  most  out  of 
existing  techniques  and  to  avoid  duplication  of  efforts.  It  would  be  important  to  first  map  the 
existing networks in this area, in terms of their coverage, specific focus / features, etc. 
Uncontroversial 
Launching  a  study  on  the  necessity  and  impacts  of  assessing  scientific  research  and  scientific 
publication is a useful action which will allow determining the state of the art, the gaps and the 
needs.  
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

X 

X 

X 

X 

Uncontroversial 
Supporting  research  in  the  mentioned  areas  is  positive  as  it  will  ensure  looking  into  new 
possibilities and alternatives to chemicals, developing new capabilities especially in the case of 
joint  operations,  further  developing  crisis  management  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 

135 

EN 

 
  
  
  
  
  
incidents 
• Technology research: 
1. Further miniaturising detection equipment, which should combine 
various capabilities in one device.  
2. The development of transportable equipment which can be used by 
emergency responders in the field. 
The Commission and Member States should enhance:  
•  Research  on  capabilities  for  response  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. 

B.06 

B.06a  All  scientific  publications  should  be  assessed  by  peer  reviewers  before 

their publication 

B.06b 

Publications of studies with sensitive biological dual-use research in two 
versions (public and restricted version) 

RN.01  The Commission and the Member States should support research into the 

following areas:  
• Detection:  
1. Detection and identification of difficult to detect radioactive sources 
and nuclear materials;  
2. Detection and identification of masked and shielded sources 
3. Improving spectrometry based detection and addressing the problems 
of "innocent" and false alarms 
4. Detection and location of radiation 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 contaminated evidence for an extended period 
of time;  
5. Guidance on the disposal of contaminated materials;  
6. Particle size distribution and potential chemical composition changes 

Uncontroversial 
Increasing funding to research will benefit overall response and recovery capabilities. 
Increasing  understanding  of  emergency  logistics  and  distribution  operations  will  increase  the 
chances of successful response and recovery in case of a real incident. Again, the earlier 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. 
Unfeasible 
Stakeholders did not support the review by peers of all scientific publications. A first concern is 
that  peer  review  might  have  a  negative  impact  on  research:  it  might  for  example  prevent 
researchers to investigate areas considered by some, and not by others, as being dangerous if the 
information was to fall into wrong hands. This could 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  findings.  Finally,  it  is  not  clear  what  further  consequences  and 
actions there would be in case a peer reviewer raises security concerns.  
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 practice. 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 proportionality and subsidiarity 
issues. In addition, this action might also raise concerns as to its compatibility with fundamental 
rights, such as freedom of speech and access to information. 
Uncontroversial 
Increasing research will benefit overall detection, response and recovery capabilities.  Mapping 
existing  research  and  fostering  European  cooperation  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 insufficient with regard to radioactive sources. 
Contamination and disposal of radiological 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  research  into  new  technologies  will  also  help  to 
improve control, monitoring and detection capacity and capability. 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

EN 

136 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
following an explosion.  
7. Other gaps identified based on a risk-assessment process 
• Technology research:  
1. Detection technologies and electronic tracking systems for radioactive 
sources;  
2. Integration of different technological solutions [address the current 
status when numerous devices are required for detection];  
3. Improving detection software;  
4. Enhance mobility and portability of detection solutions.  
5. The development of transportable equipment which can be used by 
emergency responders in the field (including neutralisation 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  terrorism,  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-border  issues.  It  will  also  help  to  formulate 
proposals to further harmonise penal 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 

1. Develop EU lists of high-risk CBRN materials and risk-based approaches to security 
The Member States and the Commission should establish and regularly 
H.20 
update EU lists of:  
• high-risk chemical agents;  
• biological agents and toxins (biosecurity list);  
• high-risk radioactive sources;  
of special security concern. 

To be assessed in detail 

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; 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l

d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l

u
e

/

N
o
s
u
b
s
i

d

i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

EN 

137 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

H.21 

RN.02 

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. 
The Commission should: 
• establish fora for EU level dialogue between relevant authorities in the 
field  of  CBRN  risk-management  in  order  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 the 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 
the  development/identification/implementation  of 
suitable methodologies 
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. 

toward 

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. 
The  Member  States  should  ensure  that  relevant  authorities  engage  in 
dialogue with the relevant site security 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. 
that  security  plans/security 
The  Member  States  should  ensure 
management  systems  are  in  place  in  high-risk  chemical  facilities.  The 
security  plans  should  provide  for  graduated  levels  of  security  based  on 

C.06 

C.07 

EN 

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 agreements in terms of risk management. 

X 

X 

X 

X 

X 

Uncontroversial 
Ensuring that information is adequately distributed to operators of facilities is very positive as it 
will  enhance  security  of  the  facilities.  It  will  particularly  be  important  to  ensure  that  they  are 
aware  of  potential  threats  and  are  part  of  a  system  of  information  on  security  of  high-risk 
radioactive materials. 

 X 

 X 

X 

X 

To be assessed in detail 

X 

X 

X 

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 the prevention and response 
to incidents, making sure that security managers and law enforcement counterparts know whom 
to contact and what to do. 
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

138 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
No. 

Policy action 

First screening 

C.08 

C.09 

C.09a 

C.10 

C.11 

C.12 

the existing threat level. Member State authorities should be involved in 
assessing  whether  these  security  plans  satisfy  the  necessary  level  of 
protection requirements. 
The Member States should:  
• Ensure that the responsibilities of the operator and the State in terms of 
security of facilities should be clearly defined. 
•  Ensure  that  local  law  enforcement  authorities  possess  information  on 
high-risk chemical facilities in their area. 
The Member States and the Commission should ensure that the chemical 
industry  develops  and  implements  the  security  side  of  the  Responsible 
Care programme. 

The  Commission  should  investigate  gaps  with  regard  to  the  delivery 
documentation  mechanism  established  under  the  Responsible  Care 
programme. 
The  Member  States  and  the  Commission  should  develop  a  high  level 
approach  to  chemical  facility  security  which  identifies  key  objectives 
and steps to be taken in order to increase security, based on national risk 
assessment approaches. 
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 should be examined in this regard as 
well, in close coordination with the authorities competent for chemicals 
of the Member States. 
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  practice  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 
Ensuring  the  definition  of  roles  of  operators  and  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 ensure that the security of chemical materials and 
facilities is enhanced. Clear links will need to be made to safety issues. 
Uncontroversial 
Ensuring  the  development  and  implementation  of  the  security  side  of  the  Responsible  Care 
programme is positive as it will allow progress on existing basis and avoid duplication of efforts. 
In addition, this action is positive as it builds on voluntary action of the chemical industry. 
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. 
To be assessed in detail 

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 enhance the development of alternative solutions. 

Uncontroversial 
The  identification  and  development  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  maximum  security  level.  Others  may  require  less 
rigid (and costly) measures. 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

X 

EN 

139 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
No. 

Policy action 

First screening 

C.13 

C.14 

B.07 

B.08 

B.08a 

B.09 

information security.  
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. 
The  Commission  should  accelerate  its  work  to  support  enhancing  the 
protection of SCADA systems against cyber-attacks. 

The Commission should assist Member States in proper implementation 
of  applicable  procedures  at  "the  laboratory  bench  level"  and  in 
developing  mechanisms  for  assessing  and  monitoring  its  correct 
implementation. 

 The Member States should establish:  
• A secure registry of facilities possessing 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 diagnostic laboratories 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;  
Introduce  the  accreditation  of  a  specific  and  limited  number  of 
laboratories,  health  institutions,  and  production  establishments  on  the 
basis of compliance with minimum security standards. 

The Commission and the Member States should support: 
• A process whereby facilities (clinical, diagnostic, university, etc) would 
avoid  keeping  clinical  samples  containing  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 the biological agents and toxins on the 

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.  

Uncontroversial 
This  action  is  positive  as  cyber  attacks  in  particular  in  relation  to  illegal  and  terrorist  use  of 
information is increasing.  
Uncontroversial 
EU level assistance with the implementation of applicable 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 monitoring implementation - Member States will 
receive  useful  feedback  on  their  strengths  and  weaknesses  as  well  as  concrete  suggestions  for 
improvements. 
To be assessed in detail 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

X 

X 

X 

Unfeasible 
Stakeholders did not support this action. They firstly raised the issue of costs 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. 
Uncontroversial 
Supporting Member States in those areas will be very beneficial to prevent access to substances 
which  are  on  the  biosecurity  list.  Facilities  should  be  allowed  to  handle  dangerous  biological 
agents and toxins only with specific authorisation. 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 

X 

X 

EN 

140 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
 
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

EU biosecurity list;  
• Progress in creating collaborative networks of facilities working on the 
biological agents and toxins on the EU biosecurity list while taking into 
account existing networks; 
The Commission and the Member States should ensure that: 
• A comprehensive overview of the relevant 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 part 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 implementation of such standards should also 
be ensured. 
The  Member  States  and  the  Commission  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). 
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.  
The  Member  States  and  the  Commission  should  conduct  an  analysis  of 
the feasibility of linking security vetting/background check requirements 

B.10 

RN.03 

RN.03
a 

RN.04 

EN 

involving  all  relevant  facilities  and  laboratories  could  contribute  to  increased  cooperation  and 
exchanges of good practices and experiences in general. 

Uncontroversial 
The establishment of a comprehensive 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 the 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 and the Member States should closely follow both 
the adoption and the implementation of standards, in order to ensure some form of harmonised 
approach.  

Uncontroversial 
Improving  the  security  requirements  of  the  facilities  manufacturing  and/or  disposing  high-risk 
sources, based on an gap and need analysis, is positive as it will reduce the risks of loss or thefts 
of those sources. 
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  ensure  the  security  of  radiological  and  nuclear 
facilities and materials. 

X 

X 

X 

X 

X 

X 

Uncontroversial 
An analysis of feasibility will be very positive as a first step to assess the possibilities of linking 

X 

X 

 X 

X 

X 

141 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

No. 

Policy action 

First screening 

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 users. A sufficient customer qualification 
scheme should be established in this regard, which is proportionate to the 
risk and cost effective. The risks associated with trade of chemicals over 
the Internet should be investigated further.  
Member  States  and  the  Commission  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 for 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.  
The  Commission  should  perform  a  feasibility  assessment  on  the 
possibility  of  using  the  delivery  documentation  mechanism  to  better 
understand and monitor the supply chain (possibly link it to tracking and 
tracing).  
The  Commission  should  launch  a  study  concerning  the  availability  of 
certain high-risk chemicals to the general public.  

C.16 

C.17 

C.18 

RN.05 

The Member States should ensure that national source registries contain 
information on all high-risk sources.  

RN.06 

The  Member  States  should  launch  recovery  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).  

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 use 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. 
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  starting  point,  given  that  the  substances  are 
often similar. 

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  monitor  the  supply  chain, 
before potentially and eventually launching such as mechanisms. 
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 has access to (sufficient) high-risk chemicals. It 
would  be  important,  again,  to  look  at  access  through  the  internet  or  by  making  multiple  small 
purchases, as terrorists have used similar approaches in the past.  
Uncontroversial 
National source registries with information on all high-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 monitored, controlled and regularly updated varies. 
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

X 

X 

X 

X 

EN 

142 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
No. 

Policy action 

First screening 

RN.07 

RN.08 

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). 
The  Member  States  and  the  Commission  should  identify  and  exchange 
good  practices  for  commercial,  health  care  and  research  facilities 
possessing radioactive sources to ensure regular appraisal of the staff and 
its monitoring. 

RN.09 

The Commission  should launch studies 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. 

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). 

RN.11 

Europol should lead an analysis of losses and thefts of high-risk sources 
in  the  EU.  This  analysis  should  take  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 should be made available to the relevant 
national authorities and reviewed regularly. 

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  handling  high-risk  CBRN  materials. 
Consideration  should  also  be  given  to  developing  EU  guidelines  for 
minimum  security  training  requirements  for  persons  working  with, 
having  access  to,  or  handling  CBRN  materials,  based  on  the  national 

Uncontroversial 
An  assessment  of  the  potential  and  practicalities  of  establishing  tracking  systems  for  high-risk 
sources will be a very useful as a first step before potentially establishing such a system.  
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  which  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  whether  a  person  so  employed  has  a  'change  of 
circumstances'.  
Uncontroversial 
Studies  on  the  origin  and  consequences  on  those  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.  disappear  from  regulatory  control,  due  to  poor 
accounting and licensing. 
Uncontroversial 
The  facilitation  of  exchange  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 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 orphan sources, as this is also very costly. 
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  necessary,  to  secure  parts  of  the 
analysis  if  this  could  point  at  specific  national weaknesses,  as  terrorists  and  criminals  could  be 
interested in knowing these. 

Uncontroversial 
Developing minimum training requirements and exchanging good practices is beneficial as it will 
ensure  increased  awareness  of  persons  working  with  or  having  access  CBRN  materialss  on 
specific security issues. It will also 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. The exercise will also help to identify gaps and future needs. 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X  

X  

X  

X  

X  

EN 

143 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No. 

Policy action 

First screening 

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. 
The  Member  States  should  develop  and  implement  specific  training 
programmes  for  private  security  staff  (in  particular  those  involved  in 
guarding specific sources). 

H.24 

C.19 

The Member States and the Commission should ensure that the chemical 
industry develops and adopts codes of conduct concerning awareness of 
security-related issues. 

C.20 

B.11 

The Member States should implement specific security training for staff 
in industry and research, where high risk chemicals are present. 

The  Commission  and  the  Member  States  shall  encourage  professional 
and other relevant associations to develop and adopt codes of conduct for 
their Members. 

B.12 

The  Commission  and  Member  States  should  define  requirements  for 
biosafety officers (roles, competences and training). 

RN.12 

RN.13 

The Member States and the Commission should use the capacity planned 
European Security Training Centre (EUSECTRA) to provide nuclear and 
radiological  security  related  training  and  to  support  and  complement 
such activities at the national level. 
The  Member  States  and  the  Commission  should  engage  with  research 
stakeholders  to  raise  awareness  of  security  issues  and  facilitate  the 
exchange  of  good  practices  on  dealing  with  security  threats.  Particular 

Uncontroversial 
Developing and implementing specific training programmes for private 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. Training certificates or other forms of proof could 
be made conditional for private security firms and staff in order to have permission / be licensed 
to guard certain sources. 
Uncontroversial 
The development and adoption of code of codes of conduct is positive 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  association  (already  used  in  some  countries)  is 
sufficient  moral  pressure  and  indeed  a  strong  tool  to  make  professionals  comply  with  a  code. 
There are good examples of national codes of conduct which work very well. 
Uncontroversial 
The implementation of specific security programmes for staff in industry and research will ensure 
a common approach to the security of facilities handling high risk chemicals. 
Uncontroversial 
The development and adoption of code of codes of conduct is positive 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  threat  of  being  excluded  from  a  professional 
association (already used in some countries) is sufficient moral pressure and indeed a strong tool 
to make professionals comply with a code. The efforts and costs required will be relatively low. 
Uncontroversial 
Defining requirements for biosafety officers will ensure a harmonised and common approach to 
the roles, competences and training of the officers responsible for safety of the facilities handling 
biological substances. 
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. 
To be assessed in detail 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Possibly 

X 

X 

X 

X 

X 

X 

X 

X 

EN 

144 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

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. 
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. 

RN.13
a 

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 

To be assessed in detail 

X 

 X 

X 

X 

To be assessed in detail 

X 

X 

X 

To be assessed in detail 

X 

X 

X 

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 stakeholders to report such transactions to 
law-enforcement authorities 
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. 

H.26 

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 services 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 materials (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.  

EN 

145 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

• 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 system for the international 
transport of CBRN materials contained in the CBRN lists (identified 
under the risk-management process) 
• Consider the feasibility and costs/benefits of introducing a requirement 
that only licensed transporters would 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. 
The  Member  States  and  the  Commission  should  ensure  that  links 
between law enforcement authorities and transporters of CBRN materials 
are enhanced. 

The  Member  States  should  ensure  that  the  training  of  transport  staff 
concerning  existing  legislative  requirements  on  the  security  of  CBRN 
materials is improved where appropriate. Regular exercises on transport 
security should be organised. 
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. 
The Member States and the Commission 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. 
Based on a risk-management approach, each Member State should work 
toward eliminating the transport of certain high-risk chemicals. This can 
be  done  by  encouraging  and  supporting  the  development  of  relevant 
chemical  manufacturing facilities at  sites which require such dangerous 
chemicals  (rather  than  transporting  them).  Enhance  links  between  law 
enforcement authorities and transporters of chemical agents. 
The Commission and the Member States should establish an ad-hoc 
committee of experts on transport security with regard to CBRN 

H.28 

H.29 

B.13 

RN.14 

C.20a 

C.20.b 

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 movements. It will also 
clarify who has to be contacted in case of a loss, theft or other type of incident. 
Uncontroversial 
Any exercises concerning the secure 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. 
To be assessed in detail 

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.  
Unfeasible 
Stakeholders  showed  little  support  for  this  action.  The  first  concerns  are  financial  as  creating 
such  facilities  would  require  substantial  investments.  In  addition,  creating  such  facilities  might 
potentially  be  dangerous.  For  example,  the  potential  multiplication  of  plants  dealing  with 
dangerous substances would increase the risks. 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Unfeasible 
These measures were highly supported by stakeholders. Studies and exchange of good practices 

X 

X 

EN 

146 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

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:  
Ø Assess whether existing transport security 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. limited 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 notification system for the international 
transport of high-risk chemicals identified under the risk-management 
process mentioned in section 1.1.  
Ø Consider the feasibility and costs/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. 
Enhance  links  between  law  enforcement  authorities  and  transporters  of 
chemical agents.  

The Commission should launch a study 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 mentioned above, the need for new transport 
rules in relation to high-risk sources should be assessed. 

C.20c 

RN.15 

7. Improve information Exchange 

EN 

in  relation  to  transport  of  chemical  materials  will  be  very  useful  as  a  first  step  to  develop  new 
measures as well as to inform those Member States which have a capacity less developed in those 
areas.  It  was  however  decided  to  put  up  the  measures  for  further  discussions  in  an  ad-hoc 
committee of experts covering transport security regarding all CBRN materials. 

Unfeasible 
These measures were highly supported by stakeholders. Studies and exchange of good practices 
in  relation  to  transport  of  chemical  materials  will  be  very  useful  as  a  first  step  to  develop  new 
measures as well as to inform those Member States which have a capacity less developed in those 
areas.  It  was  however  decided  to  put  up  the  measures  for  further  discussions  in  an  ad-hoc 
committee of experts covering transport security regarding all CBRN materials. 
Uncontroversial 
Studies on the coverage of existing legal regimes 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 

X 

X 

147 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
No. 

Policy action 

First screening 

H.30 

H.31 

H.32 

C.21 

C.22 

RN.16 

RN.16

The Member States should analyse whether potential problem areas exist 
in  the  horizontal  and  vertical  flow  of  information  among  the  entities 
dealing  with  high-risk  CBRN  materials  sources  both  within  and  across 
the individual Member States. Each Member State should assess whether 
relevant need-to-know information about changing threat levels reaches 
license holders. 
The Member States should ensure that each party within the supply chain 
informs without delay the relevant national authority in the event of any 
theft  or  loss  of  any  high-risk  CBRN  materials.  The  relevant  national 
authorities  should  inform  without  delay  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. 
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  information  for  relevant  local  law 
enforcement authorities. 
The  Member  States  and  the  Commission  should  ensure  that  public 
authorities provide, as appropriate, adequate 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 focus attention on issues of concern. 
The Member States and the Commission should consider establishing an 
alert mechanism in order to quickly transfer security related information 
to  security  managers  in  facilities  in  which  high-risk  chemicals  are 
present. 
The  Member  States  and  the  Commission  should  support  the  IAEA's 
Illicit  Trafficking  Database  with  a  view 
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. 
The  Commission  should  setup  an  EU  Database  of  Illicit  Trafficking  Unfeasible 

to  ensuring  real 

Uncontroversial 
Analysing  the  accuracy  of  the  horizontal  and  vertical  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.  

Uncontroversial 
Improving information flow on thefts 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 aware 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 supply chain partners know whom to contact. 

To be assessed in detail 

Uncontroversial 
Ensuring  that  information  is  adequately  distributed  to  the  entire  supply  chain  of  high-risk 
chemical  agents  is  positive  to  raise  their  awareness  on  issues  of  concern.  It  would  however  be 
important to ensure that such information does not cause overreactions and unrest. 

To be assessed in detail 

Uncontroversial 
Supporting  the  IAEA's  Illicit  Trafficking  Database  is  very  positive  as  it  will  ensure  that 
information  is  up  to  date,  available  and  accessible  to  law  enforcement  authorities  to  track  the 
losses and recovery of radioactive sources. 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X  

X 

X 

X 

X 

X 

X 

X 

 X 

 X 

X 

X 

X 

X 

X 

X 

X 

EN 

148 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
No. 

Policy action 

First screening 

a 

Incidents.  

RN.17 

The  Commission  should  assess  whether  existing  systems,  in  particular 
the  IAEA's  ITDB,  provides  sufficient 
law 
enforcement  community.  Europol  should  be  closely  involved  in  this 
analysis.  If  the  analysis  leads  to  the  identification  of  gaps,  further 
feasibility  work  could  be  conducted  on 
to  setup  a 
complementary EU Database of Illicit Trafficking Incidents. 

information  for 

the  need 

the 

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  enforcement  authorities  to  track  the  losses  and 
recovery of radioactive sources. However, stakeholders raised their concerns of duplication of the 
already existing IAEA's Illicit Trafficking Incidents. Using this database and making the most out 
of it would prevent duplication of efforts and would allow working on a solid basis which could 
be improved. 
Uncontroversial 
An assessment of existing information-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  involving  many  third  countries,  there  would  be  a  high 
potential for duplication of efforts. 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

8. Strengthen the import/export regime 
RN.18 

RN.19 

RN.20 

The  Commission  should  assess  the  need  to  address  the  issue  of 
import/export rules in relation to potential high-risk sources not covered 
by the HASS Directive 
The Commission should assess to what 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. 
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 
Assessing the issue of import/export rules not covered by the HASS directive is very positive, to 
make sure that high-risk sources which are currently not covered are given appropriate attention. 
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 practices and to encourage peer learning. 
Uncontroversial 
An  assessment  of  the  potential  and  practicalities  of  drawing  up  common  EU  criteria  for 
authorising imported and experts from and to third countries is a very useful as a first step before 
potentially establishing such criteria.  

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

EN 

149 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No. 

Policy action 

First screening 

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 the CPPNM by the EU Member States/Community. 

RN.22 

The  Member  States  and  the  Commission  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 implementation of the amended Convention and 
identify  and  exchange  good  practices  concerning  physical  protection 
measures. Existing forums should continue to be used as appropriate. 

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 Parties to protect nuclear facilities and material 
in  peaceful  domestic  use  and  providing  for  expanded  cooperation  between  and  among  States 
regarding rapid measures to locate and recover stolen or smuggled nuclear material, mitigate any 
radiological consequences of sabotage, and prevent and combat related offences. 
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  experience  and  capacity  to  easily  access  information  from 
other Member States which are more advanced in this area. 

3) Detection strand 

No. 

Policy action 

First screening 

1. Establish a scenario-based/modelling approach to identifying work priorities in the detection field 
H.33 

The Member States and the Commission 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 detection and false alarm rates. 

Uncontroversial 
Developing  scenarios  at  the  EU  level  will  be  positive  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. 
To be assessed in detail 

H.34 

The Member States should strengthen and support:  
• the exchange of methodologies for developing scenarios;  

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l

d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i

n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l

u
e

/

N
o
s
u
b
s
i

d

i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

 X 

X 

X 

X 

X 

X 

EN 

150 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

• 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. 
The Member States and the Commission should develop a mechanism for 
information  exchange  among  Member  States  on  scenario  development 
related  to  detection.  Prepare  an  overview  of  Member  State  activities  in 
this area. 

H.35 

H.36 

The Member States and the Commission should carry out a gap analysis 
by  creating  a  matrix  for  each  developed  scenario  of  what  is  needed  to 
identify CBRN materials and the detection technology already available. 

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. 

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  the  private  sector  should  be  ensured 
and legal requirements for evidence considered. 
Member States and the Commission should develop reference material of 
biological agents for both clinical and environmental samples (according 
to  internationally  accepted  standards)  in  order  to  achieve  quality 
assurance in detection. 
Member  States  and  the  Commission  should  set  requirements  for  the 
detection, identification and monitoring of pathogens and toxins within a 
civilian security context at the EU level 

B.15 

B.16 

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 identification of gaps and needs. 
Uncontroversial 
A  gap  analysis  of  state  of  the  art  with  regard  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  appropriate  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 identify further needs. 
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 X 

X 

To be assessed in detail 

X 

 X 

 X 

X 

Uncontroversial 
Developing reference material would allow laboratories and other actors involved in detection to 
use  the  most  up  to  date  and  efficient  material.  This  will  ensure  the  best  quality  possible  for 
detection and harmonisation amongst Member States.  
To be assessed in detail 

X 

X 

 X 

X 

X 

X 

X 

 X 

3. Establish trialling, testing and certification schemes for CBRN detection in the EU 

EN 

151 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
  
  
s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

 X 

X 

No. 

Policy action 

First screening 

To be assessed in detail 

H.38 

B.17 

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 set requirements 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 scheme 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. 
Member States and the Commission should establish: 
• Sets of relevant simulants of biological agents for field tests, practical 
exercises and field technology trialling at national level and EU level, 
where appropriate; 
• Criteria for method validation across 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 across the EU and Member States. The simulants 
will also help to better understand the climate, contextual 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  Commission  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. 
Member  States  and  the  Commission  should  enhance  and  support  the 
cooperation  between  forensic  laboratories,  reference  and  specialised 
laboratories on CBRN materials. 

H.40 

H.41 

The Member States and the Commission should:  
• Establish a mechanism of exchanging best practises in the field of 

Uncontroversial 
An  assessment  of  the  potential  and  practicalities  of  establishing  a  handbook  on  detection  of 
CBRN materials in order to create joint investigation teams is very useful as a first step before 
potentially  establishing  such  a  handbook.  Some  stakeholders  considered  that  there  may  be 
security risks involved. 

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  laboratories  at  national  and  EU  levels.  Whilst 
several  cooperation  structures  between  laboratories  exist,  these  usually  concern  very  specific 
areas and do not link the reference / specialised laboratories to those that deal with forensics.  
Uncontroversial 
A system to exchange good practices in the field of training and exercise, on the calibration of 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Possibly 

EN 

152 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

training and exercises, including awareness raising of front line officers;  
• Support EU and national projects aimed at calibrating detection devices 
in specific environments. Cooperation 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 detection methods and processes; 
The Commission should: 
• Launch a study on what is currently in place in terms of CBRN border 
monitoring in the EU; 
• Elaborate guidelines on optimal localisation of detection equipment 
Member States and the Commission should initiate: 
• The development of mobile detection, identification and sampling 
capabilities at the EU level to be undertaken 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). 
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 laboratories which are competent 
and have capacity across the EU specialising in specific biological agents 
(particularly agents which will be identified on the EU Bio-security list).  

H 42 

B.18 

B.19 

detection devices in specific environment on the 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 mechanism and good practice exchanges will also be 
useful to identifying gaps and upcoming needs. 

Uncontroversial 
Stock-taking  exercise/study  led  by  the  Commission.  Such  an  assessment  is  positive  in  order  to 
define the gaps. It will allow mapping the existing border monitoring arrangements. 

X 

X 

X 

X 

X 

To be assessed in detail 

X 

X 

X 

Uncontroversial 
The  central  role  to  be  played  by  the  Commission  in  the  networking  of  laboratories  is  very 
positive  as  it  will  allow  a  centralised  and  improved  coordination  of  works  and  exchange  of 
information  between  the  relevant  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 Commission should develop an adequate and 
sustainable  training  programme  at  EU  level  for  front  line  officers.  The 
EU-SECTRA can play an important 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 programmes, 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  available  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  development  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 

153 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
No. 

Policy action 

First screening 

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. 

provided to industry and the possibility of 'unfair competition'. 
To be assessed in detail 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

RN.24  The Member States and the Commission should promote and support EU 
and  national  projects  performing  monitoring  of  radiation  for  security 
purposes.  Cooperation  and  information  exchange  among  the  Member 
States on such projects should be enhanced. 

Uncontroversial 
Promoting and supporting projects 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 

1. Improve emergency planning 
H.43 

Each  Member  State  should  integrate  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. 

Each Member State should assess whether all operators handling 
high-risk CBRN materials possess emergency response plans. The 
feasibility  of  extending,  where  needed,  emergency  plan 
requirements  to  such  operators  should  be  assessed.  Gaps  in 
existing regulations should be identified. 
The  Member  States  and  the  Commission  should  develop  and  To be assessed in detail 

Uncontroversial 
Integrating  CBRN  emergencies  into  response  plans  with  a  particular  focus  on  criminal 
investigations and forensic in positive as it will allow a better and  more coordinate response to 
respond  to  those  emergencies  and  to  prevent  investigative  problems  and  possible  damage  to 
forensic evidence. 
Uncontroversial 
An assessment of emergency plans is positive in order to update the plans in light with gaps and 
needs identified.  

H.44 

H.45 

EN 

154 

EN 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l

d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l

u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

X 

X 

X 

X 

 X 

X 

X 

X 

X 

X 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

conduct  regular  exercises  and  training  at  all  levels  (national, 
European and international), involving and testing cooperation of 
all  relevant  organisations,  particularly  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  coordination  of  relevant  exercises  at 
EU level. 
The  Commission  should 
the 
organisation  of  State  structures  concerning  CBRN  incidents.  The 
results of the study should be shared across the EU. 

launch  a  study  concerning 

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; 
Each Member State should assess whether emergency plans exist 
for high risk public locations and high-risk public events. 

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  provided  on  the  emergency  measures 
envisaged to alert, protect and assist 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. 
Develop  plans  on  how 
the  dissemination  of 
information  in  the  event  of  a  radiological  emergency  and 

to  organise 

H.46 

B.21 

RN.25 

RN.25a 

RN.25b 

Uncontroversial 
An  assessment  of  the  State  structures  concerning  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 developed capacity in this 
area. Issues in relation to the sensitivity of information should be taken into account. 
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

X 

Uncontroversial 
Assessing the extent to which emergency plans exist for high risk public locations and high-risk 
public events is a useful action which will allow determining the state of the art, the gaps and the 
needs. This action would be very beneficial if it were to cover all CBRN issues 
Unfeasible 
The need to inform the general public was not supported by stakeholders as they did not see an 
added value in the preparedness and very little in the response. It might be too risky to inform the 
public  about  issues  which  can  appear  to  be  dangerous  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  necessarily  be  well  trained  or  aware  and  might 
overreact as a consequence of accumulated panic.  
Unfeasible 
This action received little stakeholder support and raised subsidiarity issues. The first concern is 

 X 

X 

 X 

X 

X 

X 

X 

EN 

155 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

takes 

determine  the  content  of  the  information.  In  order  to  ensure  that 
the  general  public 
the  message  seriously  without 
exaggerating  the  scale  of  the  hazard,  the  information  should  be 
credible  and  allow  the  general  public  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 diffused to the general public, within a "reasonable" 
scale and scope. It would also require finding a right 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 responsibility 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  benefits  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 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 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. 
The  Commission  should  collect  and  disseminate  good  practices 
among the Member States concerning the ways in which medical 
staff can receive guidance on dealing with large scale emergencies 
and a rapid increase of the number of patients. 
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 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 

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.  
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

X 

156 

EN 

H.48 

B.22 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

B.23 

eventual threat;  
• Build an EU wide coordinated approach to access medical 
countermeasures allowing adequate protection of the EU 
population, based on risk assessment. 
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 information flows in case of CBRN emergencies 
H.49 

To be assessed in detail 

H.50 

RN.26 

RN.27 

RN.28 

Member States should exchange information on emergency plans 
regarding CBRN incidents, involving all relevant agencies.  
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 

Each Member State should ensure 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. 
The  Member  States  and  the  Commission  should  consider 
integrating and building upon existing platforms for international 
exchange  of  information  during  nuclear  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. 
The  Member  States  and  the  Commission  should  establish  a 
process  in  order  to  develop  generic  scenarios  illustrating  the  law 
enforcement 
involving 
a 
radioactive/nuclear  materials  at  the  national  and  the  international 
level.  This  process  should  in  particular  identify  the  relevant 
stakeholders who need to be informed about a particular situation 
and the applicable thresholds for triggering information exchange 

potential 

response 

event 

to 

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  experience  to  learn  from  other 
Member States which are more advanced in this area.  
Uncontroversial 
Ensuring that information is adequately distributed to groups who might be involved in an event 
involving  radioactive/nuclear  materials  is  very  positive  as  it  will  ensure  high  level  of 
preparedness  from  those  groups.  Issues  in  relation  to  the  sensitivity  of  the  information  to  be 
provided  are  to  be  taken  into  account.  Also,  different  groups  will  require  different  forms  of 
information. 
To be assessed in detail 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Uncontroversial 
Creating scenarios setting out the response of law enforcement to an event involving radioactive 
materials  is  positive,  as  it  helps  to  determine  which  steps  are  to  be  taken  and  who  is  to  be 
involved, at which level, thus increasing the response 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 

157 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
No. 

Policy action 

First screening 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

into 

H.52 

include 

procedures. The process should at least involve representatives of 
the Member States, the Commission and Europol. 
4. Develop improved modelling tools and strengthen decontamination capacity 
The Commission should fund an assessment of existing modelling 
H.51 
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 
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 
the 
funding  could  be  provided  for  further  research 
development  of  robust  modelling  tools  applicable  to  events 
involving dangerous substances. The Commission should fund an 
assessment  of  the  role  of  modelling  tools  for  either  pre-event 
scenario studies or as decision-support systems. 
the  preparation  of  an 
facilitate 
The  Commission  should 
Emergency Response Guidebook (for first responders) applicable 
to the context of CBRN emergencies in the European Union. The 
guidebook would be provided to the Member States free of charge 
and could be translated into all official EU languages. As part of 
the  process  of  preparing  an  Emergency  Response  Guidebook,  a 
should  be 
stocktaking  of  existing  documents/guidebooks 
conducted. 
Each  Member  should  conduct  a  regular  assessment  of  the 
available  means  for  effective  decontamination  and  their  capacity 
to  deal  with  mass  casualties  with  reference  to  high-risk  CBRN 
materials.  Information  about  current  decontamination  solutions 
should be shared with all Member States. 
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 materials, which also addresses the 

H.54 

H.53 

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 propose further investments where needed. Experts 
and  Member  States  should  be  involved  in  all  stages  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 

Uncontroversial 
Creating  a  guidebook  on  CBRN  emergencies  is  positive  is  order  to  present  the  common  EU 
approach to respond to those emergencies and to guide 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 

Uncontroversial 
Regular assessments of capacity and capability do deal with contamination 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  addition,  information  sharing  will  benefit  those 
Member States with a less developed technical decontamination capacity and knowledge of risks.  
Uncontroversial 

The mentioned studies will be very useful in order to assess and model the actual consequences 
following  the  use  by  terrorists  of  CBRN  weapons,  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 

X 

X 

X 

X 

X 

EN 

158 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
No. 

Policy action 

First screening 

RN.29 

question of acceptable levels of residual contamination. 
• Launch a study on decontamination procedures which do not 
damage forensic evidence. 
The Commission should further investigate 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. 

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. 

The Commission should analyse the issue of potential problems in 
the  transport  of  CBRN  contaminated  materials  across  borders 
within  the  context  of  criminal  investigations  and  emergency 
situations in general. 
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 
relevant 
organisations  should  contribute 
laboratory 
practices  such  that  results  can  be  used  during  legal  prosecution 
(e.g.: accredited measurement procedures; 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. 
The  Commission  should  support  the  networking  of  forensic 
laboratories  and  laboratories  equipped  for  measurement/analysis 
of radioactive material 

Institutes,  JRC-ITU  and  other 

to  establishing 

H.56 

H.57 

RN.30 

EN 

s
u
p
p
o
r
t

S
t
r
o
n
g
s
t
a
k
e
h
o
l
d
e
r

P
o
s
i
t
i
v
e
o
v
e
r
a
l
l

e
f
f
e
c
t
s

L
o
w

f
i
n
a
n
c
i
a
l

c
o
s
t
s

r
a
t
i
o
n
a
l
e

H
i
g
h
E
U
a
d
d
e
d
v
a
l
u
e

/

N
o
s
u
b
s
i
d
i
a
r
i
t
y
/

p
r
o
p
o
r
t
i
o
n
a
l
i
t
y
i
s
s
u
e
s

X 

X 

 X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Uncontroversial 
Investigating in the possibility of using International information exchange tools is very positive 
to foster the exchange of expertise and knowledge 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.  

Uncontroversial 
Training of first responders of forensic awareness will limit the loss of forensic 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. 
Uncontroversial 
The analysis of potential problems in the transport 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. 
Uncontroversial 
Recommendations of forensic bodies of the EU with 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 forensic evidence so that such evidence is admissible 
in national courts in other EU countries. At present, such possibilities hardly exist also because 
Member States have different approaches to forensic laboratory practices. 

Uncontroversial 
The  central  role  to  be  played  by  the  Commission  in  the  networking  of  laboratories  is  very 
positive  as  it  will  allow  a  centralised  and  improved  coordination  of  works  and  exchange  of 
information between the relevant laboratories under EU responsibility. The networking will also 
improve  the  mutual  recognition  of  forensic  evidence  as  well  as  help  to  increase  common 

X 

X 

X 

X 

159 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
No subsidiarity / 
proportionality issues 

High EU added value / 
rationale 

Low financial costs 

Positive overall effects 

Strong stakeholder 
support 

.
s
e
c
i
t
c
a
r
p
y
r
o
t
a
r
o
b
a
l

g
n
i
n
e
e
r
c
s

t
s
r
i
F

n
o
i
t
c
a

y
c
i
l
o
P

.
o
N

N
E

0
6
1

N
E