Nonproliferation: Delays in Implementing the Chemical Weapons	 
Convention Raise Concerns About Proliferation (31-MAR-04,	 
GAO-04-361).							 
                                                                 
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.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-361 					        
    ACCNO:   A09658						        
  TITLE:     Nonproliferation: Delays in Implementing the Chemical    
Weapons Convention Raise Concerns About Proliferation		 
     DATE:   03/31/2004 
  SUBJECT:   Arms control agreements				 
	     Chemical and biological agents			 
	     Federal aid to foreign countries			 
	     Inspection 					 
	     International agreements				 
	     International cooperation				 
	     International organizations			 
	     International relations				 
	     Property disposal					 
	     Schedule slippages 				 
	     Weapons						 
	     Strategic planning 				 
	     Chemical Weapons Convention			 
	     Russia						 

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GAO-04-361

United States General Accounting Office

       GAO	Report to the Chairman, Committee on Armed Services, House of
                                Representatives

March 2004

NONPROLIFERATION

  Delays in Implementing the Chemical Weapons Convention Raise Concerns About
                                 Proliferation

                                       a

GAO-04-361

Highlights of GAO-04-361, a report to the Chairman, Committee on Armed
Services, House of Representatives

The Chemical Weapons Convention (CWC) bans chemical weapons and requires
their destruction by 2007, with possible extensions to 2012. The CWC also
seeks to reduce the proliferation of these weapons by requiring member
states to adopt comprehensive national laws to criminalize CWC-prohibited
activities. The Organization for the Prohibition of Chemical Weapons
(OPCW) monitors the destruction of chemical weapons and inspects declared
commercial facilities in member states.

GAO was asked to review (1) member states' efforts to meet key convention
requirements, (2) OPCW's efforts in conducting inspections to ensure
compliance with the convention, and (3) Russia's efforts to destroy its
chemical weapons stockpile.

Agency Comments

The Departments of State and Defense commented that our report is not
balanced because it does not provide more examples of successful CWC
implementation. We believe the CWC has made important contributions to
nonproliferation and further clarified this point in this report. State
and Defense also expressed concern that we included a policy option to
condition future U.S. aid on development of a credible Russian chemical
weapons destruction plan. However, we provide several policy options,
including increasing aid to Russia.

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

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Joseph Christoff, (202)
512-8979 or [email protected].

March 2004

NONPROLIFERATION

Delays in Implementing the Chemical Weapons Convention Raise Concerns About
Proliferation

The CWC has helped reduce the risks from chemical weapons, but CWC member
states are experiencing delays in meeting key convention requirements as
the CWC's goals have proven more difficult to achieve than anticipated.
For example, we estimate that Russia and the United States will not
complete destruction of their chemical weapons stockpiles until after the
convention's deadline of 2012, if extended. Less than 40 percent of member
states have adopted national laws to prosecute individuals that pursue
CWC-prohibited activities. The Department of State also believes that
China, Iran, Russia, and Sudan have not fully declared the extent of their
chemical weapons programs.

The OPCW faces resource challenges in addressing the proliferation threat
posed by commercial facilities and inspecting an increased number of
military facilities that destroy possessor states' chemical weapons.
Although the OPCW has conducted nearly 1,600 inspections in 58 member
states since April 1997, more than half have been conducted at military
facilities. About 36 percent of OPCW commercial inspections have taken
place at facilities producing the most dangerous chemicals identified by
the CWC. The OPCW recognizes that it must increase the number of
inspections conducted at facilities that produce dual-use chemicals. Some
of these facilities may pose a proliferation threat.

The lack of a credible Russian chemical weapons destruction plan has
hindered and may further delay destruction efforts, leaving Russia's vast
chemical weapons arsenal vulnerable to theft or diversion. As of September
2003, Russia had one operational destruction facility and had destroyed
1.1 percent of its 40,000 metric tons of chemical weapons. Russia's
destruction efforts rely heavily on international assistance. Since 1993
international donors, including the United States, have obligated about
$585 million for Russian destruction efforts while Russia has spent about
$95 million.

Status of CWC Implementation and Russian Destruction Efforts 1997-2003

Sources: GAO analysis of Department of Defense and OPCW data.
aIncludes only facilities that produce scheduled chemicals as defined by
the CWC.

Contents

  Letter

Results in Brief
Background
Member States Are Experiencing Delays in Complying with Key

CWC Requirements OPCW Conducts Inspections, but Significant Challenges
Remain Russia Faces Significant Challenges in Destroying Its Chemical

Weapons Observations Agency Comments and Our Evaluation

1 2 4

7 15

20 25 26

Appendixes

Appendix I:

Appendix II:

Appendix III:

Appendix IV:

Appendix V:

Appendix VI: Appendix VII:

Appendix VIII: Scope and Methodology

Location, Number, and Type of Inspections Conducted by the OPCW (April
1997 - December 2002)

International and Russian Funding for Chemical Weapons Destruction at
Shchuch'ye

Comments from the Department of State

GAO Comments

Comments from the Department of Defense

GAO Comments

Comments from the Department of Commerce

Comments from the Organization for the Prohibition of Chemical Weapons

GAO Comment

GAO Contact and Staff Acknowledgments

GAO Contact Acknowledgments

                                       29

                                       32

                                       34

                                     39 43

                                     46 50

                                       52

                                     53 54

55 55 55 Tables Table 1: CWC Possessor States' Declared Stockpiles and
Amount

Destroyed 7

Table 2: OPCW Inspection Activity at Military Facilities 16

Table 3: OPCW Inspection Activity at Commercial Facilities 17

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

of December 2003) 20

Contents

                                 Location of Russian Chemical Weapons         
Figures Figure 1: Figure 2:   Stockpiles Location of U.S. Chemical    9 12
                                          Weapons Stockpiles             
                     Figure 3: Chemical Weapons Destruction Facility at    35 
                                              Shchuch'ye                 
                     Figure 4:   Construction of the U.S. Destruction    
                                              Building at                
                                       Shchuch'ye, November 2003           36 
                     Figure 5:  Construction of the Russian Destruction  
                                              Building at                
                                       Shchuch'ye, November 2003           37 

Abbreviations

CW chemical weapons
CWC Chemical Weapons Convention
DOC discrete organic chemicals
DOD Department of Defense
OPCW Organization for the Prohibition of Chemical Weapons

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
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separately.

                                       A

United States General Accounting Office Washington, D.C. 20548

March 31, 2004

The Honorable Duncan Hunter Chairman Committee on Armed Services House of
Representatives

Dear Mr. Chairman:

The Chemical Weapons Convention (CWC) entered into force in April 1997. It
is the only multilateral treaty that seeks to eliminate an entire category
of weapons of mass destruction within an established time frame and verify
their destruction through inspections and monitoring. Specifically, the
convention bans the production, possession, and use of chemical weapons
and requires the destruction of chemical weapons stockpiles by 2007 with
possible extensions to 2012. The CWC also requires member states to adopt
national laws implementing the convention and to declare their military
chemical weapons facilities and commercial facilities producing dual-use
chemicals1 to the Organization for the Prohibition of Chemical Weapons
(OPCW). As of March 2004, 161 countries are CWC members, including the
Russian Federation and the United States. At the CWC's first review
conference in spring 2003, some member states expressed concern that many
member states are not meeting their key CWC obligations. For example,
Russiathe world's largest possessor of declared chemical
weaponsis experiencing delays in destroying its stockpile.

In response to your request, we reviewed (1) member states' efforts to
meet key CWC requirements, (2) OPCW's efforts to conduct inspections to
ensure compliance with the convention, and (3) Russia's efforts to destroy
its chemical weapons stockpile.

In conducting our work, we reviewed the CWC, analyzed verification and
program documents from the OPCW, and met with OPCW officials.
Additionally, we met with officials from the Departments of Commerce,
Defense, and State, as well as member states' representatives to the OPCW
at The Hague, the Netherlands. We also obtained information from Russian
government officials and visited the U.S.-funded chemical weapons
destruction facility site at Shchuch'ye in Russia. To assess the
reliability of

1The term "dual use" applies to chemicals that have both military and
commercial applications.

the data used in the report, we reviewed relevant documents and obtained
necessary information from agency and government officials. For the
purposes of our work, we determined that the data are sufficiently
reliable. We performed our work from April 2003 through March 2004 in
accordance with generally accepted government auditing standards. (See
app. I for the details of our scope and methodology.)

Results in Brief	Member states are experiencing delays in destroying their
chemical weapons stockpiles, adopting comprehensive national laws to
criminalize the possession and use of chemical weapons, and submitting
timely and accurate declarations of their CWC-related activities. While
the CWC has played an important role in reducing the risks from chemical
weapons, the CWC's nonproliferation goals have proven more difficult to
achieve than originally anticipated. Specifically, only 11 percent of the
70,000 metric tons of declared chemical weapons worldwide has been
destroyed, as of November 2003. While Russia and the United States possess
over 95 percent of the world's declared chemical weapons stockpile, they
are unlikely to meet the convention's extended deadline of 2012 for
destroying their respective stockpiles.2 In addition, less than 40 percent
of member states have adopted national laws to criminalize CWC-prohibited
activities. Finally, a 2001 Department of State report assesses that
China, Iran, Russia, and Sudan have not fully declared the extent of their
chemical weapons programs.

Although the OPCW has established a credible inspection regime and
conducted nearly 1,600 inspections in 58 member states between 1997 and
2003, the organization faces significant challenges in balancing an
increased demand for inspections at military and commercial sites with its
limited resources. The CWC does not specify the number of inspections that
the OPCW must conduct each year. Since 1997, the OPCW conducted over half
of its inspections at military facilities. The organization also conducted
inspections at 514 of the 5,460 declared commercial facilities. The OPCW
plans to increase the number of inspections conducted at commercial
facilities, that produce discrete organic chemicals, because they may pose
a greater proliferation risk than other commercial sites. However, it
simultaneously faces an increased demand for inspections at military
destruction facilities. Over the past few years, the OPCW has also

2The CWC permits member states to request extensions between 2007 and 2012
for the elimination of declared chemical weapons.

experienced financial difficulties. To help overcome the increasing
demands being placed on its limited resources, the OPCW is working with
member states to further improve the efficiency of its inspection
procedures.

Russia's efforts to destroy its chemical weapons stockpiles face
significant challenges. Russia is experiencing delays in destroying its
chemical weapons stockpile. As of September 2003, Russia had destroyed 1.1
percent of its total declared chemical weapons stockpile of 40,000 metric
tons. This compares with the 24 percent already destroyed by the United
States. In addition, current Russian destruction efforts are reliant upon
international assistance. As of December 2003, international donors,
including the United States, Germany, and others,3 had obligated about
$585 million and committed more than $1.7 billion toward Russia's chemical
weapons destruction. According to the Department of State, from 2001
through 2003 Russia budgeted about $420 million for chemical weapons
demilitarization-related activities. Russia had spent about $95 million.
Furthermore, the lack of a credible Russian chemical weapons destruction
plan has delayed destruction, and Russian planning efforts to date have
not included detailed cost and schedule information. Without a credible
plan, Russian destruction efforts may experience further delays, leaving
the Russian chemical weapons stockpile vulnerable to theft or diversion.

In commenting on our draft report, the Department of State (State)
asserted that our report was incomplete, not balanced, and did not provide
examples of the CWC's accomplishments. We have added additional
information to reflect State's concerns. However, our report acknowledges
the CWC's important contribution to addressing the threat posed by
chemical weapons and the OPCW's establishment of a credible inspection
regime. The Department of Defense (DOD) commented that the draft report
(1) had little analysis of the relative degree of proliferation risk from
those member states lacking implementing legislation and (2) did not
present a balanced view of CWC implementation. However, DOD offered no
criteria for determining which member states pose more of a proliferation
risk. DOD also provided examples of CWC accomplishments in its comments
that, while important, are secondary to the primary goal of

3Other donors include Canada, the Czech Republic, the European Union,
Italy, Norway, Switzerland, and the United Kingdom. The Nuclear Threat
Initiative is also providing assistance.

destroying the world's entire stockpile of chemical weapons. To ensure
balance, we have incorporated discussion of these issues in the report.
State and DOD said that our analysis estimating that Russia may not
destroy its chemical weapons stockpile until 2027 did not include
discussion of other options for destroying Russia's stockpile, such as
building additional destruction facilities. As of March 2004, only one
facility capable of destroying nerve agent is under construction in
Russia. The construction of this U.S-funded facility at Shchuch'ye began
11 years after the U.S. and Russia first agreed to build it. The
Department of Commerce (Commerce) commended our draft report for focusing
attention on CWC implementation. The OPCW also commended the report for
reflecting what has been achieved through CWC implementation and
recognizing areas where challenges still exist. We also received technical
comments from State, DOD, and Commerce as well as the OPCW and have
incorporated their comments where appropriate.

Background	The CWC is a multilateral arms control treaty that bans the
development, production, stockpiling, transfer, and use of chemical
weapons by member countries and requires the declaration and destruction
of those countries' existing chemical weapons stocks and production
facilities by 2007, with a possible extension to 2012. The CWC also
monitors the production and transfer of chemicals at declared commercial
facilities. When the CWC entered into force in April 1997, there were 87
member states. As of March 2004, 161 nations are CWC member states,
including Libya. Twenty-one countries are signatories but have yet to
ratify the treaty.4 According to the State Department, key nonsignatory
states include North Korea and Syria, which are believed to possess or are
actively pursuing chemical weapons capabilities.5

4Those states that have signed but not ratified the CWC are the Bahamas,
Bhutan, Cambodia, Central African Republic, Comoros, Congo, Democratic
Republic of the Congo, Djibouti, Dominican Republic, Grenada,
Guinea-Bissau, Haiti, Honduras, Israel, Liberia, Madagascar, Marshall
Islands, Myanmar, Rwanda, Saint Kitts and Nevis, and Sierra Leone.

5According to the statement by the U.S. Assistant Secretary of State for
Arms Control before the CWC Review Conference in April 2003, the United
States believed that Syria had a stockpile of nerve agent and was trying
to develop more toxic and persistent nerve agents. North Korea has also
acquired dual-use chemicals that could potentially be used to support its
long-standing chemical warfare program.

Upon ratification of the CWC, all member states are required to adopt
national laws that criminalize CWC-prohibited activities and establish a
national authority to serve as the national focal point for liaison with
the OPCW. All members are required to submit initial declarations to the
OPCW no later than 30 days after entering into the convention and annual
declarations detailing transfer activities of all declared chemicals no
later than 90 days after the end of the year. Member states must also
declare chemical weapons stockpiles and production facilities, relevant
chemical industry facilities, and other related information such as
chemical exports and imports. Member states that possess chemical weapons
stockpiles and production facilities must destroy them by April 2007. Six
member states- Albania, India, Libya, Russia, the United States, and A
State Party6have declared their chemical weapons stockpiles and
are considered possessor states. Eleven member states have declared
chemical weapons production facilities.

The OPCW consists of three organsthe Conference of States Parties,
the Executive Council, and the Technical Secretariatand was
established by the convention to implement its provisions. The Technical
Secretariat manages the organization's daily operations, including the
implementation of the convention's verification measures. The Technical
Secretariat serves as the repository for all member states' declarations
and relies upon individual member states to submit accurate, timely, and
complete declarations. Based on these declarations, the Technical
Secretariat inspects and/or monitors member states' military and
commercial chemical facilities and activities to ensure their compliance
with the CWC. Also, if a member state suspects another member state of
conducting activities prohibited by the convention, it may request a
challenge inspection of the suspected site(s). As of December 2003, no
member state has requested the OPCW to conduct a challenge inspection.

6The OPCW keeps the identity of this member state confidential.

Technical Secretariat inspectors take inventories of the declared
stockpiles to verify the accuracy of the declarations and ensure that
chemical weapons are not removed. Inspectors continuously monitor7 the
destruction of chemical weapons at operating destruction facilities by
observing the receipt of chemical weapons at sites and checking the type
and quantity of chemical weapons destroyed. Inspectors also verify the
destruction or conversion of declared chemical weapons production
facilities by observing the destruction of applicable buildings and
production equipment. So that dual-use chemicals are not diverted from
their peaceful uses, the Technical Secretariat inspects declared
commercial production facilities based on three schedules, or lists of
chemicals, contained in the CWC.8 Commercial facilities that produce
discrete organic chemicals, above 200 metric tons, are also subject to
inspections. OPCW inspectors verify that the types of chemicals being
produced are consistent with the member states' declarations.

Funding for OPCW inspections and other operations comes primarily from the
161 member states' required annual contributions, which are based on the
United Nations' scale of assessments. The other major source of funding
comes from reimbursements of inspections costs paid by chemical weapons
possessor states. The OPCW is partially reimbursed for inspection costs
incurred while conducting inspections at declared chemical weapons
facilities in those countries. The organization, however, must fund
inspections at commercial facilities and any challenge inspections it
conducts. The organization's budget for calendar year 2004 is $82.6
million.

7The CWC requires the verification of chemical weapons destruction through
continuous monitoring with on-site instruments and physical presence of
inspectors. As such, whenever destruction facilities are operational in
member states, OPCW inspectors are located at the facilities.

8Schedule 1 chemicals are either chemical weapons or are closely related
to chemical weapons. Schedule 2 chemicals can be used to make chemical
weapons but can also be used for peaceful industrial purposes. Schedule 3
chemicals are toxic chemicals that can be used to make chemical weapons
but are produced on a large scale to make common products such as oil,
paper, and cloth.

Member States Are Experiencing Delays in Complying with Key CWC
Requirements

Although the CWC has helped to reduce the risks from chemical weapons,
member states are experiencing delays in destroying their chemical weapons
and implementing key requirements of the treaty. For example, Russia and
the United States are unlikely to destroy their declared chemical weapons
by the extended deadline of 2012, and many member states have not adopted
national laws that fully implement the CWC. In addition, some member
states have yet to provide the OPCW with complete and timely declarations
detailing their CWC-related activities.

Complete Destruction of Largest Possessor States' Chemical Weapons
Stockpiles Will Extend beyond Deadline

We estimate that the United States and Russia are unlikely to meet the
2012 extended CWC deadline for destroying their chemical weapons. Three
other possessor states-Albania, India, and A State Party-possess smaller
stockpiles and are expected to destroy their stockpiles by the original
April 2007 deadline (see table 1). In addition, Libya became the sixth
possessor state in February 2004 when it became a member of the CWC and
declared that it possessed chemical weapons. According to OPCW officials
and CWC possessor states, the destruction of chemical weapons has proven
more complex, costly, and time consuming than originally anticipated.

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

Stockpile

                            Amount of stockpile destroyed, Projected date for
                                             declared September 2003 complete
                          Possessor state (metric tons) (percent) destruction

                Russian Federation     40,000         1.1               2027a 
                     United States     27,771         24                2014a 
                           Albania              b      0      
                             India              b     39      
                     A State Party              b     29                 2007 
                             Libya       23            0              unknown 

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

Note: The amount of stockpile declared applies only to the most dangerous
chemical weapons, known as category 1.

aProjected data are GAO analysis based on declared stockpiles and
destruction facilities currently in operation or under construction.

bThe amounts of the declared stockpiles are considered confidential by the
OPCW and For Official Use Only by the U.S. government.

Russia currently possesses the world's largest declared chemical weapons
stockpile at 40,000 metric tons stored at seven sites, as shown in figure
1. The stockpile includes 32,500 metric tons of nerve agent, the most
toxic of all known chemical agents, and 7,500 metric tons of blister
agent.9 As we have previously reported, DOD has installed security
upgrades at Shchuch'ye and Kizner, the two sites with portable nerve agent
munitions. However, a large quantity of Russia's chemical weapons will
remain vulnerable to theft or diversion until they are destroyed.10 As of
September 2003, Russia had destroyed 1.1 percent of its total CWC-declared
stockpile.

9Blister agents can be lethal if inhaled but generally cause slow-to-heal
burns on contact with skin. These agents are considered less of a threat
to U.S. national security interests.

10U.S. General Accounting Office, Weapons of Mass Destruction: Additional
Russian Cooperation Needed to Facilitate U.S. Efforts to Improve Security
at Russia Sites, GAO03-482 (Washington, D.C.: March 24, 2003).

Russia did not meet the original treaty deadline to destroy 1 percent of
its stockpile by April 2000. In accordance with treaty provisions, Russia
requested and received an extension of its 1-percent and 20-percent
deadlines from the OPCW.11 In April 2003, Russia met the one percent
destruction deadline. Based on information provided by DOD, we estimate
that Russia may not destroy its declared chemical weapons stockpile until
2027. Our analysis is predicated on Russia's complete destruction of its
approximately 7,500 metric tons of blister agent by the 2007 deadline and
destroying the remaining 32,500 metric tons of nerve agent at the U.S.
funded destruction facility at Shchuch'ye. In September 2003, Russia
agreed to complete the elimination of all of its nerve agent at the
Shchuch'ye destruction facility, which is scheduled to begin operations in
2008. According to DOD, the Shchuch'ye facility may not be operational
until 2009. For Russia to meet an extended April 2012 deadline, Russia
would have to destroy about 9,100 metric tons of nerve agent per year.
Operating at maximum capacity, the facility is estimated to destroy about
1,700 metric tons of nerve agent per year.12 At that rate, unless the
capacity for destruction is increased or additional destruction facilities
are built, the complete destruction of Russia's stockpile may not occur
until 2027.13 (We discuss other options for destroying Russia's nerve
agent stockpile later in this report.)

11The OPCW extended Russia's 1-percent deadline from April 2000 to May 31,
2003 and its 20-percent deadline from April 2002 to April 2007. Russia
also submitted requests to extend its 45-percent and 100-percent
deadlines. As of October 2003, specific dates for these deadlines had not
been agreed upon.

12According to DOD, the destruction rate for the Shchuch'ye facility
applies to the munitions stored at Shchuch'ye and Kizner and may not apply
to the bulk agent stored at Maradykovsky, Leonidovka, and Pochep. Our
analysis is based on the capacity of the destruction facilities that are
currently operational or under construction.

13Based on our discussion with Russian government officials, Russia may
construct three additional chemical weapons destruction facilities.

The United States possesses the second largest declared chemical weapons
stockpile with 27,771 metric tons, which is stored at eight sites, as
shown in figure 2. Currently, the United States is operating three
destruction facilities; three additional facilities will be operational in
the near future and two more will begin construction. As of December 2003,
the United States destroyed 24 percent of its declared stockpile and met
the 1-percent and 20-percent interim deadlines within the treaty time
frames. However, the United States requested and received an extension of
the 45-percent deadline from April 2004 to December 2007. The United
States will not meet the 100-percent April 2007 destruction deadline and
may not meet the 2012 deadline, if extended,14 based on the current
schedule. According to DOD, one U.S. chemical weapons destruction facility
is not scheduled to complete its destruction operation until 2014.
Persistent delays have occurred due to plant safety issues, environmental
requirements, and funding shortfalls. We have previously reported on the
significant management challenges in the U.S. chemical demilitarization
program, as well as concerns over cost growth and schedule delays. As
noted in our prior work, the U.S. chemical weapons demilitarization
program spent $11.4 billion by the end of fiscal year 2003, which accounts
for nearly half of the program's life-cycle cost estimate of $24
billion.15

14According to DOD, the United States has received "in principle" an
extension of its 100percent deadline to April 2012 and will request a
formal extension of its 100-percent deadline by April 2006.

15U.S. General Accounting Office, Chemical Weapons: Sustained Leadership,
Along with Key Strategic Management Tools, Is Needed to Guide DOD's
Destruction Program, GAO03-1031 (Washington, D.C.: September 2003).

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

Chemical weapons storage facility Destruction facility Sources: DOD
(data); Nova Development and Map Resources (images).

Note: As of November 2003, all chemical weapons at Johnston Atoll have
been destroyed and the destruction facility has been dismantled.

Three other possessor statesAlbania, India, and A State
Partyaccount for about 3 percent of the global declared chemical
weapons stockpile and are anticipated to meet the CWC complete destruction
time line by April 2007. With smaller stockpiles than those in Russia and
the United States, these countries have had less difficulty meeting their
deadlines. Albania declared its stockpile to the OPCW in 2003, and the
United States is providing assistance to destroy its chemical weapons
stockpile. Other nations, including Canada and Italy, may also provide
assistance. State officials estimate that Albania will meet the 2007
destruction deadline. According to Indian officials, India has the third
largest stockpile after Russia and the United States; however, information
on its chemical weapons destruction program is not publicly available. The
fifth possessor state, A State Party, experienced interim delays due to
technical difficulties. It requested and received an extension of its
45-percent chemical weapons destruction deadline in 2003. According to
government officials, it remains on track to meet the 2007 deadline.
Libya, the sixth possessor state, has just declared its chemical weapons
to the OPCW and has yet to develop a destruction plan for its stockpile.

Many Member States Have Yet to Adopt National Laws Implementing the CWC

According to the OPCW, less than 40 percent of CWC member states have
adopted national laws to criminalize CWC-prohibited activities. Although
the treaty does not establish a time line for the adoption of such
measures, according to the OPCW, member states are expected to implement
these laws soon after ratifying the convention. OPCW officials stated that
many member states lack sufficient legal expertise and financial resources
to adopt the required laws. At the 2003 CWC Review Conference, however,
the United States launched an initiative to assist all CWC member states
in adopting comprehensive national laws. The effort culminated in an OPCW
action plan to help member states adopt necessary laws by 2005.

According to the OPCW, 126 member states have designated a national
authority to collect and submit their declarations. However, OPCW and
State officials estimate that a large number of member states' national
authorities are not effective because they lack sufficient financial and
human resources. National authorities are important in implementing the
treaty because they facilitate member states' ability to submit accurate
and timely declarations to the OPCW and host OPCW inspections. To
encourage member states to improve the effectiveness of their national
authorities, the OPCW hosts workshops to identify common problems and
assist member states in addressing them accordingly.

Some Member States Have Submitted Incomplete or Late Declarations

According to a 2001 Department of State report, four CWC member
statesChina, Iran, Sudan, and Russiahad not acknowledged
the full extent of their chemical weapons program.16 The CWC requires
member states to fully and accurately declare their chemical weapons
capabilities. However, State believes that China maintains an active
chemical weapons research and development program, a possible undeclared
chemical weapons stockpile, and weapons-related facilities that were not
declared to the OPCW.17 Iran has not submitted a complete and accurate
declaration and is seeking to retain and modernize key elements of its
chemical weapons program, according to the report. Sudan established a
research and development program with a goal to produce chemical weapons
indigenously. The report also assesses that Russia has not divulged the
full extent of its chemical agent and weapons inventory. State views
Russia's declaration of its chemical weapons production, development
facilities, and chemical agent and weapons stockpiles as incomplete. In
addition, State reported that Russia may have knowledge of a new
generation of agents that could circumvent the CWC and possibly defeat
western detection and protection measures. The significance of this issue
was addressed at the 2003 CWC Review Conference. The Director-General of
the OPCW urged member states to provide accurate and complete declarations
to increase transparency and confidence in the treaty.

Furthermore, member states have been late in submitting their required
initial and annual declarations to the OPCW. As of December 2002, nearly
97 percent of all member states submitted their initial declarations, but
a large percentage of member states did not submit their initial
declarations within the required 30-day time frame. The OPCW also engaged
in bilateral consultations to assist member states in submitting their
initial declarations. As of October 2003, nearly one-third of member
states had failed to submit their annual declarations in a timely manner.
According to the OPCW, delays in submitting the required declarations make
it difficult for the organization to plan its annual inspections and track
chemical transfers.

16The U.S. government also has concerns about other member states' CWC
compliance; however, the identities of these countries remain classified.

17See U.S. Department of State, Adherence to and Compliance with Arms
Control and Nonproliferation Agreements and Commitments, Washington, D.C.,
2001.

OPCW Conducts Inspections, but Significant Challenges Remain

The OPCW has established a credible inspections regime. Between 1997 and
2003, the OPCW conducted nearly 1,600 inspections in 58 member states.
However, the organization faces significant challenges as it prepares to
balance an increased number of inspections at both military and commercial
facilities with its limited resources. The CWC does not specify the number
of annual inspections that the OPCW is required to conduct. Since April
1997, more than half of OPCW inspections have taken place at military
facilities even though some commercial facilities may pose a greater
proliferation threat. To meet the increased demands on its limited
resources, the OPCW is working with member states to further improve the
efficiency of its inspection activities.

OPCW Implementing CWC Inspection Regime

From April 1997 through December 2003, the OPCW's Technical Secretariat
has conducted nearly 1,600 inspections at both military and commercial
chemical facilities in 58 member states. (See app. II for a chart
depicting the locations of inspections conducted.18) According to OPCW
officials and member states' representatives we interviewed, inspections
are proceeding as planned under the CWC. Within the United States,
officials from the State, DOD, and Commerce, as well as chemical industry
representatives, stated that the United States and OPCW inspectors work
cooperatively to implement the inspection regime. When questions or
concerns arise, the Technical Secretariat and the affected member state(s)
work to resolve them. For example, the United States and the OPCW have
resolved issues such as clarifying which portions of declared commercial
facilities are subject to inspection. According to DOD, OPCW inspectors
have good access to declared sites and facilities.

As of December 2003, the Technical Secretariat conducted 965 inspections
at 167 of 190 declared military sites. The military sites that have not
been inspected are either chemical weapons production facilities destroyed
prior to CWC entry into force or sites having old or abandoned chemical
weapons. Although the CWC requires that OPCW maintain a continuous
presence at member states' sites when chemical weapons are being
destroyed, it does not specify how many inspections are to be conducted
annually. The Technical Secretariat determines how many inspections to

18The data contained in appendix II reflect inspections conducted as of
December 2002 because the OPCW could not provide more current data until
it has been approved by the CWC member states.

conduct annually based on the number of military facilities declared by
member states, member states' annual destruction plans, annual
declarations, and the annual OPCW budget documents. The greatest number of
inspections has taken place at chemical weapons destruction
facilitiesprimarily in the United States, Russia, and India. About
one-third of all inspections conducted by the Technical Secretariat have
taken place in the United States, mostly at chemical weapons destruction
facilities. Table 2 shows the number of inspections conducted at different
types of facilities at military sites from April 1997 through December
2003.

            Table 2: OPCW Inspection Activity at Military Facilities

CWC military facility inspection requirements

Declared sites or facilities, as of 2003

Inspections, as of December 2003

Sites inspected, 1997-2003

                    CW production                               
                       facilities       61            298       
                   CW destruction                               
                       facilities       39            376       
                       CW storage                               
                       facilities       33            219       
                    Abandoned CWa       15             22       
                          Old CWb       42             50       
                            Total      190            965                 167 

Source: OPCW data.

a"Abandoned chemical weapons" refers to those left by one country (after
January 1, 1925) on the territory of another country without the consent
of the latter.

b"Old chemical weapons" refers to those produced before 1925 or those
produced between 1925 and 1946 that have deteriorated to such an extent
that they cannot be used as weapons.

Between April 1997 and December 2003, Technical Secretariat officials
conducted 634 inspections at 514 sites among the 5,460 commercial
facilities declared by member states (see table 3). Because the CWC does
not specify the specific number of inspections to be conducted each year,
the Technical Secretariat selects the facilities it will inspect based on
those requiring initial inspections and the potential proliferation risk
of facilities. The annual budget document specifies the number of
inspections to be conducted. Since April 1997, most OPCW commercial
inspections have taken place at facilities that produce chemicals listed
on the CWC's three schedules. Of the declared 4,492 facilities that
produce discrete organic chemicals (DOC), the organization has inspected
163. DOC facilities produce a wide range of common commercial chemicals
and may also be

capable of producing chemical weapons. According to U.S. government and
OPCW officials, such dual-use DOC facilities may pose a proliferation
threat because they may conceal CWC-prohibited activities. Most
significantly, these DOC facilities may be modified to produce scheduled
and other chemicals that are not specifically listed on current CWC
schedules but are still banned by the CWC, if intended for prohibited
purposes. In commenting on a draft of our report, the OPCW provided
clarification of this proliferation issue. While the majority of
commercial facilities produce discrete organic chemicals, the OPCW
estimates that less than 20 percent of these DOC sites may pose highly
relevant proliferation risks.

Table 3: OPCW Inspection Activity at Commercial Facilities

CWC required
inspections at Declared sites or Number of sites
commercial facilities as of Inspections as of inspected, April 1997
facilities December 2003 December 2003 December 2003

                         Schedule 1                       
                         chemicalsa                    27                 123 
                         Schedule 2                       
                         chemicalsb          432                          233 
                         Schedule 3                       
                         chemicalsc          509                          115 
                               DOCd         4,492                         163 
                              Total         5,460                         634 

Source: OPCW data.

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

bSchedule 2 chemicals can be used to make chemical weapons but can also be
used for peaceful industrial purposes. These chemicals are not produced in
large quantities.

cSchedule 3 chemicals are toxic chemicals that can be used to make
chemical weapons but are also produced on a large scale to make products
such as oil, cement, cloth, and paper.

dDOCs cover a wide range of chemicals that are not listed in the Schedules
but could be used to produce chemical weapons.

OPCW Faces Significant Although the OPCW has made progress in conducting
inspections as Challenges in Conducting mandated by the convention, it
faces challenges in meeting an increase in More Inspections 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.19 OPCW inspection costs will
increase, if the organization maintains a continuous on-site presence at
the additional chemical weapons destruction sites that will begin
operations in the near future. However, the Technical Secretariat and
member states are currently discussing possible monitoring alternatives
that may reduce costs without compromising the credibility of the
inspections.

According to the OPCW, the organization is working to increase the number
of inspections it conducts at commercial DOC facilities to address the
proliferation risks they pose. In 2002, for example, 32 of 85 commercial
inspections conducted were at DOC facilities. In 2004, the OPCW plans to
increase the number of DOC facility inspections to 70 out of a total of
150 inspections planned at commercial facilities. Furthermore, OPCW and
member states20 are working to refine the current criteria used to select
DOC facilities for inspections to ensure that the selection process takes
into account all factors mandated by the CWC.

19The OPCW is reimbursed for all the operational expenses and roughly
one-third of the inspector salary costs for chemical weapons inspections
at military facilities in chemical weapons possessor states.

20A U.S.-Swiss proposal to clarify guidance on how the Technical
Secretariat should implement paragraphs 11(b) and 11(c) of the CWC's
verification annex is currently being discussed.

Due to budget deficits in 2001 and 2002, the Technical Secretariat had to
reduce the number of inspections it planned to conduct at commercial
chemical facilities. Such deficits were mostly the result of member
states' late payment of their annual assessments and reimbursements for
military inspections.21 When funding was limited, the OPCW could not
reduce the number of inspections at destruction facilities because
inspectors are required to continuously monitor these sites when
operational. Instead, it reduced the number of commercial inspections it
conducted. In 2001, the OPCW conducted 57 percent (75 of 132) of its
planned inspections at commercial sites. For 2002, it conducted 64 percent
(85 of 132) of its planned inspections. Although previous financial
difficulties caused a reduction in the number of inspections, the
Technical Secretariat completed its planned number of 132 commercial
inspections for 2003. Member states approved a more than 6-percent
increase in the OPCW's budget for 2004. According to OPCW officials, such
budget increases are unlikely to continue in future years, and the problem
of late receipt of member states' annual assessments and reimbursements
will likely reoccur.

To meet the increased demand for inspections, the Technical Secretariat is
working to improve the efficiency of its inspection activities. The
organization has reduced the size of inspection teams at military sites,
thereby lowering daily allowance and travel costs. For example, the team
size for most inspections conducted at chemical weapons storage facilities
was reduced from eight in 2002 to six in 2003. The Technical Secretariat
has also devised new contracts for inspectors of chemical weapons
destruction facilities that permit hiring part-time inspectors for 1 year.
When implemented, such contracts could reduce staff costs and provide for
more flexibility in assigning inspection teams. The OPCW and member states
are also exploring greater use of monitoring and recording instruments at
chemical weapons destruction facilities to reduce the number of inspectors
needed on-site. Cost-saving measures have also been proposed and
implemented to increase the efficiency of inspections conducted at
commercial facilities, including reducing the size of inspection teams and
the time they spend on-site.

21U.S. General Accounting Office, Chemical Weapons: Organization for the
Prohibition of Chemical Weapons Needs Comprehensive Plan to Correct
Budgeting Weaknesses, GAO-035 (Washington, D.C.: Oct. 24, 2002).

Russia Faces Significant Challenges in Destroying Its Chemical Weapons

Russia is experiencing delays in destroying its chemical weapons. As of
September 2003, Russia had destroyed 1.1 percent of its 40,000 metric tons
of chemical weapons at its only operational destruction facility. Russian
destruction efforts have also relied almost entirely on international
assistance. As of December 2003, international donors have shipped about
$585 million and committed more than $1.7 billion to Russian destruction
efforts. According to State, from 2001 through 2003 Russia budgeted about
$420 million for chemical weapons demilitarization-related activities.
Russia spent about $95 million. However, based on its current destruction
efforts and the international assistance committed, Russia will not meet
the extended CWC destruction deadline of 2012. Furthermore, Russia has yet
to develop a comprehensive destruction plan that includes the types of
projects and funding needed to completely destroy its declared stockpile,
which may further delay destruction efforts.

One -Percent Milestone Russia plans to destroy its chemical weapons
stockpiles at Gorny, Achieved at Gorny; Two Kambarka, and Shchuch'ye,
primarily using assistance provided by Additional Facilities under 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

Construction	at Maradykovsky, Leonidovka, and Pochep. Table 4 provides the
time line for Russia's destruction efforts at facilities in operation or
under construction.

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

                                                                    Amount of 
     Estimated date for                                              chemical 
                                                                      weapons 
       Location of      Estimated start Estimated end  Type of          to be 
        completing      of              of             agent to     destroyed 
       destruction                                                    (metric 
        facilities        destruction    destruction   be destroyed     tons) 
destruction facility                                             
    Gorny August 2002    December 2002  December 2005    Blister        1,120 
    Kambarka December    December 2005  December 2009    Blister        6,360 
           2005                                                     
Shchuch'ye September                   After 2012      Nervea              
           2008         September 2008                                 11,080

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

aRussia plans to destroy all nerve agent located at Shchuch'ye and Kizner
at the Shchuch'ye facility.

Gorny and Kambarka to Destroy All Blister Agent

Shchuch'ye Will Destroy 30 Percent of Russia's Chemical Weapons Stockpile

Russia is relying on German assistance to destroy its stockpile of blister
agent at the Gorny and Kambarka facilities. According to DOD, Germany
focused its assistance in this area because it had experience destroying
World War II blister agents. As of September 2003, Russia destroyed 455
metric tons of blister agent (1.1 percent of the Russian stockpile) stored
at the Gorny facility. Russia will destroy the remaining stockpile at
Gorny by December 2005, according to a German official. Russia constructed
the building for the destruction facility, while Germany spent about $58
million from 1993 to 2003 to equip the facility.22 Germany has committed
$120 million for the Kambarka destruction facility, currently under
construction, and up to $300 million in additional funds, according to a
German government official. The facility at Kambarka will destroy the
entire stockpile of blister agent located there by December 2009. The
construction schedule of this facility may be delayed, according to a
German government official overseeing the assistance.

Once operational, the Shchuch'ye chemical weapons destruction facility
will begin to destroy nerve agent from two Russian storage sites that
house nearly 30 percent of the total Russian stockpile.23 The storage
facilities at Kizner and Shchuch'ye each house about 5,500 metric tons of
nerve agent stored in projectiles and rockets. According to DOD and State
officials, the United States has focused its assistance to Russia at
Shchuch'ye because these chemical weapons are portable and thus vulnerable
to theft and diversion.

The United States has agreed to pay for the destruction facility at
Shchuch'ye.24 The facility is scheduled to destroy the nerve agent
stockpiles located at both the Shchuch'ye and Kizner storage sites. DOD's
Cooperative Threat Reduction program has obligated more than $460 million
on planning, design, and construction of the facility. In October 2003,
DOD updated the costs and schedule for completing the Shchuch'ye facility
and projected that the cost would increase from about $888 million

22From 2000 to 2003, the European Union also provided $6 million for the
Gorny facility. Both the German and European Union figures are expressed
in constant 2003 dollars.

23The Shchuch'ye storage site is located about 10 miles from the
destruction facility. The chemical weapons stored at Kizner are located
more than 450 miles from the Shchuch'ye destruction facility. Nerve agent
from each location will be sent to Shchuch'ye by rail.

24The United States plans to finance the construction of all buildings
within the facility, except for one destruction building, which the
Russians will fund.

to more than $1 billion. DOD also noted that the operation of the facility
may be delayed from September 2008 to July 2009. DOD attributes the
increased cost to changed site conditions, new requirements, risk factors,
and delays due to lack of U.S. funding for 2 years caused by Russia's
inability to meet U.S. congressional conditions. Once operational, the
facility is estimated to destroy 1,700 metric tons of chemical weapons per
year. With a July 2009 operational date, we estimate that the destruction
of chemical weapons stored at Shchuch'ye and Kizner will not be completed
until at least 2016. (For more detailed information on international
assistance for chemical weapons destruction at Shchuch'ye, see app. III.)

Russian Plans for Destroying Remainder of Its Nerve Agent Stockpile Are
Unknown

In November 2003, the Director of the Russian Munitions Agency informed us
that Russia has not yet decided how it will destroy the remaining nerve
agent stored at Maradykovsky, Leonidovka, and Pochep. This nerve agent
represents over 50 percent of the total Russian chemical weapons
stockpile. In September 2003, the United States and Russia amended a March
2003 agreement under which the Russian Munitions Agency agreed to complete
the elimination of all nerve agent at the Shchuch'ye destruction facility,
unless otherwise agreed in writing. According to DOD and Russian
government officials, there is uncertainty whether Russia will comply.
Russian officials have concerns about the costs and risks of transporting
the weapons from these sites to Shchuch'ye, most of which are located more
than 500 miles away. As a result, Russian officials have indicated that
Russia may construct three chemical weapons neutralization facilities for
the nerve agent stored at Maradykovsky, Leonidovka, and Pochep. Under this
option, Russia would neutralize the chemical weapons at the three sites so
the agent would be safe for transport, and then complete the destruction
process at Shchuch'ye. This would require the construction of three
neutralization facilities plus new destruction capacity at Shchuch'ye,
because the neutralized agent would likely be destroyed using a different
process than the unneutralized agent from the Shchuch'ye and Kizner sites.
In November 2003, however, Italy agreed to commit funding for the
construction of a destruction facility at Pochep.25

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

International Donors Assist Russian Chemical Weapons Destruction

While Germany and the United States have obligated about $515 million and
committed an additional $1 billion for Gorny, Kambarka, and Shchuch'ye,
other donors have spent about $70 million at these sites.26 Furthermore,
in June 2002, the Group of Eight launched the Global Partnership
initiative, which was designed to prevent the proliferation of weapons of
mass destruction to terrorists and their supporters. Among other projects
in Russia, the initiative is currently assisting with chemical weapons
destruction.27 As of December 2003, international donors, including the
United States, Germany, Canada, Italy, and the United Kingdom, 28 have
committed more than $1.7 billion for Russian chemical weapons destruction.

Lack of Plan May Hinder Russia's Progress in Destroying Chemical Weapons

Congress has conditioned U.S. funding for the Shchuch'ye facility on a
Secretary of Defense certification that Russia has developed a practical
chemical weapons destruction plan.29 In September 2003, Russia signed an
agreement with the United States to provide a chemical weapons destruction
plan by March 2004. The plan would include the types of projects and
funding needed to completely destroy its declared chemical weapons.
Officials from State and DOD were not optimistic that the Russians will
deliver a plan within the required time.

According to State and DOD officials, Russia's planning efforts to date
have been based on inaccurate assumptions and have lacked detailed
information on how the destruction of chemical weapons will occur at each
site. For example, Russian officials have stated that they expect the
Shchuch'ye chemical weapons destruction facility to be operational in
2006, despite DOD estimates that it may take until July 2009. DOD
officials stated that additional time is needed to procure and install the
equipment needed for the destruction facility.

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

27Other priority concerns of the Global Partnership initiative include
plutonium disposition, nuclear submarine dismantlement, and employment of
former weapons scientists in Russia.

28In addition, the Czech Republic, the European Union, Norway,
Switzerland, and the Nuclear Threat Initiative are also providing
assistance.

29In accordance with Public Law 108-136, Sec. 1306, the President
exercised his authority to waive congressional stipulations and continue
funding of the Shchuch'ye facility.

In addition, Russia's plans need greater specificity. Russia has provided
some information to the United States regarding the following:

o  where the chemical weapons will be destroyed,

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

o  costs for each facility, and

o  how each facility will contribute to the destruction efforts.

According to officials from State and DOD, the information provided does
not appear credible and lacks key elements. Russia has not provided the
method, schedule, and cost for transporting its chemical weapons to the
destruction facility at Shchuch'ye. In addition, Russia has no credible
plan to destroy the nerve agent at Maradykovsky, Leonidovka, and Pochep.
Russian officials indicated that the nerve agent may be neutralized at
each site but did not provide any details regarding what would be needed
to undertake such an effort, including a plan to dispose of the toxic
chemicals resulting from the neutralization process.

Russia's chemical weapons destruction efforts at Pochep, Leonidovka, and
Maradovski may be further complicated by Russia's definition of
destruction, which differs from that of the United States and the OPCW.
The CWC defines destruction of chemical weapons as an essentially
irreversible process.30 The United States and the OPCW maintain that
chemical weapons are not destroyed until the materials resulting from the
destruction process are essentially irreversible (i.e., can no longer be
reversed back to chemical weapons) and the remaining materials can be
inspected by the OPCW. The United States neutralizes some of its chemical
weapons in a two-phase process that first neutralizes the agent and then
transports the resulting hazardous waste to a commercial chemical facility
for final disposition. The OPCW inspects both phases of the neutralization
process. Russian officials maintain that chemical weapons should be
considered destroyed after the initial neutralization phase and not
require further processing or OPCW inspections. Russian officials argue
that,

30Under the CWC, the destruction of chemical weapons is defined as "a
process by which chemicals are converted in an essentially irreversible
way to a form unsuitable for production of chemical weapons, and which in
an irreversible manner renders munitions and other devices unusable."

although toxic chemicals resulting from the neutralization process could
be reverted to chemical weapons, the cost to do so would be prohibitive.
Russia raised this issue at the May 2003 CWC Review Conference, but OPCW
member states maintained that complete destruction should be an
essentially irreversible process as specified in the CWC. Despite this
opposition, Russian government officials at the Russian Munitions Agency
and the Ministry of Foreign Affairs stated in November 2003 that they
consider initial neutralization equivalent to destruction.

Observations	The CWC has played an important role in reducing the risks
from chemical weapons. Member states have destroyed more than 7,700 metric
tons of chemical weapons and the OPCW has established a credible
inspection regime that has inspected many military and commercial chemical
facilities in 58 countries. Nearly 7 years after entry into force, the
CWC's nonproliferation goals have proven more difficult to achieve than
originally anticipated. CWC member states and the OPCW face difficult
choices in addressing the delays in Russia's destruction program, the
limited number of inspections at dual-use commercial sites, and the slow
progress in passing laws criminalizing CWC-prohibited activities.
Decision-makers will have to make some combination of policy changes in
these areas if the CWC is to continue to credibly address nonproliferation
concerns worldwide.

First, the destruction of chemical weapons will likely take longer and
cost more than originally anticipated. Even with significant international
assistance, Russia may not destroy its declared chemical weapons until 15
years beyond the extended CWC deadline. Russia's large stockpile will thus
remain vulnerable to theft and diversion. Several options exist, however,
for the United States and other donors to reduce the proliferation risks
from Russia's chemical weapons stockpile. Such options may include (1)
increasing funding for security improvements at Russia's chemical weapons
storage sites, (2) deferring financing for Russia's chemical weapons
destruction effort until the Russian government develops a credible
destruction plan, or (3) financing the construction of additional
destruction facilities.

Second, technical advancements in the chemical industry and the increasing
number of dual-use commercial facilities worldwide challenge the CWC and
the OPCW's ability to deter and detect proliferation. Member states will
need to determine the best policies for addressing potential proliferation
at dual-use commercial facilities. CWC member states could

decide that the OPCW should conduct more commercial inspections, which
would require member states to provide more funding and subject their
national chemical industries to additional inspections. Alternatively,
member states may determine that the current level of commercial
inspections is sufficient to detect and deter activities prohibited by the
CWC.

Third, many member states have not yet adopted national laws to fully
implement the convention, or have not submitted complete and accurate
declarations of their CWC-related activities. These problems undermine
confidence in overall treaty compliance. It is important for the OPCW and
member states to reinforce member states' obligations to adopt national
laws, enforce them accordingly, and submit accurate and timely
declarations. Challenge inspections may also be a vehicle to ensure member
states' compliance with the CWC.

Agency Comments and Our Evaluation

We obtained written comments on a draft of this report from State, DOD,
Commerce, and the OPCW, which are reprinted in appendixes IV, V, VI, and
VII respectively. We also received technical comments from the departments
as well as the OPCW, which we have incorporated where appropriate. In
commenting on our draft report, State asserted that our report was
misleading, incomplete, and not balanced. State did not provide specific
examples but instead claimed that the report omitted positive CWC
accomplishments such as growth in the number of member states, correction
of OPCW management inefficiencies, and OPCW execution of the CWC
inspection regime. In response, we agree that the CWC has played an
important role in reducing the threat posed by chemical weapons and the
report acknowledges this accomplishment. With regard to State's comment
about the growth in the number of CWC member states, the report focuses on
CWC implementation among already existing member states. For clarification
however, we have provided additional information on the increase in CWC
membership since entry into force. Secondly, State commented that the
report did not assess OPCW management corrections. In this report we
reviewed OPCW's efforts to conduct inspections, not the management of the
organization. We had previously reported on this topic in October 2002.31
Thirdly, the report

31U.S. General Accounting Office, Chemical Weapons: Organization for the
Prohibition of Chemical Weapons Needs Comprehensive Plan to Correct
Budgeting Weaknesses,

GAO-03-5 (Washington, D.C.: Oct. 24, 2002).

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.

Sincerely yours,

Joseph A. Christoff, Director International Affairs and Trade

Appendix I

Scope and Methodology

To determine what efforts member states have made in meeting key Chemical
Weapons Convention (CWC) requirements, we compared these requirements with
documents obtained from the Organization for the Prohibition of Chemical
Weapons (OPCW) and the Department of State (State), including annual
reports that assess member states' compliance with the treaty, surveys
assessing the status of member states' compliance with key requirements,
and member states' official statements to the 2003 CWC Review Conference.
We also obtained information from OPCW officials including the
Director-General, the Deputy Director-General, the Administration
Division, the Verification and Inspectorate Division, and the Office of
Internal Oversight, as well as member states' representatives to the OPCW
in The Hague.1 To assess the reliability of the OPCW data regarding
whether the member states are meeting their CWC requirements, which
include the destruction of chemical weapons, we reviewed numerous OPCW and
U.S. government documents, interviewed OPCW and U.S. officials, and
examined OPCW's procedures for ensuring data reliability. We determined
that the OPCW data was sufficiently reliable for the purposes of this
engagement. In addition, we met with officials from State's Bureau of Arms
Control, the Bureau of Nonproliferation, the Bureau of Verification and
Compliance, and the Bureau of Intelligence and Research in Washington,
D.C., and with representatives of the intelligence community. We also met
with officials at the U.S. Mission to the OPCW at The Hague. To obtain
information on how the CWC is implemented in the United States we attended
the June 2003 Defense Threat Reduction Agency's CWC Orientation Course
held in Fairfax, Virginia.

To assess the OPCW's efforts in conducting inspections to ensure
compliance with the convention, we analyzed the CWC and various OPCW
documents including Verification and Implementation Reports, annual
budgets, and other reports. In The Hague, we met with Director-General,
the Deputy Director-General, of the OPCW, and with officials from the
Administration Division and the Verification and Inspectorate Division. We
also visited the inspection laboratory and equipment store at Rijswijk,
The Netherlands. To assess the reliability of the OPCW data regarding the
number of inspections being conducted in the CWC member states, we
reviewed numerous OPCW and U.S. government documents, interviewed OPCW and
US officials, and examined OPCW's procedures for ensuring

1During our visit to the OPCW in September 2003, we met with
representatives from "A State Party," Albania, China, the Czech Republic,
Finland, France, Germany, India, Italy, Japan, Malaysia, Norway, the
Russian Federation, and the United Kingdom.

Appendix I Scope and Methodology

data reliability. We determined that the OPCW data was sufficiently
reliable for the purposes of this engagement. To assess member states'
experiences with OPCW inspections, we spoke with numerous member states'
representatives to the OPCW. We also met with officials at the U.S.
Mission to the OPCW at The Hague. In addition, we met with officials from
State's Bureau of Arms Control, the Bureau of Nonproliferation, and the
Bureau of Verification and Compliance. To obtain an understanding of how
OPCW inspections are conducted at military chemical weapons-related
facilities in the United States, we met with Department of Defense (DOD)
officials from the Defense Threat Reduction Agency. We also toured the
U.S. chemical weapons destruction facility in Aberdeen, Maryland. To
obtain an understanding of how OPCW inspections are conducted at
commercial chemical facilities in the United States, we met with
Department of Commerce officials from the Bureau of Industry and Security,
Office of Nonproliferation Controls and Treaty Compliance, as well as
representatives from the American Chemistry Council.

In reviewing Russia's efforts to destroy its chemical weapons stockpile,
we visited the Russian Federation and obtained information from Russian
government officials at the Chamber of Accounts, the Russian Munitions
Agency, and the Ministry of Foreign Affairs. We also met with
representatives from the Russian Duma who have funding authority over
Russian chemical weapons destruction. In addition, we traveled to
Shchuch'ye to observe the U.S.-funded chemical weapons destruction
facility and surrounding infrastructure projects. While in Shchuch'ye, we
spoke with local government officials and the Cooperative Threat Reduction
program funded contractor responsible for building the Shchuch'ye
facility. We obtained information from officials in the Bureau of
Nonproliferation and the Bureau of Arms Control in the Department of
State. At DOD, we met with officials and acquired documents from the
Office of the Secretary of Defense for Cooperative Threat Reduction Policy
and the Defense Threat Reduction Agency, which set policy and manage the
implementation of CTR assistance to the Shchuch'ye facility. We also
obtained information on international donors commitments for Russian
chemical weapons destruction efforts from DOD and government
representatives from Canada, Germany, and the United Kingdom. We obtained
data from a variety of sources on the funding and assistance provided for
Russian chemical weapon destruction efforts. To assess the reliability of
these data, we interviewed officials from the United States, Canada,
France, Germany, Great Britain, Italy, Russia, and the OPCW. We also asked
these officials to corroborate other nations' data wherever possible. In
addition, we cross-checked the data on funding to Russia that

Appendix I Scope and Methodology

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.

Appendix II

Location, Number, and Type of Inspections Conducted by the OPCW (April
1997 -December 2002)

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

A State Partya

Algeria 3

Argentina 4

                      Page 32 GAO-04-361 Nonproliferation
Australia      3 1 4 1  Austria        1 1  Belarus        1 2  Belgium     2 3 1 3 2  Bosnia           Herzegovina 2          Brazil       2 3 1  Bulgaria       1 1 2  Canada     2 5   5  Chile        1 2  China 2   16  10 21 9 1  Costa         1  Croatia         4   Czech          2 5  Denmark       1   1 Estonia         2 2                   Republic           Yugoslavia 2     2   1 5 Finland      7 2  3 12 France 10    6 5 18 7  46 Germany     15  29 7  51 Hungary        4 1 5 India 21 38 13   4 2 7  85 Iran 2     1  1 5 9 Ireland       3  2 5 Italy    2 5  23 3  33 Japan 5    4 4 24 8 1 46 Lithuania         1 1 Mexico        1 2 3 Morocco         2 2 Netherlands      4 7 2 1 14   New                
                                                                                        and                                                                                                                                             Rica                                Republic                                                     Federal              of                                                                                                                                                                                                                                                                                                                                                    Zealand      1   2 3

                                  Appendix II
                   Location, Number, and Type of Inspections
                      Conducted by the OPCW (April 1997 -
                                 December 2002)

                         (Continued From Previous Page)

    Member state  CWPF CWDF CWSF ACW OCW Schedule Schedule Schedule DOC Total 
                                         1        2        3            
       Norway                                   5        1            4    10 
       Panama                      1                                    
       Poland                      1                              3   5 
      Romania                                                     3   3 
      Russian                                                           
     Federation    106   35   35                         3        1   1   181 
    Saudi Arabia                                                      2 
     Singapore                                  2                 1   2 
       Slovak                                   4                 1   3 
      Republic                                                          
      Slovenia                                                        3 
    South Africa                                6                 1   2 
       Spain                                    4        3        3     
       Sweden                                   4        1        1   1 
    Switzerland                                 3       11        3     
       Turkey                                                     1   3 
      Ukraine                                                         5 
United Kingdom   20                 6        9       12        5     

    United States     86    219   75         3    13   31           3     430 
      Uzbekistan         1                                     1            2 
        Total        257    292   123   20   43   99   197   89   94    1,316 
    Source: OPCW.                                                     

Notes:�CWPF = chemical weapons production facility�CWDF =
chemical weapons destruction facility�CWSF = chemical weapons
storage facility�ACW = abandoned chemical weapons�OCW = old
chemical weapons�DOC = discrete organic chemicals�

The inspection data contained in the table is through December 2002
because the OPCW could not�provide more current data until it has
been approved by the CWC member states. Also, the table does �not
include inspections of the destruction of hazardous chemical weapons or
the emergency �destruction of chemical weapons in the United States
and Russia.�

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

Appendix III

International and Russian Funding for Chemical Weapons Destruction at
Shchuch'ye

As of December 2003, the United States and other international donors have
obligated about $525 million to develop, build, and support a chemical
weapons destruction facility at Shchuch'ye. Russia has spent about $95
million.1 These funds support three related areas of effort: (1) the
design and construction of the destruction facility, (2) the completion of
infrastructure located outside the destruction facility necessary for its
operation, and (3) community improvement projects in the town of
Shchuch'ye.

When completed, the Shchuch'ye chemical weapons destruction facility will
comprise a complex of about 100 buildings and structures designed to
support and complete the destruction of the chemical weapons stored at
Shchuch'ye and Kizner, which represents about 30-percent of Russia's total
stockpile. The United States, through the Department of Defense's (DOD)
Cooperative Threat Reduction program, has obligated more than $460 million
for the design, construction, equipment acquisition and installation,
systems integration, training, and start-up of the facility.2 The United
States plans to spend a total of more than $1 billion to finance the
construction of 99 of the 100 buildings and structures within the
facility, including one building where the chemical munitions will be
disassembled and the chemical agent destroyed. Russia has agreed to fund
the construction of a second destruction building at an estimated cost of
$150 million to $175 million, according to a DOD official. Russia spent an
estimated $6 to $8 million for the construction of the second destruction
building.3 Figure 3 illustrates the buildings and structures within the
destruction facility at Shchuch'ye.

1Since 2001, Russia has allocated at least $25 million per year at
Shchuch'ye, satisfying a Congressional condition for U.S. assistance.

2This includes funding for a Russian chemical analytical lab but does not
include funding for demilitarizing former Russian chemical weapons
production facilities and securing Russian chemical weapons stockpiles.

3According to DOD and Russian officials, international donors may provide
assistance for construction of the Russian destruction building at
Shchuch'ye.

                                  Appendix III
                     International and Russian Funding for
                   Chemical Weapons Destruction at Shchuch'ye

Figure 3: Chemical Weapons Destruction Facility at Shchuch'ye

Source: Department of Defense.

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.

Appendix III
International and Russian Funding for
Chemical Weapons Destruction at Shchuch'ye

Figure 4: Construction of the U.S. Destruction Building at Shchuch'ye,
November 2003

Source: GAO.

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.

Appendix III
International and Russian Funding for
Chemical Weapons Destruction at Shchuch'ye

Figure 5: Construction of the Russian Destruction Building at Shchuch'ye,
November 2003

Source: GAO.

The operation of the chemical weapons destruction facility at Shchuch'ye
depends upon the completion of several infrastructure projects, such as
the installation of natural gas and water lines and an electric
distribution station. As of October 2003, Russia had spent more than $56
million to support those projects. International donors have spent about
$65 million for these and other infrastructure projects, such as the
construction of access roads.4 About $66 million of infrastructure
projects, including the installation of sewage and fiber optic lines,
remain unfunded. In September 2003, Russia signed an agreement with the
United States stating that it would complete all necessary infrastructure
to support initial testing of the Shchuch'ye facility.

4International donors include Canada, the Czech Republic, the European
Union, Italy, Norway, the Nuclear Threat Initiative, and the United
Kingdom.

Appendix III
International and Russian Funding for
Chemical Weapons Destruction at Shchuch'ye

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.

                                  Appendix IV

                     Comments from the Department of State

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

Appendix IV
Comments from the Department of State

                                 See comment 1.

                         See comment 2. See comment 3.

Appendix IV
Comments from the Department of State

                                 See comment 4.

                                 See comment 5.

                                 See comment 6.

                                 See comment 7.

Appendix IV
Comments from the Department of State

                                 See comment 8.

                                  Appendix IV
                     Comments from the Department of State

The following are GAO's comments on the Department of State letter dated
March 19, 2004.

GAO Comments 1.	State asserts that this report did not sufficiently
present positive CWC accomplishments such as the continuous growth in the
number of CWC member states, the identification and correction of
management inefficiencies at the OPCW, and the effective implementation of
the OPCW inspection regime. In response, we included additional
information in this report to acknowledge the growth in the number of
member states. We also cite that Libya, the sixth possessor state, acceded
to the CWC in February 2004. This report does not discuss the management
of the OPCW, as we previously reported on the management of the
organization under the leadership of the former Director-General, Jose
Bustani.1 We did not review the management of the OPCW under the current
Director-General, Rogelio Pfirter but acknowledge that he is committed to
implementing management reforms. Finally, this report clearly articulates
that the OPCW has established a credible inspection regime.

2.	State concluded that the entry into force of the CWC caused two
previously unknown stockpiles to be discovered and accelerated chemical
weapons destruction efforts. In its comments, however, State did not
identify the member states that possess the unknown stockpiles.

3.	State cites that of the 158 member states, 56 of 61 member states with
CWC-declarable facilities have adopted national laws. This statement
implies that only countries with CWC-declarable facilities should adopt
national implementing laws. As stated in the report, the CWC requires all
member states to adopt national implementing laws. Assistant Secretary of
State for Arms Control stated in his remarks to the 2003 CWC Review
Conference that the lack of national implementing laws among member states
is troubling "in light of the efforts of Al Qaeda and other terrorist
organizations to acquire chemical weapons."

1U.S. General Accounting Office, Chemical Weapons: Organization for the
Prohibition of Chemical Weapons Needs Comprehensive Plan to Correct
Budgeting Weaknesses, GAO-035 (Washington, D.C.: Oct. 24, 2002).

Appendix IV
Comments from the Department of State

4.	State indicated that Russia budgeted roughly $420 million for all of
its chemical weapons demilitarization-related activities between 2001 and
2003 and that Russia's approved 2004 budget requests about $180 million
more. We have included this additional information in the report, as it
was not previously provided to us.

5.	State contends that our estimated deadline of 2014 for the complete
destruction of the U.S. chemical weapons stockpile is unsubstantiated. The
department further asserts that our 2027 estimate for the completion of
Russia's chemical weapons destruction assumes a single nerve agent
destruction facility, at Schuch'ye and that we omit the possibility of
constructing additional destruction facilities. We have clarified the 2014
deadline by adding information citing a U.S. chemical weapons destruction
facility schedule that indicates that the facility will not complete its
destruction operations until 2014. While we acknowledge that Russia may
construct additional destruction facilities, our analysis is based on the
destruction capacity of the one nerve agent destruction facility currently
under construction. At this time, there are no other nerve agent
destruction facilities under construction and no definitive plans for
building additional facilities. Furthermore, Russia has agreed to
eliminate all nerve agent at Shchuch'ye, unless otherwise agreed in
writing. In a March 2004 congressional testimony, the Deputy
Undersecretary of Defense for Technology Security Policy and
Counterproliferation stated that the Shchuch'ye facility "will destroy all
of Russia's nerve agent inventory." While Russian officials have indicated
that Russia may construct neutralization facilities at Pochep, Leonidovka,
and Maradovski, a detailed plan and/or cost estimates have yet to be
provided.

6.	State contends that the option of delaying further assistance to Russia
could result in a greater proliferation threat. State implies that we are
only presenting one option, when in fact this report provides numerous
options, including providing additional assistance for Russian chemical
weapons destruction. Furthermore, Congress has previously exercised the
option of withholding U.S. assistance for Russian chemical weapons
destruction.

7.	State claims that facilities that produce discrete organic chemicals
(DOC) are of little or no proliferation concern to the CWC. However,
information we obtained from State, Commerce, DOD, and the OPCW,
contradicts this statement. Officials and documents from all four
organizations clearly expressed concern over the potential

Appendix IV
Comments from the Department of State

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.

                                   Appendix V

                    Comments from the Department of Defense

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

Appendix V
Comments from the Department of Defense

Appendix V
Comments from the Department of Defense

                                 See comment 1.

                                 See comment 2.

                                 See comment 3.

Appendix V
Comments from the Department of Defense

                                 See comment 4.

                                 See comment 5.

                                   Appendix V
                    Comments from the Department of Defense

The following are GAO's comments on the Department of Defense letter dated
March 18, 2004.

GAO Comments 1.

2.

3.

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.

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.

DOD believes that this report is not conducive to providing a balanced
perspective because it does not acknowledge successes in implementing the
CWC. For example, DOD cites that progress has been made in eliminating
former chemical weapons production facilities and destroying category 2
and 3 chemical weapons related munitions. Such successes, while important,
remain secondary to the CWC's primary goal of destroying actual chemical
weapons. As stated in the report, the CWC is the only multilateral treaty
that seeks to eliminate an entire category of weapons of mass destruction
under an established time frame and verify their destruction through
inspections. DOD also asserts that this report does not recognize the
significant changes occurring within the OPCW. This report does not assess
OPCW functions or performance because we conducted such a review of the
OPCW in October 2002. This report does, however, credit the organization
with finding more efficient and cost-effective means of conducting its
inspection activities as it faces the challenge of meeting an increased
inspection workload. In addition, we have provided information in this
report to further clarify that OPCW inspectors have access to declared
facilities and that there are now 161 member states to the OPCW, including
Libya.

Appendix V
Comments from the Department of Defense

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.

Appendix VI

Comments from the Department of Commerce

Appendix VII

Comments from the Organization for the Prohibition of Chemical Weapons

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

                                  Appendix VII
                     Comments from the Organization for the
                        Prohibition of Chemical Weapons

The following is GAO's comment on the Organization for the Prohibition of
Chemical Weapons' letter dated March 25, 2004.

GAO Comment 1.	We made changes to this report to accurately reflect the
technical comments we received from the OPCW.

Appendix VIII

                     GAO Contact and Staff Acknowledgments

                    GAO Contact David Maurer (202) 512-9627

Acknowledgments	In addition to the individual named above, Beth A. Hoffman
Leon, Nanette J. Ryen, Julie A. Chamberlain, and Lynn Cothern made key
contributions to this report. Etana Finkler and Pierre R. Toureille also
provided assistance.

GAO's Mission	The General Accounting Office, the audit, evaluation and
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