Practical Implementation of Complementary Access
Complementary Access (CA) may be requested by the IAEA after a State’s Article 2. declaration
is reviewed and cross-checked against the Agency’s own verification
information, AP declarations filed by collaborating partner States, and
open source information. Most access is to assure the absence
of undeclared nuclear material and activities, and occasional questions
are to be expected.
Case Example: CA
in a Research Laboratory
In the particular case of CA in a research laboratory, the
IAEA may do
the following:
- Determine its location;
- Confirm nature of research conducted;
- Confirm project status;
- Review project records; and
- Collect environmental samples.
The IAEA will utilize indicators such as open source
information, equipment and materials that are present, and other
observations during the CA activities to address inconsistencies or
check on the absence of undeclared nuclear material or activities.
It should be noted that the Agency may take location-specific
environmental samples anywhere in the State, even locations that are
not declared. However, the “reasonable effort” provision (see
section 6.2) applies in this case. For all environmental
sampling, the IAEA typically leaves one portion (i.e., “split”) of the
sample with the State so they may analyze it if they desire.
Location-specific
environmental sampling means the collection of environmental
samples (e.g., air, water, vegetation, soil, smears) at, and in the
immediate
vicinity of, a location specified by the Agency for the purpose of
assisting the Agency to draw conclusions about the absence of
undeclared nuclear material or nuclear activities at the specified
location.
Administrative procedures as well as self-assessments against
those procedures can assist a State with preparing, hosting, and
concluding a CA. Administrative considerations that can be addressed in
the procedures may include:
- Providing a designated workspace with telephones for the
inspectors;
- Verification of inspectors’ passports and inclusion on the
list of Agency designated inspectors for the State;
- Issuing foreign visitor identification, if necessary;
- Discussing health, safety, and security procedures and
providing training, if necessary;
- Checking inspectors’ CA kit;
- Verification of CA assignments of the host team. The host
team may consist of any of the following individuals:
- State representative
- Facility representative
- Person familiar with a State's AP declaration
- Principle investigators on declarable activities being
viewed
- Safety and health official
- Person familiar with relevant commercially sensitive or
proprietary information
- Foreign Guest Services representative in charge of
security or escorting
- Formal CA close-out meeting;
- Reviewing action items;
- Reviewing request for documents; and
- Returning safety monitoring devices and documents provided
to the IAEA during the CA.