Preparing for Complementary Access (CA)

An integral part of the Additional Protocol (AP) is the IAEA’s right to verify specified locations for the absence of undeclared nuclear activities, confirm the status of operation as well as to resolve questions about the correctness and completeness of a State’s declaration.  Especially considering that CAs can be conducted with only 24 and/or two-hour notice, establishing procedures for notification of appropriate government officials and affected private entities of an upcoming CA will facilitate a successful CA.  Part of the planning should involve procedures for handling a CA, specifically for managed access to protect proprietary or sensitive information.  More information is provided on CAs in the "Complementary Access" module.        

Administrative Preparation - procedural preparations necessary in the event that a CA occurs.  Facility, regulator, and governmental preparations are considered.  Typical component areas address a graded approach to preparing locations for a possible CA visit and how to remain in readiness for a CA from an administrative point of view.

Technical Preparation - ensure readiness for a CA from a technical perspective.  A sample item might be to consider whether the State should do its own open source study to identify possible proliferation concerns relevant to the State.  Another is how an understanding of the nuclear fuel cycle and the AP Annexes help to determine what is needed to obtain materials of concern, and how it helps in identifying crossover technologies (i.e., technologies typically used for non-nuclear purposes that may have nuclear application). How a state might identify those entities possessing the material means and the intellectual capability to acquire nuclear materials of interest, relevance of the AP in helping to identify precursors to the acquisition of nuclear material, and awareness of foreign research and development collaborations are other examples.

Host Team Roles and Responsibilities - addresses the composition of the CA host team and seeks to define the team’s membership, activation, and roles/responsibilities.  Typical responsibility areas are the host team spokesperson, technical expert and documentarian, as well as safety, health, security, and administrative representation.  Because of the short notice associated with CAs, backups for key personnel should be considered.

CA Implementation - examines issues that arise during a CA.  Example considerations include the kind of information that would be exchanged at an Entrance Meeting, what information the host can expect to exchange with the CA team, CA team members’ right to privacy of notes taken during the CA, activities the CA team might conduct, how the host might be assured of its ability to answer CA team questions, and expectations from the Exit Meeting.

Entrance Meeting - describes the protocol to be followed on receipt of a CA Notice.  Entrance Meeting topics such as understanding the purpose of the CA, issues to be addressed, determining what questions can be resolved at the Entrance Meeting, how information/documentation requests will be addressed, and who should be present are typical preparation subjects.  How the CA team (IAEA inspectors) will be greeted, access procedures to be followed, health and safety considerations/procedures, CA equipment inspection, notification of normal working times, and logistical aspects such as provision of workspace and communications for the CA team, may also be explored.

Managed Access - considers the issue of using managed access measures to protect proprietary information and how to assure the health and safety of the CA team.  Relevant procedures for selecting access routes, walk-downs of areas, and use of cameras, as well as a good understanding of the Reasonable Effort provision and activities authorized under managed access must all be addressed well ahead of a managed access notification.

Effectiveness and Efficiency - explores procedures and policies, and examines good practices, to meet the obligations of a CA in the most effective and efficient manner possible.  Post-CA lessons learned meetings and updates to existing procedures are some example techniques.  Scheduling periodic (for example, annual) reviews and updates to existing procedures are others.