Chemical weapons

1.  Introduction

The UK is a signatory to the Chemical Weapons Convention (CWC), which sets out the international controls on chemical weapons and certain toxic chemicals, including their precursors. These substances are listed in Schedules to the CWC and reproduced here as appendices 1, 2 and 3.  Some are used, produced or otherwise acquired, or likely to be stored in University departments (albeit in small amounts). As there are no longer any thresholds for national declarations under the CWC, the University‚Äôs activities are covered by certain provisions of the CWC, implemented in the UK by the Chemical Weapons Act 1996. 

In the case of Schedule 1 substances (Appendix 1), the University has been authorised by the Secretary of State for Trade and Industry to operate under an Open General Licence issued under the Act. This imposes a number of conditions relating to the quantities of scheduled chemicals that may be kept, to requirements for various notifications to the Secretary of State, and to requirements for record keeping.

In the case of Schedule 2 substances (Appendix 2), the University must make an annual return to the Department of Trade and Industry (DTI) of the quantities consumed, produced, imported 1, or exported.

In the case of Schedule 3 substances (Appendix 3), the University must make an annual return to the Department of Trade and Industry (DTI) of the quantities produced, imported 1, or exported.

2.  Action required

The University Safety Office will administer these requirements on behalf of the University and the actions required of departments are as follows.

(a)  Note that these actions apply to very few departments: the Safety Office does not require a response from departments that do not store, consume, produce, import, or export chemicals listed in the appendixes.

(b)  Notify the Safety Office immediately if any chemical listed in appendix 1 is kept, used, acquired, or produced. Note that acquisition includes receipt as a gift from colleagues or collaborators as well as purchase. (The Safety Office must then notify the Secretary of State within 14 days of the acquisition or production).

[1] Note that this refers to direct import, not to purchase from a UK supplier where the supplier is the importer.

(c)  Notify the Safety Office well in advance of any intention to import [1] saxitoxin or ricin from, or export them to, another Member State of the European Community. (The Safety Office must notify the Secretary of State at least 50 days in advance of the proposed import or export).

(d)  Notify the Safety Office immediately if the department ceases to keep or use, or wishes to dispose of, any chemical listed in appendix 1. (The Safety Office must make an annual return to the Secretary of State detailing the University's stocks of these substances).

(e)  Notify the Safety Office by 1 December of each year if any substances in appendix 2 have been consumed, produced, imported 1, or exported.

(f)  Notify the Safety Office by 1 December of each year if any substances in appendix 3 have been produced, imported1, or exported. (Note that this list includes many common chemicals: if they have merely been purchased or used, but not produced, imported 1, or exported, then no notification is required).

(g)  Departments should note that many appendix entries refer to groups of chemicals, rather than individual chemicals. The Safety Office holds a comprehensive list of chemicals that are notifiable under the CWC (this is not made available for general circulation) and advice should be sought where there is any doubt about the need to make a notification in respect of a certain chemical.

THIS STATEMENT FORMS PART OF THE UNIVERSITY SAFETY POLICY.  UNIVERSITY GUIDANCE NOTE S1/97 IS WITHDRAWN.  PLEASE AMEND THE INDEX.

[1] Note that this refers to direct import, not to purchase from a UK supplier where the supplier is the importer.

November 2004