Pre-Inspection Briefing
OVERVIEW

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About PIB

The PIB is the first official activity during a CWC inspection, and therefore critical to creating a cooperative atmosphere for a Chemical Weapons Convention (CWC) inspection. The Chemical Weapons Convention Regulations (CWCR) (15 CFR Part 716.4(c)) mandate that the PIB be no more than 3 hours in length and is provided by representatives of the plant site (consult DOC fact sheet "Lessons Learned from Industry Inspections" for further information). The briefing must address a number of site-specific issues which may impact the inspection, including general site activities, physical layout, declared areas and associated units, scheduled chemicals, process flow, safety measures, and administrative and logistic arrangements for the inspection. The briefing's purpose is to provide sufficient information to the inspection team from the Organization for the Prohibition of Chemical Weapons (OPCW) so it may design an inspection plan that achieves its inspection aims in the least intrusive manner possible. A thorough and accurate PIB helps ensure that company, plant site, and plant(s) information is accurately reflected in the inspection report.

The PIB can be a useful tool in identifying company operational activities and procedures that may impact, or be adversely impacted by, inspection activities. By providing ample information in the briefing about your plant site and the activities the inspectors may observe, you will be able to proactively address many issues and questions that typically arise during an inspection. It is also important to ensure that the PIB is consistent with what may be observed during inspection activities.

It has been the experience of the Department of Commerce (DOC) Bureau of Industry and Security (BIS) that the inspectors' approach to inspections often is affected by the information provided by the site during the PIB. Although implementing the recommendations contained in this presentation is not required, BIS encourages you to consider and incorporate them when developing your own PIB. The recommendations presented have been developed based on experiences and lessons learned from roughly 40 CWC inspections of U.S. industrial facilities.

Upon notification of an inspection, BIS deploys an Advance Team (AT) to your site to assist in inspection preparation, including the assembly of the PIB. The AT will offer suggestions for additional information and assist in training site personnel in the presentation of the PIB. This helps ensure the PIB is complete, accurate and informative, thus laying the foundation for a successful inspection.

UDOC Overview

The following is an overview of the content typically included in a PIB for an inspection at an Unscheduled Discrete Organic Chemical (UDOC) plant site.

The CWCR group toxic or precursors to toxic chemicals into three schedules and a basket category known as Unscheduled Discrete Organic Chemicals (UDOC). The latter includes discrete organic chemicals not listed in either Schedule 1, 2, or 3 and consistent with the definition listed below:

As defined in Supplement No.1 to Part 715 of the CWCR, UDOCs include "any chemical:(1) belonging to the class of chemical compounds consisting of all compounds of carbon except for its oxides, sulfides and metal carbonates identifiable by chemical name, by structural formula, if known, and by Chemical Abstract Service registry number, if assigned; and (2) that is not contained in the Schedules of Chemicals (see Supplements No. 1 to parts 712 through 714 of the CWCR). UDOCs subject to declaration under this part are those produced by synthesis that are isolated for use or sale as a specific end product." UDOCs containing the elements phosphorus, sulfur or fluorine is referred to as "PSF-chemicals". Refer to Supplement No. 2 to Part 715 for examples of UDOCs and UDOC production.

Exemptions to the UDOC classification include the following: (1) polymer substances and oligomers consisting of two or more repeating units, and formed by the chemical reaction of monomer or polymer substances; (2) chemicals and chemical mixtures produced through a biological or biomediated process; (3) products from the refining of crude oil, including sulfur-containing crude-oil; (4) metal carbides (i.e., chemicals consisting only of metal and carbon); (5) UDOCs produced by synthesis that are ingredients or by-products in foods designed for consumption by humans and/or animals. (6) UDOC plant sites that exclusively produce hydrocarbons (organic compounds that contain only carbon and hydrogen; and (7) UDOC plant sites that exclusively produce explosives or mixture of chemicals that are included in Class 1 of the United Nations Organization hazard classification system.

Plant sites that produce by synthesis in excess of 200 metric tons aggregate (including PSF-chemicals) or in excess 30 metric tons for each PSF-chemical at one or more plants are required to submit declarations to BIS. Plant sites that declare in excess of 200 metric tons aggregate of UDOCs (including PSF chemicals) are subject to inspection by the OPCW. UDOC inspection selection methodology is based on random geographical selection and other factors. Currently, 57 States Parties have declared more than 4,100 UDOC plant sites subject to inspection.

PIB Requirements

Company representatives are required to provide the OPCW inspection team with an overview of the declared activities and the declared plant site prior to the start of the inspection. The CWCR's requirements for a PIB are as follows:

Upon arrival at the inspection site and before the commencement of the inspection, facility representatives will provide to the Inspection Team and Host Team a pre-inspection briefing on the facility, the activities carried out there, safety measures, and administrative and logistical arrangements necessary for the inspection, which may be aided with the use of maps and other documentation as deemed appropriate by the facility. The time spent for the briefing will be limited to the minimum necessary and may not exceed three hours.

The PIB will address:

• plant safety and alarms
• activities, business and manufacturing operations
• physical layout
• delimitation of declared facility
• scheduled chemicals/chemistries declared and undeclared
• units specific to declared operations
• administrative and logistics information.

The PIB may also address:

• introduction of key facility personnel
• management, organization and history
• confidential business information concerns
• types and location of records and documents
• data declaration updates and/or revisions
• draft facility agreement (if requested by site)
• proposed inspection plan

By addressing those elements required and suggested by the CWCR, a plant site can proactively demonstrate compliance with the CWC, and potentially reduce the length of the inspection.

Interactive PIB Presentation

The following slides provide an overview of the content typically included in a Pre-Inspection Briefing for an inspection at an Unscheduled Discrete Organic Chemical (UDOC) plant site and includes explanations and rationales for the included content.

Click to Continue with the Interactive PIB Presentation template description.

Click to Download ¹ the Interactive PIB Presentation template.

Note: If would like additional information call BIS at 202-482-1001.

 

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¹ Requires Microsoft PowerPoint software.