Nonproliferation: Delays in Implementing the Chemical Weapons Convention Raise Concerns About Proliferation
Published: 2004-03-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Chemical Weapons Convention (CWC) bans chemical weapons and requires their destruction by 2007, with possible extensions to 2012. The CWC also seeks to reduce the proliferation of these weapons by requiring member states to adopt comprehensive national laws to criminalize CWC-prohibited activities. The Organization for the Prohibition of Chemical Weapons (OPCW) monitors the destruction of chemical weapons and inspects declared commercial facilities in member states. GAO was asked to review (1) member states' efforts to meet key convention requirements, (2) OPCW's efforts in conducting inspections to ensure compliance with the convention, and (3) Russia's efforts to destroy its chemical weapons stockpile.
section_title: What GAO Found
paragraphs: The CWC has helped reduce the risks from chemical weapons, but CWC member states are experiencing delays in meeting key convention requirements as the CWC's goals have proven more difficult to achieve than anticipated. For example, we estimate that Russia and the United States will not complete destruction of their chemical weapons stockpiles until after the convention's deadline of 2012, if extended. Less than 40 percent of member states have adopted national laws to prosecute individuals that pursue CWC-prohibited activities. The Department of State also believes that China, Iran, Russia, and Sudan have not fully declared the extent of their chemical weapons programs. The OPCW faces resource challenges in addressing the proliferation threat posed by commercial facilities and inspecting an increased number of military facilities that destroy possessor states' chemical weapons. Although the OPCW has conducted nearly 1,600 inspections in 58 member states since April 1997, more than half have been conducted at military facilities. About 36 percent of OPCW commercial inspections have taken place at facilities producing the most dangerous chemicals identified by the CWC. The OPCW recognizes that it must increase the number of inspections conducted at facilities that produce dual-use chemicals. Some of these facilities may pose a proliferation threat. The lack of a credible Russian chemical weapons destruction plan has hindered and may further delay destruction efforts, leaving Russia's vast chemical weapons arsenal vulnerable to theft or diversion. As of September 2003, Russia had one operational destruction facility and had destroyed 1.1 percent of its 40,000 metric tons of chemical weapons. Russia's destruction efforts rely heavily on international assistance. Since 1993 international donors, including the United States, have obligated about $585 million for Russian destruction efforts while Russia has spent about $95 million.

section_title: Letter
paragraphs: The Chemical Weapons Convention (CWC) entered into force in April 1997.  It is the only multilateral treaty that seeks to eliminate an entire category of  weapons of mass destruction within an established time frame and verify  their destruction through inspections and monitoring. Specifically, the  convention bans the production, possession, and use of chemical weapons  and requires the destruction of chemical weapons stockpiles by 2007 with  possible extensions to 2012. The CWC also requires member states to adopt  national laws implementing the convention and to declare their military  chemical weapons facilities and commercial facilities producing dual-use  chemicals to the Organization for the Prohibition of Chemical Weapons  (OPCW). As of March 2004, 161 countries are CWC members, including the  Russian Federation and the United States. At the CWC’s first review  conference in spring 2003, some member states expressed concern that  many member states are not meeting their key CWC obligations.  For  example, Russiathe world’s largest possessor of declared chemical  weaponsis experiencing delays in destroying its stockpile.
In response to your request, we reviewed (1) member states’ efforts to  meet key CWC requirements, (2) OPCW’s efforts to conduct inspections to  ensure compliance with the convention, and (3) Russia’s efforts to destroy  its chemical weapons stockpile.
In conducting our work, we reviewed the CWC, analyzed verification and  program documents from the OPCW, and met with OPCW officials.  Additionally, we met with officials from the Departments of Commerce,  Defense, and State, as well as member states’ representatives to the OPCW  at The Hague, the Netherlands. We also obtained information from Russian  government officials and visited the U.S.-funded chemical weapons  destruction facility site at Shchuch’ye in Russia.  To assess the reliability of  the data used in the report, we reviewed relevant documents and obtained  necessary information from agency and government officials. For the  purposes of our work, we determined that the data are sufficiently reliable.  We performed our work from April 2003 through March 2004 in accordance  with generally accepted government auditing standards. (See app. I for the  details of our scope and methodology.)
subsections: section_title: Background
paragraphs: The CWC is a multilateral arms control treaty that bans the development,  production, stockpiling, transfer, and use of chemical weapons by member  countries and requires the declaration and destruction of those countries’  existing chemical weapons stocks and production facilities by 2007, with a  possible extension to 2012.  The CWC also monitors the production and  transfer of chemicals at declared commercial facilities. When the CWC  entered into force in April 1997, there were 87 member states.  As of March  2004, 161 nations are CWC member states, including Libya.  Twenty-one  countries are signatories but have yet to ratify the treaty. According to the  State Department, key nonsignatory states include North Korea and Syria,  which are believed to possess or are actively pursuing chemical weapons  capabilities.
Upon ratification of the CWC, all member states are required to adopt  national laws that criminalize CWC-prohibited activities and establish a  national authority to serve as the national focal point for liaison with the  OPCW.  All members are required to submit initial declarations to the  OPCW no later than 30 days after entering into the convention and annual  declarations detailing transfer activities of all declared chemicals no later  than 90 days after the end of the year. Member states must also declare  chemical weapons stockpiles and production facilities, relevant chemical  industry facilities, and other related information such as chemical exports  and imports.  Member states that possess chemical weapons stockpiles and  production facilities must destroy them by April 2007. Six member states— Albania, India, Libya, Russia, the United States, and A State Partyhave  declared their chemical weapons stockpiles and are considered possessor  states. Eleven member states have declared chemical weapons production  facilities.
The OPCW consists of three organsthe Conference of States Parties, the  Executive Council, and the Technical Secretariatand was established by  the convention to implement its provisions. The Technical Secretariat  manages the organization’s daily operations, including the implementation  of the convention’s verification measures.  The Technical Secretariat serves  as the repository for all member states’ declarations and relies upon  individual member states to submit accurate, timely, and complete  declarations. Based on these declarations, the Technical Secretariat  inspects and/or monitors member states’ military and commercial chemical  facilities and activities to ensure their compliance with the CWC. Also, if a  member state suspects another member state of conducting activities  prohibited by the convention, it may request a challenge inspection of the  suspected site(s). As of December 2003, no member state has requested the  OPCW to conduct a challenge inspection.
Technical Secretariat inspectors take inventories of the declared stockpiles  to verify the accuracy of the declarations and ensure that chemical  weapons are not removed. Inspectors continuously monitor the  destruction of chemical weapons at operating destruction facilities by  observing the receipt of chemical weapons at sites and checking the type  and quantity of chemical weapons destroyed. Inspectors also verify the  destruction or conversion of declared chemical weapons production  facilities by observing the destruction of applicable buildings and  production equipment. So that dual-use chemicals are not diverted from  their peaceful uses, the Technical Secretariat inspects declared commercial  production facilities based on three schedules, or lists of chemicals,  contained in the CWC. Commercial facilities that produce discrete organic  chemicals, above 200 metric tons, are also subject to inspections. OPCW  inspectors verify that the types of chemicals being produced are consistent  with the member states’ declarations.
Funding for OPCW inspections and other operations comes primarily from  the 161 member states’ required annual contributions, which are based on  the United Nations’ scale of assessments. The other major source of  funding comes from reimbursements of inspections costs paid by chemical  weapons possessor states.  The OPCW is partially reimbursed for  inspection costs incurred while conducting inspections at declared  chemical weapons facilities in those countries. The organization, however,  must fund inspections at commercial facilities and any challenge  inspections it conducts.  The organization’s budget for calendar year 2004 is  $82.6 million.
section_title: Member States Are Experiencing Delays in Complying with Key CWC Requirements
paragraphs: Although the CWC has helped to reduce the risks from chemical weapons,  member states are experiencing delays in destroying their chemical  weapons and implementing key requirements of the treaty. For example,  Russia and the United States are unlikely to destroy their declared  chemical weapons by the extended deadline of 2012, and many member  states have not adopted national laws that fully implement the CWC.  In  addition, some member states have yet to provide the OPCW with complete  and timely declarations detailing their CWC-related activities.
subsections: section_title: Complete Destruction of Largest Possessor States’ Chemical Weapons Stockpiles Will Extend beyond Deadline
paragraphs: We estimate that the United States and Russia are unlikely to meet the 2012  extended CWC deadline for destroying their chemical weapons. Three  other possessor states—Albania, India, and A State Party—possess smaller  stockpiles and are expected to destroy their stockpiles by the original April  2007 deadline (see table 1). In addition, Libya became the sixth possessor  state in February 2004 when it became a member of the CWC and declared  that it possessed chemical weapons.  According to OPCW officials and  CWC possessor states, the destruction of chemical weapons has proven  more complex, costly, and time consuming than originally anticipated.
Russia currently possesses the world’s largest declared chemical weapons  stockpile at 40,000 metric tons stored at seven sites, as shown in figure 1.  The stockpile includes 32,500 metric tons of nerve agent, the most toxic of  all known chemical agents, and 7,500 metric tons of blister agent. As we  have previously reported, DOD has installed security upgrades at  Shchuch’ye and Kizner, the two sites with portable nerve agent munitions.   However, a large quantity of Russia’s chemical weapons will remain  vulnerable to theft or diversion until they are destroyed. As of September  2003, Russia had destroyed 1.1 percent of its total CWC-declared stockpile.
Russia did not meet the original treaty deadline to destroy 1 percent of its  stockpile by April 2000.  In accordance with treaty provisions, Russia  requested and received an extension of its 1-percent and 20-percent  deadlines from the OPCW. In April 2003, Russia met the one percent  destruction deadline.  Based on information provided by DOD, we estimate  that Russia may not destroy its declared chemical weapons stockpile until  2027. Our analysis is predicated on Russia’s complete destruction of its  approximately 7,500 metric tons of blister agent by the 2007 deadline and  destroying the remaining 32,500 metric tons of nerve agent at the U.S.  funded destruction facility at Shchuch’ye.  In September 2003, Russia  agreed to complete the elimination of all of its nerve agent at the  Shchuch’ye destruction facility, which is scheduled to begin operations in  2008.  According to DOD, the Shchuch’ye facility may not be operational  until 2009. For Russia to meet an extended April 2012 deadline, Russia  would have to destroy about 9,100 metric tons of nerve agent per year.  Operating at maximum capacity, the facility is estimated to destroy about  1,700 metric tons of nerve agent per year. At that rate, unless the capacity  for destruction is increased or additional destruction facilities are built, the  complete destruction of Russia’s stockpile may not occur until 2027.  (We  discuss other options for destroying Russia’s nerve agent stockpile later in  this report.)
The United States possesses the second largest declared chemical weapons  stockpile with 27,771 metric tons, which is stored at eight sites, as shown in  figure 2.  Currently, the United States is operating three destruction  facilities; three additional facilities will be operational in the near future  and two more will begin construction. As of December 2003, the United  States destroyed 24 percent of its declared stockpile and met the 1-percent  and 20-percent interim deadlines within the treaty time frames.  However,  the United States requested and received an extension of the 45-percent  deadline from April 2004 to December 2007. The United States will not  meet the 100-percent April 2007 destruction deadline and may not meet the  2012 deadline, if extended, based on the current schedule. According to  DOD, one U.S. chemical weapons destruction facility is not scheduled to  complete its destruction operation until 2014.  Persistent delays have  occurred due to plant safety issues, environmental requirements, and  funding shortfalls. We have previously reported on the significant  management challenges in the U.S. chemical demilitarization program, as  well as concerns over cost growth and schedule delays. As noted in our  prior work, the U.S. chemical weapons demilitarization program spent  $11.4 billion by the end of fiscal year 2003, which accounts for nearly half of  the program’s life-cycle cost estimate of $24 billion.
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Three other possessor statesAlbania, India, and A State Partyaccount  for about 3 percent of the global declared chemical weapons stockpile and  are anticipated to meet the CWC complete destruction time line by April  2007.  With smaller stockpiles than those in Russia and the United States,  these countries have had less difficulty meeting their deadlines.  Albania  declared its stockpile to the OPCW in 2003, and the United States is  providing assistance to destroy its chemical weapons stockpile.  Other  nations, including Canada and Italy, may also provide assistance. State  officials estimate that Albania will meet the 2007 destruction deadline.  According to Indian officials, India has the third largest stockpile after  Russia and the United States; however, information on its chemical  weapons destruction program is not publicly available.  The fifth possessor  state, A State Party, experienced interim delays due to technical difficulties.   It requested and received an extension of its 45-percent chemical weapons  destruction deadline in 2003.  According to government officials, it remains  on track to meet the 2007 deadline.  Libya, the sixth possessor state, has  just declared its chemical weapons to the OPCW and has yet to develop a  destruction plan for its stockpile.
section_title: Many Member States Have Yet to Adopt National Laws Implementing the CWC
paragraphs: According to the OPCW, less than 40 percent of CWC member states have  adopted national laws to criminalize CWC-prohibited activities. Although  the treaty does not establish a time line for the adoption of such measures,  according to the OPCW, member states are expected to implement these  laws soon after ratifying the convention. OPCW officials stated that many  member states lack sufficient legal expertise and financial resources to  adopt the required laws. At the 2003 CWC Review Conference, however,  the United States launched an initiative to assist all CWC member states in  adopting comprehensive national laws.  The effort culminated in an OPCW  action plan to help member states adopt necessary laws by 2005.
According to the OPCW, 126 member states have designated a national  authority to collect and submit their declarations. However, OPCW and  State officials estimate that a large number of member states’ national  authorities are not effective because they lack sufficient financial and  human resources. National authorities are important in implementing the  treaty because they facilitate member states’ ability to submit accurate and  timely declarations to the OPCW and host OPCW inspections.  To  encourage member states to improve the effectiveness of their national  authorities, the OPCW hosts workshops to identify common problems and  assist member states in addressing them accordingly.
section_title: Some Member States Have Submitted Incomplete or Late Declarations
paragraphs: According to a 2001 Department of State report, four CWC member  statesChina, Iran, Sudan, and Russiahad not acknowledged the full  extent of their chemical weapons program. The CWC requires member  states to fully and accurately declare their chemical weapons capabilities.   However, State believes that China maintains an active chemical weapons  research and development program, a possible undeclared chemical  weapons stockpile, and weapons-related facilities that were not declared to  the OPCW. Iran has not submitted a complete and accurate declaration  and is seeking to retain and modernize key elements of its chemical  weapons program, according to the report.  Sudan established a research  and development program with a goal to produce chemical weapons  indigenously. The report also assesses that Russia has not divulged the full  extent of its chemical agent and weapons inventory.  State views Russia’s  declaration of its chemical weapons production, development facilities,  and chemical agent and weapons stockpiles as incomplete. In addition,  State reported that Russia may have knowledge of a new generation of  agents that could circumvent the CWC and possibly defeat western  detection and protection measures.  The significance of this issue was  addressed at the 2003 CWC Review Conference.  The Director-General of  the OPCW urged member states to provide accurate and complete  declarations to increase transparency and confidence in the treaty.
Furthermore, member states have been late in submitting their required  initial and annual declarations to the OPCW.  As of December 2002, nearly  97 percent of all member states submitted their initial declarations, but a  large percentage of member states did not submit their initial declarations  within the required 30-day time frame. The OPCW also engaged in bilateral  consultations to assist member states in submitting their initial  declarations.  As of October 2003, nearly one-third of member states had  failed to submit their annual declarations in a timely manner. According to  the OPCW, delays in submitting the required declarations make it difficult  for the organization to plan its annual inspections and track chemical  transfers.
section_title: OPCW Conducts Inspections, but Significant Challenges Remain
paragraphs: The OPCW has established a credible inspections regime. Between 1997  and 2003, the OPCW conducted nearly 1,600 inspections in 58 member  states. However, the organization faces significant challenges as it prepares  to balance an increased number of inspections at both military and  commercial facilities with its limited resources. The CWC does not specify  the number of annual inspections that the OPCW is required to conduct.   Since April 1997, more than half of OPCW inspections have taken place at  military facilities even though some commercial facilities may pose a  greater proliferation threat. To meet the increased demands on its limited  resources, the OPCW is working with member states to further improve the  efficiency of its inspection activities.
subsections: section_title: OPCW Implementing CWC Inspection Regime
paragraphs: From April 1997 through December 2003, the OPCW’s Technical Secretariat  has conducted nearly 1,600 inspections at both military and commercial  chemical facilities in 58 member states. (See app. II for a chart depicting  the locations of inspections conducted.) According to OPCW officials and  member states’ representatives we interviewed, inspections are proceeding  as planned under the CWC. Within the United States, officials from the  State, DOD, and Commerce, as well as chemical industry representatives,  stated that the United States and OPCW inspectors work cooperatively to  implement the inspection regime. When questions or concerns arise, the  Technical Secretariat and the affected member state(s) work to resolve  them. For example, the United States and the OPCW have resolved issues  such as clarifying which portions of declared commercial facilities are  subject to inspection. According to DOD, OPCW inspectors have good  access to declared sites and facilities.
As of December 2003, the Technical Secretariat conducted 965 inspections  at 167 of 190 declared military sites. The military sites that have not been  inspected are either chemical weapons production facilities destroyed  prior to CWC entry into force or sites having old or abandoned chemical  weapons.  Although the CWC requires that OPCW maintain a continuous  presence at member states’ sites when chemical weapons are being  destroyed, it does not specify how many inspections are to be conducted  annually.  The Technical Secretariat determines how many inspections to  conduct annually based on the number of military facilities declared by  member states, member states’ annual destruction plans, annual  declarations, and the annual OPCW budget documents.  The greatest  number of inspections has taken place at chemical weapons destruction  facilitiesprimarily in the United States, Russia, and India. About one-third  of all inspections conducted by the Technical Secretariat have taken place  in the United States, mostly at chemical weapons destruction facilities.  Table 2 shows the number of inspections conducted at different types of  facilities at military sites from April 1997 through December 2003.
Between April 1997 and December 2003, Technical Secretariat officials  conducted 634 inspections at 514 sites among the 5,460 commercial  facilities declared by member states (see table 3).  Because the CWC does  not specify the specific number of inspections to be conducted each year,  the Technical Secretariat selects the facilities it will inspect based on those  requiring initial inspections and the potential proliferation risk of facilities.  The annual budget document specifies the number of inspections to be  conducted.  Since April 1997, most OPCW commercial inspections have  taken place at facilities that produce chemicals listed on the CWC’s three  schedules. Of the declared 4,492 facilities that produce discrete organic  chemicals (DOC), the organization has inspected 163. DOC facilities  produce a wide range of common commercial chemicals and may also be  capable of producing chemical weapons.  According to U.S. government  and OPCW officials, such dual-use DOC facilities may pose a proliferation  threat because they may conceal CWC-prohibited activities.  Most  significantly, these DOC facilities may be modified to produce scheduled  and other chemicals that are not specifically listed on current CWC  schedules but are still banned by the CWC, if intended for prohibited  purposes. In commenting on a draft of our report, the OPCW provided  clarification of this proliferation issue.  While the majority of commercial  facilities produce discrete organic chemicals, the OPCW estimates that less  than 20 percent of these DOC sites may pose highly relevant proliferation  risks.
section_title: OPCW Faces Significant Challenges in Conducting More Inspections
paragraphs: Although the OPCW has made progress in conducting inspections as  mandated by the convention, it faces challenges in meeting an increase in  its inspection workload.  As possessor states’ destruction activities  increase over the next few years, the OPCW will have to maintain a  continuous inspection presence at more facilities.  Concurrently, the OPCW  wants to increase the number of inspections it conducts at commercial  DOC facilities to address proliferation concerns.  However, the OPCW has  experienced financial difficulties over the past few years.  To better meet  the increased demand on its resources, the OPCW is working with member  states to find more efficient and cost-effective means of conducting its  inspection activities.
The OPCW projects that the number of chemical weapons destruction  facilities that will require monitoring will increase from seven to nine by  2007.  Under the CWC, OPCW inspectors must maintain a continuous  onsite presence at chemical weapons destruction facilities to monitor and  verify the destruction of chemical weapons stockpiles. According to OPCW  officials, the organization is reimbursed for about two-thirds of the  expenses it incurs during such inspections. OPCW inspection costs will  increase, if the organization maintains a continuous on-site presence at the  additional chemical weapons destruction sites that will begin operations in  the near future. However, the Technical Secretariat and member states are  currently discussing possible monitoring alternatives that may reduce costs  without compromising the credibility of the inspections.
According to the OPCW, the organization is working to increase the  number of inspections it conducts at commercial DOC facilities to address  the proliferation risks they pose.  In 2002, for example, 32 of 85 commercial  inspections conducted were at DOC facilities.  In 2004, the OPCW plans to  increase the number of DOC facility inspections to 70 out of a total of 150  inspections planned at commercial facilities.  Furthermore, OPCW and  member states are working to refine the current criteria used to select  DOC facilities for inspections to ensure that the selection process takes  into account all factors mandated by the CWC.
Due to budget deficits in 2001 and 2002, the Technical Secretariat had to  reduce the number of inspections it planned to conduct at commercial  chemical facilities. Such deficits were mostly the result of member states’  late payment of their annual assessments and reimbursements for military  inspections. When funding was limited, the OPCW could not reduce the  number of inspections at destruction facilities because inspectors are  required to continuously monitor these sites when operational. Instead, it  reduced the number of commercial inspections it conducted. In 2001, the  OPCW conducted 57 percent (75 of 132) of its planned inspections at  commercial sites.  For 2002, it conducted 64 percent (85 of 132) of its  planned inspections.  Although previous financial difficulties caused a  reduction in the number of inspections, the Technical Secretariat  completed its planned number of 132 commercial inspections for 2003.  Member states approved a more than 6-percent increase in the OPCW’s  budget for 2004. According to OPCW officials, such budget increases are  unlikely to continue in future years, and the problem of late receipt of  member states’ annual assessments and reimbursements will likely  reoccur.
To meet the increased demand for inspections, the Technical Secretariat is  working to improve the efficiency of its inspection activities.  The  organization has reduced the size of inspection teams at military sites,  thereby lowering daily allowance and travel costs.  For example, the team  size for most inspections conducted at chemical weapons storage facilities  was reduced from eight in 2002 to six in 2003. The Technical Secretariat has  also devised new contracts for inspectors of chemical weapons destruction  facilities that permit hiring part-time inspectors for 1 year.  When  implemented, such contracts could reduce staff costs and provide for more  flexibility in assigning inspection teams.  The OPCW and member states are  also exploring greater use of monitoring and recording instruments at  chemical weapons destruction facilities to reduce the number of inspectors  needed on-site.  Cost-saving measures have also been proposed and  implemented to increase the efficiency of inspections conducted at  commercial facilities, including reducing the size of inspection teams and  the time they spend on-site.
section_title: Russia Faces Significant Challenges in Destroying Its Chemical Weapons
paragraphs: Russia is experiencing delays in destroying its chemical weapons. As of  September 2003, Russia had destroyed 1.1 percent of its 40,000 metric tons  of chemical weapons at its only operational destruction facility. Russian  destruction efforts have also relied almost entirely on international  assistance. As of December 2003, international donors have shipped about  $585 million and committed more than $1.7 billion to Russian destruction  efforts.  According to State, from 2001 through 2003 Russia budgeted about  $420 million for chemical weapons demilitarization-related activities.   Russia spent about $95 million. However, based on its current destruction  efforts and the international assistance committed, Russia will not meet the  extended CWC destruction deadline of 2012. Furthermore, Russia has yet  to develop a comprehensive destruction plan that includes the types of  projects and funding needed to completely destroy its declared stockpile,  which may further delay destruction efforts.
subsections: section_title: One−Percent Milestone Achieved at Gorny; Two Additional Facilities under Construction
paragraphs: Russia plans to destroy its chemical weapons stockpiles at Gorny,  Kambarka, and Shchuch’ye, primarily using assistance provided by  Germany and the United States. Russia has yet to develop a credible plan to  destroy the remaining 50-percent of its chemical weapons stockpile stored  at Maradykovsky, Leonidovka, and Pochep. Table 4 provides the time line  for Russia’s destruction efforts at facilities in operation or under  construction.
Russia is relying on German assistance to destroy its stockpile of blister  agent at the Gorny and Kambarka facilities.  According to DOD, Germany  focused its assistance in this area because it had experience destroying  World War II blister agents. As of September 2003, Russia destroyed 455  metric tons of blister agent (1.1 percent of the Russian stockpile) stored at  the Gorny facility. Russia will destroy the remaining stockpile at Gorny by  December 2005, according to a German official.  Russia constructed the  building for the destruction facility, while Germany spent about $58 million  from 1993 to 2003 to equip the facility. Germany has committed $120  million for the Kambarka destruction facility, currently under construction,  and up to $300 million in additional funds, according to a German  government official. The facility at Kambarka will destroy the entire  stockpile of blister agent located there by December 2009. The  construction schedule of this facility may be delayed, according to a  German government official overseeing the assistance.
subsections: section_title: Shchuch’ye Will Destroy 30 Percent of Russia’s Chemical Weapons Stockpile
paragraphs: Once operational, the Shchuch’ye chemical weapons destruction facility  will begin to destroy nerve agent from two Russian storage sites that house  nearly 30 percent of the total Russian stockpile. The storage facilities at  Kizner and Shchuch’ye each house about 5,500 metric tons of nerve agent  stored in projectiles and rockets. According to DOD and State officials, the  United States has focused its assistance to Russia at Shchuch’ye because  these chemical weapons are portable and thus vulnerable to theft and  diversion.
The United States has agreed to pay for the destruction facility at  Shchuch’ye. The facility is scheduled to destroy the nerve agent  stockpiles located at both the Shchuch’ye and Kizner storage sites.  DOD’s  Cooperative Threat Reduction program has obligated more than $460  million on planning, design, and construction of the facility.  In October  2003, DOD updated the costs and schedule for completing the Shchuch’ye  facility and projected that the cost would increase from about $888 million  to more than $1 billion. DOD also noted that the operation of the facility  may be delayed from September 2008 to July 2009. DOD attributes the  increased cost to changed site conditions, new requirements, risk factors,  and delays due to lack of U.S. funding for 2 years caused by Russia’s  inability to meet U.S. congressional conditions. Once operational, the  facility is estimated to destroy 1,700 metric tons of chemical weapons per  year. With a July 2009 operational date, we estimate that the destruction of  chemical weapons stored at Shchuch’ye and Kizner will not be completed  until at least 2016. (For more detailed information on international  assistance for chemical weapons destruction at Shchuch’ye, see app. III.)
section_title: Russian Plans for Destroying Remainder of Its Nerve Agent Stockpile Are Unknown
paragraphs: In November 2003, the Director of the Russian Munitions Agency informed  us that Russia has not yet decided how it will destroy the remaining nerve  agent stored at Maradykovsky, Leonidovka, and Pochep. This nerve agent  represents over 50 percent of the total Russian chemical weapons  stockpile.  In September 2003, the United States and Russia amended a  March 2003 agreement under which the Russian Munitions Agency agreed  to complete the elimination of all nerve agent at the Shchuch’ye destruction  facility, unless otherwise agreed in writing. According to DOD and Russian  government officials, there is uncertainty whether Russia will comply.  Russian officials have concerns about the costs and risks of transporting  the weapons from these sites to Shchuch’ye, most of which are located  more than 500 miles away.  As a result, Russian officials have indicated that  Russia may construct three chemical weapons neutralization facilities for  the nerve agent stored at Maradykovsky, Leonidovka, and Pochep. Under  this option, Russia would neutralize the chemical weapons at the three  sites so the agent would be safe for transport, and then complete the  destruction process at Shchuch’ye.  This would require the construction of  three neutralization facilities plus new destruction capacity at Shchuch’ye,  because the neutralized agent would likely be destroyed using a different  process than the unneutralized agent from the Shchuch'ye and Kizner sites.   In November 2003, however, Italy agreed to commit funding for the  construction of a destruction facility at Pochep.
subsections: section_title: International Donors Assist Russian Chemical Weapons Destruction
paragraphs: While Germany and the United States have obligated about $515 million  and committed an additional $1 billion for Gorny, Kambarka, and  Shchuch’ye, other donors have spent about $70 million at these sites.  Furthermore, in June 2002, the Group of Eight launched the Global  Partnership initiative, which was designed to prevent the proliferation of  weapons of mass destruction to terrorists and their supporters. Among  other projects in Russia, the initiative is currently assisting with chemical  weapons destruction. As of December 2003, international donors,  including the United States, Germany, Canada, Italy, and the United  Kingdom, have committed more than $1.7 billion for Russian chemical  weapons destruction.
section_title: Lack of Plan May Hinder Russia’s Progress in Destroying Chemical Weapons
paragraphs: Congress has conditioned U.S. funding for the Shchuch’ye facility on a  Secretary of Defense certification that Russia has developed a practical  chemical weapons destruction plan. In September 2003, Russia signed an  agreement with the United States to provide a chemical weapons  destruction plan by March 2004.  The plan would include the types of  projects and funding needed to completely destroy its declared chemical  weapons. Officials from State and DOD were not optimistic that the  Russians will deliver a plan within the required time.
According to State and DOD officials, Russia’s planning efforts to date have  been based on inaccurate assumptions and have lacked detailed  information on how the destruction of chemical weapons will occur at each  site.  For example, Russian officials have stated that they expect the  Shchuch’ye chemical weapons destruction facility to be operational in  2006, despite DOD estimates that it may take until July 2009. DOD officials  stated that additional time is needed to procure and install the equipment  needed for the destruction facility.
In addition, Russia’s plans need greater specificity. Russia has provided  some information to the United States regarding the following:  where the chemical weapons will be destroyed,  when they will be destroyed and the amounts at each location,   costs for each facility, and  how each facility will contribute to the destruction efforts.
According to officials from State and DOD, the information provided does  not appear credible and lacks key elements.  Russia has not provided the  method, schedule, and cost for transporting its chemical weapons to the  destruction facility at Shchuch’ye.  In addition, Russia has no credible plan  to destroy the nerve agent at Maradykovsky, Leonidovka, and Pochep.  Russian officials indicated that the nerve agent may be neutralized at each  site but did not provide any details regarding what would be needed to  undertake such an effort, including a plan to dispose of the toxic chemicals  resulting from the neutralization process.
Russia’s chemical weapons destruction efforts at Pochep, Leonidovka, and  Maradovski may be further complicated by Russia’s definition of  destruction, which differs from that of the United States and the OPCW.  The CWC defines destruction of chemical weapons as an essentially  irreversible process.  The United States and the OPCW maintain that  chemical weapons are not destroyed until the materials resulting from the  destruction process are essentially irreversible (i.e., can no longer be  reversed back to chemical weapons) and the remaining materials can be  inspected by the OPCW. The United States neutralizes some of its chemical  weapons in a two-phase process that first neutralizes the agent and then  transports the resulting hazardous waste to a commercial chemical facility  for final disposition. The OPCW inspects both phases of the neutralization  process. Russian officials maintain that chemical weapons should be  considered destroyed after the initial neutralization phase and not require  further processing or OPCW inspections. Russian officials argue that,  although toxic chemicals resulting from the neutralization process could be  reverted to chemical weapons, the cost to do so would be prohibitive.   Russia raised this issue at the May 2003 CWC Review Conference, but  OPCW member states maintained that complete destruction should be an  essentially irreversible process as specified in the CWC. Despite this  opposition, Russian government officials at the Russian Munitions Agency  and the Ministry of Foreign Affairs stated in November 2003 that they  consider initial neutralization equivalent to destruction.
section_title: Observations
paragraphs: The CWC has played an important role in reducing the risks from chemical  weapons.  Member states have destroyed more than 7,700 metric tons of  chemical weapons and the OPCW has established a credible inspection  regime that has inspected many military and commercial chemical facilities  in 58 countries. Nearly 7 years after entry into force, the CWC’s  nonproliferation goals have proven more difficult to achieve than originally  anticipated. CWC member states and the OPCW face difficult choices in  addressing the delays in Russia’s destruction program, the limited number  of inspections at dual-use commercial sites, and the slow progress in  passing laws criminalizing CWC-prohibited activities.  Decision-makers  will have to make some combination of policy changes in these areas if the  CWC is to continue to credibly address nonproliferation concerns  worldwide.
First, the destruction of chemical weapons will likely take longer and cost  more than originally anticipated. Even with significant international  assistance, Russia may not destroy its declared chemical weapons until 15  years beyond the extended CWC deadline. Russia’s large stockpile will thus  remain vulnerable to theft and diversion. Several options exist, however,  for the United States and other donors to reduce the proliferation risks  from Russia’s chemical weapons stockpile. Such options may include (1)  increasing funding for security improvements at Russia’s chemical  weapons storage sites, (2) deferring financing for Russia’s chemical  weapons destruction effort until the Russian government develops a  credible destruction plan, or (3) financing the construction of additional  destruction facilities.
Second, technical advancements in the chemical industry and the  increasing number of dual-use commercial facilities worldwide challenge  the CWC and the OPCW’s ability to deter and detect proliferation. Member  states will need to determine the best policies for addressing potential  proliferation at dual-use commercial facilities.  CWC member states could  decide that the OPCW should conduct more commercial inspections,  which would require member states to provide more funding and subject  their national chemical industries to additional inspections. Alternatively,  member states may determine that the current level of commercial  inspections is sufficient to detect and deter activities prohibited by the  CWC.
Third, many member states have not yet adopted national laws to fully  implement the convention, or have not submitted complete and accurate  declarations of their CWC-related activities. These problems undermine  confidence in overall treaty compliance. It is important for the OPCW and  member states to reinforce member states’ obligations to adopt national  laws, enforce them accordingly, and submit accurate and timely  declarations. Challenge inspections may also be a vehicle to ensure  member states’ compliance with the CWC.
section_title: Agency Comments and Our Evaluation
paragraphs: We obtained written comments on a draft of this report from State, DOD,  Commerce, and the OPCW, which are reprinted in appendixes IV, V, VI, and  VII respectively.  We also received technical comments from the  departments as well as the OPCW, which we have incorporated where  appropriate.  In commenting on our draft report, State asserted that our  report was misleading, incomplete, and not balanced.  State did not   provide specific examples but instead claimed that the report omitted  positive CWC accomplishments such as growth in the number of member  states, correction of OPCW management inefficiencies, and OPCW  execution of the CWC inspection regime. In response, we agree that the  CWC has played an important role in reducing the threat posed by chemical  weapons and the report acknowledges this accomplishment.  With regard  to State’s comment about the growth in the number of CWC member states,  the report focuses on CWC implementation among already existing  member states.  For clarification however, we have provided additional  information on the increase in CWC membership since entry into force.   Secondly, State commented that the report did not assess OPCW  management corrections.  In this report we reviewed OPCW’s efforts to  conduct inspections, not the management of the organization.  We had  previously reported on this topic in October 2002.  Thirdly, the report  clearly articulates that the OPCW has established a credible inspection  regime and has conducted nearly 1,600 inspections in 58 member states.  While this report discusses several important delays in CWC  implementation, it still acknowledges that the CWC and OPCW have made  important contributions to addressing the threat posed by chemical  weapons.
DOD commented that our draft report had little analysis of the relative  degree of proliferation risk from those member states lacking  implementing legislation.  DOD, however, does not offer what criteria one  would use to make a determination about which member states are more  important to CWC implementation.  As stated in the report, the CWC  requires all member states to adopt national implementing legislation. In  addition, DOD believes that the report is not conducive to providing a  balanced perspective because it does not acknowledge successes in  implementing the CWC.  For example, DOD cites that progress has been  made in eliminating former chemical weapons production facilities and  destroying category 2 and 3 chemical weapons related munitions.  Such  successes, however, remain secondary to the CWC’s primary goal of  destroying actual chemical weapons.  As stated in this report, the CWC is  the only multilateral treaty that seeks to eliminate an entire category of  weapons of mass destruction under an established time frame and verify  their destruction through inspections.  DOD also asserts that the report  does not recognize the significant changes occurring within the OPCW. As  mentioned previously, this report does not assess OPCW functions or  performance because we conducted such a review of the OPCW in October  2002.  This report does, however, credit the OPCW with finding more  efficient and cost-effective means of conducting its inspection activities as  it faces the challenge of meeting an increased inspection workload.  We  have included additional information in this report to further clarify the  achievements of the CWC and the OPCW.
Both DOD and State commented that our analysis estimating that Russia  may not destroy its chemical weapons stockpile until 2027 was misleading.   We have clarified our presentation of this analysis to include a discussion  of other options being considered for destroying Russia’s stockpile. As of  March 2004, only one facility capable of destroying nerve agent is being  constructed in Russia.  Although plans to build additional facilities are  being discussed, we note that construction of the U.S-funded facility at  Shchuch’ye began 11 years after the U.S. and Russia first agreed to build it.
Commerce commended the report for focusing attention on the important  issue of member states’ achieving compliance with the CWC.  The  department noted that the U.S. government has taken a leading role at the  OPCW in promoting an action plan to ensure all member states’ adoption of  national law implementing the CWC and is providing assistance to member  states to achieve this goal.
The OPCW commended the draft report for reflecting what has been  achieved through CWC implementation and recognizing areas where  challenges still exist. It noted, however, that some statements as presented  in the report do not reflect the views of the Technical Secretariat.
As arranged with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days after the  date of this letter.  At that time we will send copies of this report to the  Secretaries of State, DOD, and Commerce; the Director-General of the  OPCW; and other interested congressional committees.  We will also make  copies available to others upon request.  In addition, this report will be  available free of charge on the GAO Web site at http://www.gao.gov.
Please contact me at (202) 512-8979 if you or your staff have any questions  concerning this report.  Another GAO contact and staff acknowledgments  are listed in appendix VIII.
section_title: Scope and Methodology
paragraphs: To determine what efforts member states have made in meeting key  Chemical Weapons Convention (CWC) requirements, we compared these  requirements with documents obtained from the Organization for the  Prohibition of Chemical Weapons (OPCW) and the Department of State  (State), including annual reports that assess member states’ compliance  with the treaty, surveys assessing the status of member states’ compliance  with key requirements, and member states’ official statements to the 2003  CWC Review Conference. We also obtained information from OPCW  officials including the Director-General, the Deputy Director-General, the  Administration Division, the Verification and Inspectorate Division, and the  Office of Internal Oversight, as well as member states’ representatives to  the OPCW in The Hague.  To assess the reliability of the OPCW data  regarding whether the member states are meeting their CWC requirements,  which include the destruction of chemical weapons, we reviewed  numerous OPCW and U.S. government documents, interviewed OPCW and  U.S. officials, and examined OPCW's procedures for ensuring data  reliability.  We determined that the OPCW data was sufficiently reliable for  the purposes of this engagement.  In addition, we met with officials from  State’s Bureau of Arms Control, the Bureau of Nonproliferation, the Bureau  of Verification and Compliance, and the Bureau of Intelligence and  Research in Washington, D.C., and with representatives of the intelligence  community. We also met with officials at the U.S. Mission to the OPCW at  The Hague.  To obtain information on how the CWC is implemented in the  United States we attended the June 2003 Defense Threat Reduction  Agency’s CWC Orientation Course held in Fairfax, Virginia.
To assess the OPCW’s efforts in conducting inspections to ensure  compliance with the convention, we analyzed the CWC and various OPCW  documents including Verification and Implementation Reports, annual  budgets, and other reports. In The Hague, we met with Director-General,  the Deputy Director-General, of the OPCW, and with officials from the  Administration Division and the Verification and Inspectorate Division.  We  also visited the inspection laboratory and equipment store at Rijswijk, The  Netherlands. To assess the reliability of the OPCW data regarding the  number of inspections being conducted in the CWC member states, we  reviewed numerous OPCW and U.S. government documents, interviewed  OPCW and US officials, and examined OPCW's procedures for ensuring  data reliability.  We determined that the OPCW data was sufficiently  reliable for the purposes of this engagement.  To assess member states’  experiences with OPCW inspections, we spoke with numerous member  states’ representatives to the OPCW. We also met with officials at the U.S.  Mission to the OPCW at The Hague.  In addition, we met with officials from  State’s Bureau of Arms Control, the Bureau of Nonproliferation, and the  Bureau of Verification and Compliance.  To obtain an understanding of how  OPCW inspections are conducted at military chemical weapons-related  facilities in the United States, we met with Department of Defense (DOD)  officials from the Defense Threat Reduction Agency.  We also toured the  U.S. chemical weapons destruction facility in Aberdeen, Maryland.  To  obtain an understanding of how OPCW inspections are conducted at  commercial chemical facilities in the United States, we met with  Department of Commerce officials from the Bureau of Industry and  Security, Office of Nonproliferation Controls and Treaty Compliance, as  well as representatives from the American Chemistry Council.
In reviewing Russia’s efforts to destroy its chemical weapons stockpile, we  visited the Russian Federation and obtained information from Russian  government officials at the Chamber of Accounts, the Russian Munitions  Agency, and the Ministry of Foreign Affairs.  We also met with  representatives from the Russian Duma who have funding authority over  Russian chemical weapons destruction.  In addition, we traveled to  Shchuch’ye to observe the U.S.-funded chemical weapons destruction  facility and surrounding infrastructure projects.  While in Shchuch’ye, we  spoke with local government officials and the Cooperative Threat  Reduction program funded contractor responsible for building the  Shchuch’ye facility. We obtained information from officials in the Bureau of  Nonproliferation and the Bureau of Arms Control in the Department of  State.  At DOD, we met with officials and acquired documents from the  Office of the Secretary of Defense for Cooperative Threat Reduction Policy  and the Defense Threat Reduction Agency, which set policy and manage  the implementation of CTR assistance to the Shchuch’ye facility.  We also  obtained information on international donors commitments for Russian  chemical weapons destruction efforts from DOD and government  representatives from Canada, Germany, and the United Kingdom.  We  obtained data from a variety of sources on the funding and assistance  provided for Russian chemical weapon destruction efforts.  To assess the  reliability of these data, we interviewed officials from the United States,  Canada, France, Germany, Great Britain, Italy, Russia, and the OPCW.  We  also asked these officials to corroborate other nations’ data wherever  possible.  In addition, we cross-checked the data on funding to Russia that  we were given by our different sources.  We determined that data on  funding and assistance provided for Russian chemical weapon destruction  were sufficiently reliable for the purposes of this engagement.
The information on foreign law in this report does not reflect our  independent legal analysis, but is based on interviews and secondary  sources.  We performed our work from April 2003 through March 2004 in  accordance with generally accepted government auditing standards.
section_title: Location, Number, and Type of Inspections Conducted by the OPCW (April 1997 - December 2002)
subsections: section_title: (Continued From Previous Page)
paragraphs: CWPF = chemical weapons production facility CWDF = chemical weapons destruction facility CWSF = chemical weapons storage facility ACW = abandoned chemical weapons OCW = old chemical weapons DOC = discrete organic chemicals  The inspection data contained in the table is through December 2002 because the OPCW could not  provide more current data until it has been approved by the CWC member states.  Also, the table does  not include inspections of the destruction of hazardous chemical weapons or the emergency  destruction of chemical weapons in the United States and Russia.
The OPCW considers the inspection details for A State Party to be confidential.
section_title: International and Russian Funding for Chemical Weapons Destruction at Shchuch’ye
paragraphs: As of December 2003, the United States and other international donors  have obligated about $525 million to develop, build, and support a chemical  weapons destruction facility at Shchuch’ye.  Russia has spent about $95  million. These funds support three related areas of effort: (1) the design  and construction of the destruction facility, (2) the completion of  infrastructure located outside the destruction facility necessary for its  operation, and (3) community improvement projects in the town of  Shchuch’ye.
When completed, the Shchuch’ye chemical weapons destruction facility  will comprise a complex of about 100 buildings and structures designed to  support and complete the destruction of the chemical weapons stored at  Shchuch’ye and Kizner, which represents about 30-percent of Russia’s total  stockpile. The United States, through the Department of Defense’s (DOD)  Cooperative Threat Reduction program, has obligated more than $460  million for the design, construction, equipment acquisition and installation,  systems integration, training, and start-up of the facility. The United States  plans to spend a total of more than $1 billion to finance the construction of  99 of the 100 buildings and structures within the facility, including one  building where the chemical munitions will be disassembled and the  chemical agent destroyed.  Russia has agreed to fund the construction of a  second destruction building at an estimated cost of $150 million to $175  million, according to a DOD official.  Russia spent an estimated $6 to $8  million for the construction of the second destruction building. Figure 3  illustrates the buildings and structures within the destruction facility at  Shchuch’ye.
In March 2003, the United States began construction of the Shchuch’ye  facility.  Figure 4 shows the completed foundation work for the U.S.  destruction building as of November 2003.  Prior DOD estimates indicated  that the facility would begin destroying chemical weapons in August 2008.   However, in October 2003, DOD stated the facility may not be operational  until July 2009.
Based on the U.S. design, Russia also began constructing its destruction  building at the Shchuch’ye complex in 2003, according to a DOD official,  but Russia has not provided a completion date for its destruction building.  Figure 5 shows the uncompleted foundation work on the Russian funded  destruction building, as of November 2003.
The operation of the chemical weapons destruction facility at Shchuch’ye  depends upon the completion of several infrastructure projects, such as the  installation of natural gas and water lines and an electric distribution  station.  As of October 2003, Russia had spent more than $56 million to  support those projects.  International donors have spent about $65 million  for these and other infrastructure projects, such as the construction of  access roads. About $66 million of infrastructure projects, including the  installation of sewage and fiber optic lines, remain unfunded. In September  2003, Russia signed an agreement with the United States stating that it  would complete all necessary infrastructure to support initial testing of the  Shchuch’ye facility.
In addition, Russian and U.S. officials stated that the town of Shchuch’ye  lacks adequate housing, schools, roads, and other services to support the  expected influx of destruction facility workers and their families.  As of  October 2003, the Russian government had spent more than $31 million for  a variety of community improvement projects in Shchuch’ye, including a  new school, improved medical facilities, and new housing.
section_title: Comments from the Department of State
paragraphs: The following are GAO’s comments on the Department of State letter dated  March 19, 2004.
subsections: section_title: GAO Comments
paragraphs: 1. State asserts that this report did not sufficiently present positive CWC  accomplishments such as the continuous growth in the number of CWC  member states, the identification and correction of management  inefficiencies at the OPCW, and the effective implementation of the  OPCW inspection regime. In response, we included additional  information in this report to acknowledge the growth in the number of  member states.  We also cite that Libya, the sixth possessor state,  acceded to the CWC in February 2004. This report does not discuss the  management of the OPCW, as we previously reported on the  management of the organization under the leadership of the former  Director-General, Jose Bustani. We did not review the management of  the OPCW under the current Director-General, Rogelio Pfirter but  acknowledge that he is committed to implementing management  reforms.  Finally, this report clearly articulates that the OPCW has  established a credible inspection regime. 2. State concluded that the entry into force of the CWC caused two  previously unknown stockpiles to be discovered and accelerated  chemical weapons destruction efforts.  In its comments, however, State  did not identify the member states that possess the unknown  stockpiles.  3. State cites that of the 158 member states, 56 of 61 member states with  CWC-declarable facilities have adopted national laws. This statement  implies that only countries with CWC-declarable facilities should adopt  national implementing laws.  As stated in the report, the CWC requires  all member states to adopt national implementing laws.  Assistant  Secretary of State for Arms Control stated in his remarks to the 2003  CWC Review Conference that the lack of national implementing laws  among member states is troubling “in light of the efforts of Al Qaeda  and other terrorist organizations to acquire chemical weapons.” 4. State indicated that Russia budgeted roughly $420 million for all of its  chemical weapons demilitarization-related activities between 2001 and  2003 and that Russia’s approved 2004 budget requests about $180  million more.  We have included this additional information in the  report, as it was not previously provided to us. 5. State contends that our estimated deadline of 2014 for the complete  destruction of the U.S. chemical weapons stockpile is unsubstantiated.  The department further asserts that our 2027 estimate for the  completion of Russia’s chemical weapons destruction assumes a single  nerve agent destruction facility, at Schuch’ye and that we omit the  possibility of constructing additional destruction facilities.  We have  clarified the 2014 deadline by adding information citing a U.S. chemical  weapons destruction facility schedule that indicates that the facility  will not complete its destruction operations until 2014. While we  acknowledge that Russia may construct additional destruction  facilities, our analysis is based on the destruction capacity of the one  nerve agent destruction facility currently under construction.  At this  time, there are no other nerve agent destruction facilities under  construction and no definitive plans for building additional facilities.   Furthermore, Russia has agreed to eliminate all nerve agent at  Shchuch’ye, unless otherwise agreed in writing. In a March 2004  congressional testimony, the Deputy Undersecretary of Defense for  Technology Security Policy and Counterproliferation stated that the  Shchuch’ye facility “will destroy all of Russia’s nerve agent inventory.”  While Russian officials have indicated that Russia may construct  neutralization facilities at Pochep, Leonidovka, and Maradovski, a  detailed plan and/or cost estimates have yet to be provided.  6. State contends that the option of delaying further assistance to Russia  could result in a greater proliferation threat. State implies that we are  only presenting one option, when in fact this report provides numerous  options, including providing additional assistance for Russian chemical  weapons destruction.  Furthermore, Congress has previously exercised  the option of withholding U.S. assistance for Russian chemical  weapons destruction. 7. State claims that facilities that produce discrete organic chemicals  (DOC) are of little or no proliferation concern to the CWC.  However,  information we obtained from State, Commerce, DOD, and the OPCW,  contradicts this statement.  Officials and documents from all four  organizations clearly expressed concern over the potential  proliferation risks from DOC facilities.  This report, therefore, indicates  that these facilities produce a wide range of common commercial  chemicals and may be capable of producing chemical weapons.  8. State cites that this report omits the fact that all existing chemical  weapons production, storage, and destruction facilities have been  inspected multiple times.  To further clarify the inspection information  contained in this report, we have included the information.
section_title: Comments from the Department of Defense
paragraphs: The following are GAO’s comments on the Department of Defense letter  dated March 18, 2004.
subsections: section_title: GAO Comments
paragraphs: 1. DOD stated that this report provides little or no analysis to conclude  how many of those member states lacking implementing legislation  truly pose a proliferation risk. In its comments, however, DOD does not  offer what criteria one would use to make a determination about which  member states are more important to CWC implementation.  As stated  in this report, the CWC requires all member states to adopt national  implementing legislation after ratifying the convention. 2. According to DOD, this report does not give the visibility it should have  to some of the central nonproliferation aspects of the CWC, such as a  discussion of the proliferation risks associated with discrete organic  chemical facilities. This report includes a specific discussion of how  such dual-use facilities pose a proliferation threat because they may  conceal CWC-prohibited activities.  This report does not further  elaborate on the degree of proliferation posed by these facilities as  such information is classified. 3. DOD believes that this report is not conducive to providing a balanced  perspective because it does not acknowledge successes in  implementing the CWC.  For example, DOD cites that progress has  been made in eliminating former chemical weapons production  facilities and destroying category 2 and 3 chemical weapons related  munitions.  Such successes, while important, remain secondary to the  CWC’s primary goal of destroying actual chemical weapons.  As stated  in the report, the CWC is the only multilateral treaty that seeks to  eliminate an entire category of weapons of mass destruction under an  established time frame and verify their destruction through inspections.   DOD also asserts that this report does not recognize the significant  changes occurring within the OPCW. This report does not assess OPCW  functions or performance because we conducted such a review of the  OPCW in October 2002.  This report does, however, credit the  organization with finding more efficient and cost-effective means of  conducting its inspection activities as it faces the challenge of meeting  an increased inspection workload.  In addition, we have provided  information in this report to further clarify that OPCW inspectors have  access to declared facilities and that there are now 161 member states  to the OPCW, including Libya. 4. DOD raised a concern about this report’s option to delay financial  assistance for Russia’s destruction program.  The report provides a  variety of policy options for decision-makers including providing more  financial assistance to finance the construction of additional  destruction facilities in Russia.  Furthermore, Congress has restricted  U.S. assistance for Russian chemical weapons destruction in the past. 5. DOD stated that this report does not adequately point out that two  additional stockpiles have been added to the list of chemical weapons  being destroyed. In its comments, however, DOD did not identify the  member states that possess these stockpiles. If DOD had provided  clarification, such information could have been included in this report,  provided that the information was not classified.
section_title: Comments from the Department of Commerce
section_title: Comments from the Organization for the Prohibition of Chemical Weapons
paragraphs: The following is GAO’s comment on the Organization for the Prohibition of  Chemical Weapons’ letter dated March 25, 2004.
subsections: section_title: GAO Comment
paragraphs: 1. We made changes to this report to accurately reflect the technical  comments we received from the OPCW.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, Beth A. Hoffman León, Nanette  J. Ryen, Julie A. Chamberlain, and Lynn Cothern made key contributions to  this report.  Etana Finkler and Pierre R. Toureille also provided assistance.
section_title: GAO’s Mission
paragraphs: The General Accounting Office, the audit, evaluation and investigative arm of  Congress, exists to support Congress in meeting its constitutional responsibilities  and to help improve the performance and accountability of the federal government  for the American people. GAO examines the use of public funds; evaluates federal  programs and policies; and provides analyses, recommendations, and other  assistance to help Congress make informed oversight, policy, and funding  decisions. GAO’s commitment to good government is reflected in its core values of  accountability, integrity, and reliability.
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subsections: section_title: Order by Mail or Phone
section_title: To Report Fraud, Waste, and Abuse in Federal Programs
section_title: Public Affairs