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Weapons of Mass Destruction (WMD)

UNSCOM - Report to the Security Council - 25 January 1999

ANNEX C

STATUS OF VERIFICATION OF IRAQ'S BIOLOGICAL WARFARE PROGRAMME

Executive Summary

1. Iraq did not acknowledge its proscribed Biological Warfare (BW) weapons programme until July 1995. From the first UNSCOM inspections in 1991 until 1995 Iraq denied it had a BW programme and has taken active steps to conceal it from the Special Commission. These steps included fraudulent statements, forged documents, misrepresentation of the roles of people and facilities, and other specific acts of deception.

2. Since its first revelations in July 1995, Iraq has submitted three "Full, Final and Complete Disclosures" (FFCDs) of its proscribed biological programme. The first of these, presented in August 1995, was declared null and void by Iraq itself. The second, submitted in June 1996, was subjected to intensive efforts to verify its accuracy and completeness through eight inspections and other technical discussions. In March 1997 an international panel of experts reviewed that FFCD and recommended its rejection because of the inadequacy of the material presented throughout the document.

3. In September 1997, Iraq submitted its third "final" FFCD since the July 1995 disclosures. This FFCD contained essentially no new significant information from the previous one that the Commission had rejected as incomplete. A panel of international experts reviewed it in September 1997 and considered it as deficient in all areas. Iraq however argued that it had not been given an adequate opportunity to present its case to the UNSCOM assembled experts and at Iraq's request, a Technical Evaluation Meeting (TEM) between Iraq and a Commission assembled panel of international experts convened in Vienna in March 1998. Iraq did not present any new information at that meeting and the experts therefore reviewed the same material for a third time.

4. The TEM team reviewed the entire FFCD, and concluded it was deficient in all areas. In summary:

  • Weaponization There is considerable uncertainty regarding weaponization. The Iraqi account of the Al-Hussein BW warheads cannot be reconciled with the physical evidence. On R-400 bombs, there are inconsistencies in the account and the experts had no confidence in the number filled or how many were filled with particular agents.
  • Production Bulk BW agent production appears to be consistently understated. There are discrepancies between production capacity and the amounts of bulk agent declared to have been produced. The lack of documentation contributes to a low level of confidence in the Iraqi account of agent production quantities.
  • Acquisition The declaration on imports of raw materials and equipment is incomplete.
  • Planning All aspects of planning are omitted. This ranges from the circumstances surrounding the decision to commence the programme, the planning and the direction of the programme, the reasons for decisions and the individuals and organizations involved. The Commission considers that a knowledge of planning and decision-making is important because without it, determining the scale and the scope of the programme is not possible.
  • Research and Development (R&D) R&D is said to be unplanned, but the evidence shows that the programme was thoroughly planned.

  • History of Iraq's BW Programme Iraq provided a selected and incomplete history of the BW programme.

  • Organizations The FFCD generally lacks information concerning organizational information from the highest levels down. There is also a lack of information on the military (or intelligence) involvement in the programme in spite of the fact that the programme resulted in the deployment of weapons such as bombs and missiles.
  • Concealment and Deception Since its disclosures in 1995 Iraq has continued to deceive the Commission and conceal parts of its BW programme. This includes efforts to hide documents, media, equipment and operating locations.

5. At Iraq's request another review of the FFCD by a team of international experts was conducted in Baghdad in July 1998. By agreement with Iraq and the Special Commission this team focused on those elements directly related to the material balance: weapons, bulk agents and materials such as bacterial growth media. This team concluded:

  • Weapons On weapons the team concluded that the material balances and their sub-components (production, filling and destruction) declared in the FFCD for biological bombs (R-400) and Al-Hussein warheads, could not be verified. Furthermore the account in the FFCD on biological spray devices, modified drop tanks and the aerosol generator (Zubaidy device), could not be verified.
  • BW agents The material balances for bulk BW agents and their sub-components (production, filling, losses and destruction) for all declared agents (Clostridium botulinum toxin, Bacillus anthracis spores, aflatoxin Clostridium perfringens spores and wheat smut) could not be verified.
  • Media The media material balance and its sub-components (acquisition, consumption, losses and destruction) could not be verified.
  • FFCD Iraq's FFCD in its totality cannot be verified. The team also expressed the view that verification cannot be achieved in the present circumstances whilst the Commission has an incomplete understanding of the philosophy of the programme including the military and other (such as security service) requirements for biological weapons. Without such an understanding, the Commission has an inadequate basis on which to assess whether the Iraqi account is complete. Accordingly, the FFCD in its present form, is an inadequate document for verification purposes.

6. Both the Vienna TEM and the experts' review in Baghdad concluded that Iraq's biological FFCD is an inadequate document for verification purposes. The FFCD does not provide a coherent or comprehensive account of Iraq's BW programme and lacks any supporting framework such as descriptions of planning, objectives, policy and organizations involved. The experts found that much of the information collected by the Commission to verify the FFCD in fact contradicts statements therein, particularly the evidence regarding weaponization, the quantity of agents produced and the media balance. The hundreds of interviews that the Commission has conducted with Iraqi officials also fail to provide a comprehensive account and even allowing for errors of memory, often contradict the account in the FFCD.

7. Supporting documentation is generally lacking. Iraq explains that this was because a decision was made in 1991 that all documents relating to the BW programme were to be destroyed. After the departure of Lt. Gen. Hussein Kamel Hassan in August 1995, the Commission was told that some documents had however been saved and about 200 documents relating to the BW programme were recovered by the Commission from buildings at the Haidar Farm. Most of these documents related to research and did not add a great deal to the Commission's overall understanding of the programme. In addition to these documents, since 1995 and after much prompting by the Commission, Iraq has provided a number of additional documents of variable quality. Most of them are peripheral to the verification process and are open to various assessments. Thus, except in some limited areas, documentation provided by Iraq is grossly inadequate for verification purposes.

8. On technical, industrial and scientific developments of Iraq's BW programme, it has not been possible to compile a comprehensive assessment because Iraq has not been transparent in its FFCD nor in its clarifications of the account of its BW programme.

9. The review also attempted to quantify levels of confidence in the accounting for the various elements of Iraq's BW programme. In reaching its assessment, the Commission has taken into consideration the quality of information in its possession; documentary, physical, and personal testimony provided by Iraq; and the correlation of this information with other information such as that provided by Iraq's former suppliers, from inspections or otherwise obtained by the Commission.

10. The Commission has a degree of confidence in the accounting for some proscribed items which Iraq presented for verification and disposal. This includes, for example: the destruction of buildings, and equipment at Al-Hakam, the destruction of large quantities of growth media acquired for the programme; and evidence that R-400 aerial bombs and Al-Hussein warheads contained BW agents and consequently that Bacillus anthracis spores and Clostridium botulinum toxin were indeed weaponized.

11. The Commission has far less confidence in the accounting for proscribed items declared by Iraq as having been unilaterally destroyed. These include, for example: the number and fill of R-400 aerial bombs destroyed at Al-Azzizziyah; the number and fill of BW Al-Hussein warheads destroyed; and the fate of the biological warfare agent to be used with drop tanks.

12. The Commission has little or no confidence in Iraq's accounting for proscribed items for which physical evidence is lacking or inconclusive, documentation is sparse or nonexistent, and coherence and consistency is lacking. These include, for example: quantities and types of munitions available for BW filling; quantities and types of munitions filled with BW agents; quantities and type of bulk agents produced; quantities of bulk agents used in filling; quantities of bulk agents destroyed; quantities of growth media acquired for the programme; and quantities of growth media used/consumed. In addition the Commission has no confidence that all bulk agents have been destroyed; that no BW munitions or weapons remain in Iraq; and that a BW capability does not still exist in Iraq.

13. From 1987 onwards Iraq undertook pilot and industrial scale production of BW agents. Iraq denies any parallel activity to develop weapons capable of delivering the BW agents it was producing. During inspections, Iraq has stated that its policy was to evaluate weapons that had been developed for Chemical Warfare (CW) purposes, to establish whether they could be adapted for BW agents. It is difficult to accept that Iraq claims it had not initiated a BW-specific weapons programme in the late 80's, possibly in the MIC Naval and Aerial Bombs Section, in order that efficient and effective dissemination weapons be made available. It is not clear whether such weapons have been developed and are not disclosed, or have been partly developed, not reaching a stage where they could be manufactured.

14. Several other outstanding issues also remain to be resolved. These issues are related: to the scope and extent of R&D activities; the acquisition of supplies and equipment; the involvement of military and other agencies in the BW programme; and deception and concealment of the BW programme.

15. Iraq has not provided evidence concerning the termination of its offensive BW programme. The evidence collected by the Commission and the absence of information from Iraq, raises serious doubts about Iraq's assertion that the BW programme was truly "obliterated" in 1991 as it claims.

16. Abbreviations

Agent A.................................................................................................Clostridium botulinum toxin

Agent B.......................................................................................................Bacillus anthracis spores

Agent C.................................................................................................................................aflatoxin

Agent D................................................................................................................Wheat Cover Smut

Agent G.............................................................................................Clostridium perfringens spores

Al-Hakam...............................................................Al-Hakam Factory for Production of BW agents

ATCC..........................................................................................American Type Culture Collection

Bt......................................................................................................................Bacillus thuringiensis

BW........................................................................................................................Biological Warfare

CN.......................................................................................1-Chloroacetophenone, riot control agent

CS...................................................................o-Chlorobenzylidene Malononitrile, riot control agent

CW.........................................................................................................................Chemical Warfare

DIALOG..............................................................................................................Computer Database

FFCD..........................................................................................Full Final and Complete Disclosure

FMD..................................................................................Foot and Mouth Disease Vaccine Factory

Haidar Farm...........................................Storage site for documents of Iraq's weapons programmes

IAEA........................................................................................International Atomic Energy Agency

kg........................................................................................................................................kilograms

km......................................................................................................................................kilometres

Kimadia.............................................State Company for Drugs and Medical Appliances Marketing

LC...............................................................................................................................Letter of Credit

MIC.................................................................................................Military Industrial Commission

MOD..................................................................................................................Ministry of Defence

NMD...............................................................................................National Monitoring Directorate

R&D........................................................................................................Research and Development

SCP.......................................................................................................................Single Cell Protein

SCR.........................................................................................................Security Council Resolution

SEHEE.........................................................State Establishment for Heavy Engineering Equipment

SEPP..........................................................................State Establishment for Pesticides Production

SOTI...............................................................................State Organization for Technical Industries

TEM...................................................................................................Technical Evaluation Meeting

TSMID................................................................Technical and Scientific Materials Import Division

TRC...........................................................................................................Technical Research Centre

UNSCOM..................................................................................United Nations Special Commission

VRL...............................................................................................Veterinary Research Laboratories

Introduction

17. Iraq's offensive BW programme was among the most secretive of its programmes of weapons of mass destruction. Its existence was not acknowledged until July 1995. During the period from 1991 to 1995 Iraq categorically denied it had a biological weapons programme and it took active steps to conceal the programme from the Special Commission. These included fraudulent statements, false and forged documents, misrepresentation of the roles of people and facilities and other specific acts of deception. For example, Iraq claims to have destroyed much of the documentation and overt evidence of the programme. At the same time Iraq maintained other aspects of the programme such as the equipment, supplies (e.g., bacterial growth media), and personnel as an intact entity and facilities of the programme such as the Al-Hakam facility that produced BW agents.

18. In 1995, when Iraq was confronted with evidence collected by the Commission of imports of bacterial growth media in quantities that had no civilian utility within Iraq's limited biotechnology industry, it eventually, on 1 July 1995, acknowledged that it used this growth media to produce two BW agents in bulk, botulinum toxin and Bacillus anthracis spores, between 1988 and 1991. It was not, until August of 1995, however, that Iraq acknowledged that it had weaponized BW agents, and had undertaken weapon tests from 1987 onwards. This admission only occurred after Lt. Gen. Hussein Kamel Hassan departed. Shortly afterwards, Iraq released a considerable quantity of documents concerned with its weapons of mass destruction programmes. The documents relating to biology represented just 200 documents with some pages out of a total of more than a million pages. Many of the biological documents were scientific reprints from foreign journals. Clearly, they represent only a minor portion of a BW programme that ran from 1973 until at least 1991.

19. Since July 1995, the Commission has conducted 35 biological inspections directly or indirectly related to investigations of Iraq's proscribed BW programme. In addition, two inspections devoted to the destruction of sites, known to be integral components of the programme, have been undertaken. The past programme investigations have concentrated on issues that are directly related to disarmament and have attempted to validate these aspects of Iraq's Full Final and Complete Disclosure (FFCD), generally without success. This considerable effort has been negated by Iraq's intransigence and failure to provide cooperation concerning its biological weapons since January 1996.

20. After Iraq's acknowledgement of its BW weapons programme , Iraq has submitted three FFCDs of its BW programme. While the first of these FFCDs was declared void by Iraq itself in August 1995, the two latter FFCDs were reviewed by panels of international experts on four occasions. In March 1997, an expert panel recommended the rejection of Iraq's June 1996 FFCD because of the inadequacy of the material presented throughout the document. In May 1997, the Commission presented formats to enable Iraq to clarify deficiencies in its biological FFCD. All areas of concern to the Commission were clearly identified and discussed with Iraq. It was expected that these issues would be seriously and comprehensively addressed by Iraq in its next FFCD. However, in September 1997, Iraq provided a new FFCD that contained essentially the same information, ignoring all advice provided to it by the Commission. As reported to the Council, an international expert panel reviewed Iraq's biological FFCD in September 1997, and considered it deficient in most aspects. In March 1998, a biological Technical Evaluation Meeting (TEM) between the Commission and Iraq took place in Vienna dealing with all aspects of the biological FFCD. The Commission's team comprised 18 experts from 15 countries.

21. On each occasion the experts unanimously considered Iraq's FFCD presented an inadequate, inaccurate account with deficiencies in all areas. Iraq's latest biological FFCD (submitted in September 1997) is not complete and fails to present a coherent, technically detailed, overall account. The shortcomings occurred not only in areas directly concerned with the material balance (e.g., weapons, bulk-agent products, and microbiological growth media), but also in all other areas (e.g., history, planning, acquisition, research and development). The TEM team also concluded that the FFCD had substantial deficiencies in all areas and Iraq's account of its BW programme could not be verified as a 'full and complete disclosure', as required by the Security Council. Iraq provided many explanations for the account in the FFCD but was unable to substantiate most of its disclosure, and was unwilling to add the missing components. In July 1998, another international team concluded the FFCD, in its present state, could not be verified as complete and accurate.

22. The Emergency Session of the Commission held in November 1997, concluded that the biological weapons file was the most serious area in which Iraq had consistently disregarded its obligations under SCR 687. The members of the Commission noted that the paucity of progress was largely attributable to Iraq's denial of the existence of any biological weapons programme until July 1995. The members of the Commission further noted that Iraq's FFCD of September 1997, was not substantially different from previous, unacceptable, versions, and it remained largely unsupported by evidence and documentation. The Security Council was urged to call upon Iraq to rectify the existing deficiencies.

23. In April 1998, the Commission's report to the Security Council (S/1998/332) listed the priority issues identified by the TEM. These included: history of the BW programme, organizations involved, acquisitions, research and development, production, weaponization and materials balance. In May 1998, Iraq provided clarifications of some issues arising from the TEM but has failed to resolve any of the key issues outstanding. Subsequently on 3 and 4 June 1998, the Commission provided a technical briefing to the Security Council. This gave an outline of the material balance and the main outstanding disarmament issues in each weapons area. In biology, this briefing highlighted the lack of verifiable details on virtually the entirety of the programme.

24. UNSOM presented to the Security Council outstanding issues and sought to establish a programme of work that would enable outstanding issues to be resolved. In biology the priority concerns were: the production of materials and equipment; agents; munitions, and their possible destruction. Additional requirements from Iraq were the provision of the information and materials identified by the TEM. The Commission subsequently met with the Deputy Prime Minister of Iraq in June and agreed on a schedule of work for the next two months. As part of the schedule of work it was agreed, at Iraq's request, to reconvene the international experts to discuss again, with a broad range of Iraqi experts the overall problems associated with the biological FFCD.

25. For these discussions, the Commission proposed that the approach should be "top down", that is focus primarily on weapons, in the belief that the many other important issues in biology might be more easily resolved if progress were made with respect to weapons. Accordingly, the discussions focussed on the provision of new material in the key area of the material balance of weapons, especially material not covered in the March TEM. Iraq did not provide any new information and the FFCD, presented to the Commission in 1997, was judged again to be inadequate.

26. Iraq has recently pressed for the experts to make a "quality assessment," as to whether any biological weapons or agent remain in Iraq. This was emphatically stressed by Iraq during a meeting between him and the Commission's Chief Inspector in July 1998. Given the present information disclosed by Iraq, such an assessment could not be made.

27. To assess the quality of any biological agent over time requires knowledge and confidence in that knowledge. This includes the physical state of the agent, e.g., liquid or dried, with or without stabilizers; storage conditions of the filled weapons or bulk agent, e.g., temperature, humidity, containers, etc.; tests done on the agent before and after filling, and the results of such tests. None of this information on Iraqi weapons is available to the Commission. SCR 687 (1991) requires the elimination of BW weapons regardless of its"quality".

28. The FFCD presents a limited account that deals only with some components of the programme uncovered during the Commission's investigations. Iraq states that it 'obliterated' the BW programme in 1991, claiming that this involved the destruction of all its BW weapons and associated records and documents. This has greatly complicated the determination of the material balance, and thus hindered verification. The FFCD portrays a programme designed to culminate in January 1991, suggesting that no plans existed beyond that time. In reality the programme was a continuing one, with objectives stretching well into the future. The statement that the programme was 'obliterated' in 1991 is contradicted by later evidence of deception and concealment. This activity continued until 1995, at least, and one of the aims could have been the preservation of essential components of the BW programme. Indeed, Iraq, after 1991, retained suitable growth media, BW facilities, production equipment, teams of expert personnel, and the essential technical knowledge.

29. Iraq has not revealed the planning process. No mention is made of the role of the military and intelligence services in defining the requirements for the BW programme, or in the subsequent planning to meet that requirement. Iraq's doctrine of use of BW weapons is not covered in the FFCD. Consequently, the Commission can not determine the organization, scope and fate of the programme. Iraq has yet to present any formal renunciation of the termination of its BW programme.

30. This paper presents a status report on the investigation and the various attempts to verify Iraq's FFCD. Greater emphasis is placed on matters that affect the Material Balance (Part I), i.e., unfilled and filled weapons, bulk agent, and microbiological growth media. Part II presents the status of verification of other areas, including history, acquisition of supplies and equipment, research and development, sites and facilities, involvement of other organizations such as military and intelligence organs. Part III presents other issues that also relate directly to verification. These include: investigation and verification inspections; Iraq's documentary evidence; technical coherence of Iraq's stated programme; technological progress of the programme; termination of Iraq's programme; and concealment and deception.

STATUS OF VERIFICATION CONCERNING THE MATERIAL BALANCE OF IRAQ'S BIOLOGICAL WARFARE PROGRAMME

Weapons Systems

31. To assess whether Iraq has met its obligations under Security Council Resolution 687 (1991), obtaining a full understanding of all aspects of Iraq's BW weapons is essential. Iraq's FFCD does not contain the required detail for such an assessment. It must include numbers, types, markings and a detailed account of individual weapon systems, supported by documents and physical evidence. The term 'weapons' in this paper refers to filled munitions, empty munitions, and bulk BW agents.

Al-Hussein Missile Warheads

32. In August 1995 Iraq declared that it had filled 25 Al-Hussein missile warheads with BW agents. This figure is not supported by conclusive evidence. In its FFCD Iraq has declared that five warheads were filled with Bacillus anthracis spores, 16 with botulinum toxin and four with aflatoxin. Ten warheads containing botulinum toxin were deployed to an abandoned railway tunnel at Al-Mansuriyah. The remainder was stored on the banks of the Tigris canal. No credible evidence has been presented to support this account of BW agent filling and subsequent weapon deployment.

33. Iraq claims that the Al-Hussein warheads were not specifically developed for BW; instead the Chemical Warfare (CW) warheads were filled with BW agents. Although static and dynamic trials were undertaken with CW agents, Iraq denies that there were any BW trials. Most of the CW warheads had aluminium containers. According to Iraq, later CW, and all BW, warheads had stainless steel containers to be filled with CBW agents. The substitution of aluminium containers with stainless steel containers is explained as a response to difficulties in welding aluminium. It is not attributed to the needs of the payload. Thus this BW weapon was filled and operationally deployed without any field tests.

34. Iraq asserts that all 25 BW warheads were unilaterally destroyed at specific locations at Al-Nibai desert in July 1991. To verify the FFCD, the Commission in 1998 took samples from the remnants of agent warhead containers excavated from various locations at Al-Nibai. The results of the analyses do not support the statements made in Iraq's FFCD. Traces of Bacillus anthracis spores have been identified on remnants of containers from at least seven distinct missile warheads as opposed to the five declared. There are discrepancies between the Iraqi account of where groups of warheads containing particular BW agents were destroyed and the results of the analyses. This throws doubt on the accounts of weapons filling, deployment and subsequent destruction.

35. In response to this evidence, in July 1998, Iraq changed its account of BW warhead and other munitions filling. It stated to an Commission team that, instead of the declared five Bacillus anthracis spores and 16 botulinum toxin warheads, there had been in fact 16 Bacillus anthracis spores and five botulinum toxin missile warheads. Iraq insisted that this change in disclosure would not affect Iraq's declaration on the total quantity of BW agents produced and weaponized. These changes also included alterations to the numbers of R-400 aerial bombs filled with Bacillus anthracis spores and botulinum toxin. Iraq did not present any supporting documents or other specific evidence to substantiate the new statement. In the original account, Iraq emphatically asserted that all ten weapons in the Al-Mansuriyah railway tunnel were filled with Bacillus anthracis spores and only later was this adjusted to botulinum toxin.

36. This new explanation contradicts many aspects of the accounts of the unilateral destruction of special warheads, including those filled with BW agents. Further, it is inconsistent with the accounts provided during the preceding three years by Iraqi personnel directly involved in warhead filling and destruction activities. The new statement does not fit the physical evidence available of the unilateral destruction of biological warheads.

37. The account of Iraq's Al-Hussein BW warheads has changed frequently over the past few years. In July 1998, even in the space of a few weeks, Iraq made 'suggestions' changing the numbers of warheads filled with particular BW agents and their deployment and destruction. The physical evidence from the destruction area and the analyses of the remnants contradicts the account contained in the FFCD. Thus the FFCD account is inaccurate and is not validated.

38. This table provides a summary of Iraq's declarations concerning Al-Hussein missile warheads.

FFCD UNSCOM Assessment Comments
Al-Hussein Missile Warheads Produced for the BW Programme,
Produced

25

There is no conclusive evidence that only 25 warheads were produced for BW use. The number cannot be ascertained. No evidence has been offered by Iraq, nor can UNSCOM find any, to indicate the numbers of BW warhead containers produced. Iraq acknowledges this lack of evidence.
Al-Hussein Missile Warheads Filled with BW Agents
Total filled

25

The evidence is circumstantial. The sole supporting document does not clearly refer to BW warheads. There is no credible evidence that only 25 were filled. This number is based solely on a document that refers to the "integration" of 25 warheads and mentions the presence of an officer connected with the BW programme.
Filled with botulinum

toxin

16

The figure of 16 appears to be derived solely by deduction; there is no supporting information. The number is inconsistent with evidence available. In September 1995, Iraq stated that 15 warheads had been filled with botulinum toxin; later this number was changed to 13. Later still the number was adjusted to 16. In July 1998, an Iraqi official suggested that only five may have been filled with botulinum toxin. According to Amer Rashid, this last figure was based on mathematical reasoning coupled with the results of the analysis of warheads recently excavated at Al-Nibai.
Filled with

Bacillus anthracis spores

5

The figure of five appears to be derived solely by deduction; there is no supporting information. The number is inconsistent with the evidence available, which suggests that more than five warheads contained Bacillus anthracis spores. In September 1995, Iraq stated that 10 warheads had been filled with Bacillus anthracis spores; later this number was changed to five. In July 1998, an Iraqi official suggested that 16 may have been filled with Bacillus anthracis spores. According to Amer Rashid, this last figure was based on mathematical reasoning coupled with the results of the analysis of warheads excavated at Al-Nibai.
Filled with

aflatoxin

4

The figure of four appears to be derived solely by deduction; there is no supporting information. In the original declaration of the contents of the Al-Hussein missile warheads, in September 1995, no mention was made of aflatoxin. Later Iraq stated that two had been filled with aflatoxin. Finally this number was adjusted to four.
Other

0

Documents presented by Iraq indicate that 16 warheads were filled with an agent that had a "time to effect" of greater than one week. This implies that the agent mentioned would not cause significant casualties until more than a week had passed following exposure. This raises the possibility of an agent other than Bacillus anthracis spores and Clostridium botulinum toxin which have a time to effect less than one week. Aerosol exposure to Clostridium perfringens spores fit this description. Iraq has declared the production of 340 litres of this agent but denied weaponization. Iraq has failed to account for very large quantities of a growth component, i.e., peptone, that could have been used to produce more than 7,500 litres of this BW agent. The description could apply also to aflatoxin, however, the amount of aflatoxin produced by Iraq's account, was insufficient to fill 16 warheads.

Al-Hussein Missile Warheads for BW Destroyed
Destroyed

25

Remnants excavated from Al-Nibai, the site of their declared unilateral destruction, include sufficient stainless-steel agent containers to account for declared quantities of BW and possible CW warheads, however the locations of the remnants are inconsistent with the FFCD account. Iraq declares that 25 warheads containing deactivated BW agent were destroyed.

R-400 Aerial Bombs

39. Iraq has declared, that 200 R-400 aerial bombs were manufactured for BW purposes. However, Iraq acknowledges that the numbers of bombs filled with particular BW agents are "guesses".

40. Iraq's accounts concerning the development of the R-400 bomb for BW purposes have changed since 1995. In 1995 when the personnel who conducted the programme were explaining the programme, they described it in considerable detail. There was a series of field trials using a total of six R-400 bombs, two each charged with Clostridium botulinum toxin, Bacillus subtilis and aflatoxin. Many animals were said to have been used. These field trials were reflected in the June 1996 FFCD. Subsequently, Iraq has denied that any such trials were conducted. It is very difficult to reconcile this change with very specific accounts of R-400 trials given by scientists, the attendant veterinary surgeon and workers, at what was said to be the site, namely Al-Mohammediyat. There was also a trial in August 1990 to determine the size of 'booster charge' charge required to disperse the agent. All attempts by Iraq to locate the exact site at Al-Hakam and find any evidence have failed.

41. Iraq initially claimed that 166 R-400 bombs were filled with BW agents. It was stated that three agents were used: agent 'A' (Clostridium botulinum toxin), agent 'B' (Bacillus anthracis spores), and agent 'C' (aflatoxin). Subsequently, to accommodate a document provided by Iraq that suggested that 157 R-400 bombs were destroyed, the figures were adjusted by a new claim by Iraq that only seven, and not 16 R-400 bombs were filled with aflatoxin.

42. Evidence of the destruction of three botulinum toxin filled R-400 bombs was found in 1997 when and remnants of another 20 R-400 bombs in the same area were identified. Remnants of another 25 R-400 bombs were also found in 1991, by a Commission inspection team, at a time when Iraq was declaring a total of only 40 R-400 bombs (stated to be all CW) at Al-Azzizziyah. It cannot be determined whether all these weapons had ever been filled. The figure of "157" R-400 bombs is based on a document provided by Iraq that suggests that 157 were destroyed. There is no evidence to support that these were in fact biological bombs.

43. A review by international experts of all information available to the Commission demonstrated that the account of R-400 bombs in the 1997 biological FFCD is both incomplete and inaccurate. The FFCD provides no documented account of filling. This means that a material balance for the weapons and the BW agents incorporated within them cannot be established. There is no confident upper limit on the number of bombs filled for BW purposes. There is no authenticated account of the destruction of the BW agent contained in the weapons. The possibility that such weapons remain in Iraq, cannot be precluded or that agent produced for such weapons exists in bulk storage.

44. The 1997 biological FFCD omits, or does not substantiate, many aspects of the R-400 programme, such as quantitative aspects of filling weapons, location and timing of filling, storage, deployment and destruction of weapons and military deployment or use. Photographic evidence shows that biological R-400 bombs were at an undisclosed site in October 1991, which is after Iraq claims that the BW programme had been "obliterated". This is of particular concern as it affects the credence of the account of R-400 weapons in the FFCD. The total number of R-400 bombs that would have been available for filling is not known.

45. The account of Iraq's R-400 aerial bombs has been changed several times since 1991. Even in July 1998 Iraq has made 'suggestions' changing the numbers of bombs filled with particular BW agents. The inconsistency between the FFCD account and the physical evidence means that the Iraqi account cannot be confirmed. Thus, the FFCD account is not verified.

46. The frequent changes in the Iraqi account of the Al-Hussein missile warheads and the R-400 aerial bombs are more than adjustments of detail. They cast doubt on the entire Iraqi declaration on weaponization.

47. The table provides a summary of Iraq's declarations concerning R-400 aerial bombs.

FFCD UNSCOM Assessment Comments
R-400 Aerial Bombs Produced
Produced

200

The number of R-400A bombs produced cannot be established. From production documents it is evident, that more than 200 bombs were available for BW. Senior Iraqi officials stated that the numbers given in the FFCD are only estimates. Partly coated bombs both with and without black stripes have been found by UNSCOM that is inconsistent with Iraq's account. Initially, Iraq ordered 200 R-400A bombs for the BW programme, externally marked with two longitudinal black stripes and with an internal protective coating. Iraq claims that, because of time constraints, a decision was made to produce only 175 R-400A bombs and another 25 without the epoxy coating or black stripes.
R-400 Aerial Bombs Filled with BW Agents
Total filled

157

The figure 157 is based solely on an extract from a diary that states 157 R-400 bombs were destroyed. However, it is unclear if the items destroyed were associated with BW agents. In 1991 Iraq claimed that only 40 R-400 bombs were destroyed at Al-Azzizziyah. In September 1995 Iraq declared that 166 bombs were filled. After presenting a diary that indicated 157 R-400 bombs were destroyed at Al-Azzizziyah, the number was changed to only 157 filled.
Filled with botulinum toxin 100 Iraq did not present any evidence in support of its claims. Evidence of botulinum toxin was found by UNSCOM in two destroyed R-400A bombs at Al-Azzizziyah. However, botulinum toxin was also found in one recovered R-400 bomb. In 1991, empty R-400 bombs bearing markings consistent with botulinum toxin fill were presented as chemical weapons to a UNSCOM team. Iraq states that 100 R-400A but no R-400 bombs were filled with botulinum toxin. A senior Iraqi official suggested in July 1998 that many more than 100 contained botulinum toxin. According to Iraq, the numbers are only estimates.
Filled with

Bacillus anthracis spores 50

The account is not supported by documents. No evidence of Bacillus anthracis spores has been found among the remnants recovered at the destruction site. Iraq states that 50 R-400A but no R-400 bombs were filled with Bacillus anthracis spores. A senior Iraqi official in July 1998 suggested that probably fewer than 50 contained Bacillus anthracis spores. According to Iraq, the numbers filled are only estimates.
Filled with aflatoxin 7 Iraq has not provided any documents to support the filling of R-400s with aflatoxin. No evidence of aflatoxin has been found among the remnants recovered at the destruction site. Iraq initially stated that 16 uncoated R-400 but no R-400A bombs were filled with aflatoxin. Later the number was reduced to seven to correspond to the decrease in total numbers of bombs filled. According to Iraq, numbers filled are only estimates.
Other

0

There is no complete account of the agents to fill R-400 weapons. An analysis of all the available evidence does not rule out the possibility that another BW agent was filled into some weapons, either in addition to those declared, or substituting one already declared. The inconsistencies in markings indicating agent type on the R-400 bombs coupled with the lack of evidence on filling, the presence at Al-Walid Airbase of two undeclared R-400A weapons and the frequently changing accounts of Iraqi personnel make it impossible to confirm the BW agents deployed or used for filling purposes.
R-400 Aerial Bombs Destroyed
Empty bombs destroyed 43 Video tape and still photographs of destruction activity are the basis for this number. Not all bombs were visible. Iraq states that none of these bombs was ever filled. Based on the markings on the weapons and other circumstantial evidence this cannot be confirmed. Iraq states that a total of 37 R-400 bombs "intended" for filling with BW agents were destroyed at Al-Muthanna under UNSCOM supervision (26 black-striped and 11 non black-striped). An additional six were claimed to be defective and not filled. These were recovered from the River Euphrates in December 1994.
Filled bombs destroyed 157 Evidence of the destruction of BW bombs was found at Al-Azzizziyah. The total numbers destroyed could not be determined from the remains at Al-Azzizziyah. In addition there is evidence that R-400A bombs carrying BW markings were present at an airfield where no BW weapons were declared. Iraq states, based on a diary, reporting the events, that 157 BW-filled bombs were destroyed at Al-Azzizziyah in July 1991. Evidence that all were indeed BW-filled was not presented.

Aircraft Drop Tanks

48. In September 1995, Iraq declared the existence of two projects concerning the use of aircraft drop-tanks to disseminate BW agents. One employed a Mirage F-1 aircraft, the other a MiG 21. The Mirage F-1 drop-tank project was said to have commenced in November 1990 when a prototype, made from a modified drop-tank, was manufactured and a series of trials undertaken. Following the last trial, just before the Gulf war, the Mirage with the prototype tank attached was left in a shelter at Abou Obeydi Airbase, near Al-Kut. Iraq states the shelter was bombed and the Mirage F-1 and its drop-tank were said to have been destroyed by fire. Three further drop-tanks were modified. This work, which appears to have been straightforward, requiring only a few days' efforts, continued throughout the period of the war at several establishments. The weapons were completed in March 1991. It is stated that these items were destroyed in summer 1991. The remains of three such tanks have been inspected. Iraq's plan was for the modification of 12 tanks in total. Iraq states that only the scarcity of a key component, an electric fuel cock, limited the number to three.

49. The drop-tank project appears to have been pursued with the utmost vigour by Iraq. It seems to have been the only BW weapon system that continued in development after the start of the Gulf war. Two mobile tanks for bulk BW agents, each with a capacity of 1000 litres, were found buried at the Al-Azzizziyah outstation of Abou Obeydi. This raises questions about the state of readiness of this weapon system. Iraq will not discuss the details of concepts of use and flatly refuses to acknowledge the plan for this project.

50. Iraq has claimed for two years that the drop tanks were intended to deliver Bacillus anthracis spores. Bacillus subtilis spores were used as simulant in a test with this intent. In the Vienna TEM Lt. Gen. Amer Al-Saadi reversed this statement by claiming that botulinum toxin was the agent to be used. His technical experts were unable to provide technical information in support of this claim. The availability of agent, and its nature, greatly influence an assessment of the material balance. Four drop tanks would require 8000 litres of agent. The FFCD fails to state which agent was intended to be used.

51. There is no evidence that the prototype weapon and aircraft were destroyed, nor is there sufficient documentary evidence concerning this weapon and its components. The FFCD account is not validated.

Pilotless Aircraft Project

52. The concept was to produce a MIG-21 aircraft that could take off and fly on a preset flight path without a pilot on board. The plane would carry a drop-tank containing BW agent. After a preset time the valves on the tank would open and disseminate the agent. The aircraft would continue to fly until it ran out of fuel. One experiment was undertaken on 10 January 1991 at the Iraqi Air Force Al-Rasheed Airbase. The reason given for dropping the project was the intervention of the 1991 war, expressed as "the situation at that time".

53. Apart from one letter, thanking the project workers, all the information on this matter stems from interviews. However, there is a lack of evidence. The accounts given of the project are credible, when dealing with its technical aspects. When the management of the project, its place in the BW programme and the concepts of use of the weapon are considered, the accounts are contradictory and have changed between 1995 and the summer 1998. The FFCD gives abbreviated details of this project. No mention is made of the intended use of the pilotless aircraft for the dissemination of BW agent.

54. The FFCD account is too brief, considering the apparent intended use of this equipment. There is no clear evidence of the termination of the development of pilotless aircraft for BW dispersal. It is known that such work continues, although for a different stated purpose (targets for anti-aircraft artillery). The attempts to dissociate the MIG-21 project from the development of aircraft spray tanks has not been convincingly explained. The FFCD account is not validated.

55. This table provides a summary of Iraq's declarations concerning fixed wing aircraft spray systems:

FFCD UNSCOM Assessment Comments
Modification of F-1 Drop-Tanks
Drop-tanks produced

4

There is no evidence to corroborate that only four were produced. Interviews indicate that 12 tanks were to be modified. Iraq declares that one Mirage F-1 drop-tank was modified for dissemination of BW agent by 15 January 1991. Subsequently three more were similarly modified during the period of the Gulf war.

F-1 Drop-Tanks Destroyed

Drop-tanks destroyed

4

The original prototype drop-tank is said to have been destroyed by bombing. There is no physical evidence to support this. The remains of the other three drop-tanks were inspected by the Commission. There are extensive piles of damaged aircraft at Abou-Obeydi, however, the remains of the prototype drop-tank and Mirage F-1 fighter carrying it have not been identified among the debris.

Pilotless Aircraft Development

Pilotless MiG 21

1

Interviews generally support the statements on the development of a pilotless MIG-21. It is unclear whether the MIG-21 was intended to carry BW or CW weapons. Interviews suggest that the drop-tank and its delivery aircraft were being developed for both CW and BW. There is no evidence to confirm that the project was dropped before completion. The letter offered as evidence that the project terminated provides no such confirmation.

Aerosol Generators/Helicopter Spray System ("The Zubaidy Device")

56. An aerosol generator for the dispersal of biological warfare agents or toxins was developed by the Technical Research Centre at Salman Pak by modification of helicopter-borne commercial chemical insecticide disseminators. These modified aerosol generators are assessed as suitable for the dissemination of BW agents from helicopters or slow moving fixed-wing aircraft and are referred to as Zubaidy devices. A description was included in the June 1996 FFCD. It did not however cite the number of devices produced nor account for their final disposition. In the current FFCD, the devices are only briefly mentioned. A document has also been submitted by Iraq reporting the successful field-testing of these devices in August 1988 to spray Bacillus subtilis spores. However it was stated at the Vienna biological TEM in March 1998, that Iraq now considers these devices to be inconsequential.

57. The absence of a comprehensive account of the Zubaidy devices including their disposition and supporting evidence is an example of the incompleteness of the current biological FFCD.

58. The following table provides a summary of Iraq's declaration concerning the Aerosol Generators.

FFCD UNSCOM Assessment Comments
Aerosol Generators:

Numbers produced not stated in FFCD.

Iraq claims this device was not effective, but documentation provided by Iraq states that it was successfully field tested to spray bacteria. Experts assess this device as a most effective BW munition. Iraq turned over to UNSCOM developmental devices but not the final tested devices. These remain unaccounted for. From interviews Iraq has acknowledged 12 devices produced. None destroyed by UNSCOM.

59. The Commission has evidence of a parallel development by the Technical Research Centre (TRC) of a similar device, probably for delivery by drones. Iraq officially denies all knowledge about this second device but this denial is inconsistent with indications from interviews. It is unknown whether development of this second device continued to deployment but the possibility exists that it did and that such a weapon system still exists in Iraq.

Other Weapons Systems

60. Cluster Bombs: Iraq has been asked whether cluster munitions, which are inherently a more effective delivery system for BW agents than aerial bombs, were part of the BW programme. On one occasion, an Iraqi representative mentioned that, although cluster munitions were never used in the CW programme, they were part of the BW programme. He later retracted this remark formally. Since then Iraq has strenuously denied that cluster munitions played any part in the BW programme.

61. 122mm Rocket Warheads: The majority of the declared BW field trials carried out by Iraq involved the testing of 122mm rocket warheads. This part of the programme proceeded in an ordered and logical fashion, commencing with static tests of single warheads and culminating with salvoes of rockets charged with BW agent or simulant. There are documents, video tapes and interview information detailing this work. The Iraqi reports on these trials submitted to MIC, point out the success of the system and recommend adoption of this weapon for the delivery of Agents A, B, C and D. Despite the progress made over a period of years, the development of 122mm warheads was said to have been abandoned by August 1990. The 122mm warhead was considered unsuitable by Iraq "for the impending conflict". The full scope of this work, the rationale for the use of these weapons and the seemingly abrupt end of the project have never been satisfactorily explained.

62. Artillery Shells: A single 155mm artillery shell was found at Iraq's main BW production facility Al-Hakam, recovered from the River Euphrates. It was of the same type used for CW agents. It contained water. Another smaller calibre shell was also found. It had been detonated. These shells were said to have been for evaluation. Four similar shells were used in a trial for the dissemination of the BW agent Ricin, . No further evidence has been found. It appears that these trials produced indifferent results, and that, apparently, these projects were not continued.

63. LD-250 Aerial Bomb: Static trials of LD-250 aerial bombs to disperse agents were conducted in 1988. It is likely that further such trials were conducted. These tests were considered successful. Despite this, and the adoption of the weapon for CW agent delivery, it is claimed that no further development occurred.

64. Fragmentation Weapons: Experimental work on the sub-dermal introduction of Clostridium perfringens spores, applicable to fragmentation weapons, was acknowledged by a senior Iraqi worker in the field. He admitted that the work was relevant to fragmentation weapons that are designed to cause gas gangrene. Iraq denies carrying out any developmental work on weapons exploiting this research

65. Land Mines: When Iraq was considering which weapons to use for the dissemination of BW agent, land mines were considered. One of the scientists was sent to Al-Qa'a Qa'a, the explosives factory, to look for types of anti-personnel land mines that could be used for the purpose of filling. He found that there was nothing available suitable for filling with liquid BW agents.

66. 350mm and 1,000mm Calibre SuperGun Projectiles: The Iraqi SuperGun programme was developing long-range projectiles for both 350mm and 1,000mm calibre weapons. The drawings of various designs for the 350mm device, depict a projectile with a guidance and control section, control surfaces on the fins and a payload of around 20 kg. Plans existed for a 1,000mm calibre weapon that would have had a longer range, and a payload greater than 100 kg. Iraq denies that there was any connection between the BW programme and that of the SuperGun. This project, like the BW and CW programmes, was managed solely by MIC. Like the BW project, no objective or planning has been acknowledged. The development of this weapon system was well advanced, with several sites being used and plans prepared for new and more versatile weapons. The intended purpose of this weapon has not been revealed. A long range delivery system, with its guided projectile, capable of delivering relatively modest pay-loads suggests the use of very potent warheads, such as CW or BW agents, or even radioactive material. The range and payload delivery are of a similar order to those of the Al-Hussein. Without a more comprehensive disclosure by Iraq, the possibility that this weapon was being developed for the delivery of a BW payload cannot be ruled out.

BW Agents

67. Bulk warfare agent production appears to be considerably understated by Iraq. Production accounts are incompatible with resources available to Iraq's BW programme, including growth media and fermentor capacity. Production figures in the FFCD remain unsupported from 1987 to 1989 and 1991. The sole supporting document, for 1990, differs from information contained in the FFCD itself. Experts' calculations of possible agent production quantities, either by equipment capacity or by growth media amounts, far exceed Iraq's stated results. Significant periods when the fermentors were claimed not to be utilized are unexplained, especially for a period after August 1990, when Iraq's BW production facilities were ordered to operate at their maximum capacity. Stated low productivity of readily available equipment has not been adequately explained. The idle times for fermentor utilization and low productivity, which are technically not credible, cast doubt on the elemental credibility of the 1997 FFCD.

68. Quantities of each agent (and indeed what agents were placed) placed into munitions are unclear. Similarly, the quantities of bulk agents destroyed can not be verified. The quantities cited by Iraq are deduced and may have little relationship to actual quantities. The place and method of destruction is not established. There is no assurance that bulk agents were not recovered, in some instances, from weapons prior to destruction of the weapons.

69. Iraq has not reported all the known quantities of bacterial growth media that was imported for its BW programme, nor has it accounted credibly for all the media that it has reported. Iraq's declared failed batches are excessive and inconsistent in totality. In production of botulinum toxin, Iraq reported that thioglycollate broth when used at half strength of that recommended by the manufacturer produced acceptable toxin levels. These factors add to the quantity of BW agent that might have been produced by Iraq.

70. Fermentor usage: Iraq has calculated the quantity of agent produced by an assigned frequency and efficiency of fermentor utilization as well as assumed numbers of failed batches of agent production. For the years 1987 to 1989 there are no records to support production and the frequency and efficiency of fermentor operation is inconsistent with the overall information. Additionally, fermentors appear to have been available earlier than stated. For example, the fermentation line acquired from the Veterinary Research Laboratories (VRL) at Abu Ghraib is stated to have been acquired only late in 1988 when it was moved and installed at Al-Hakam. However, documents provided by Iraq indicated consideration of its use in situ at the VRL and spare parts for this line were ordered by the BW programme beginning late May 1988.

71. Fermentor idle times: Relative to available resources, Iraq has declared less than expected production of bulk agents. Declared quantities are based on limited availability of capability such as fermentors and a shortage of specific bacterial growth components. As a proof for the limited production output Iraq claims, fermentors were not used for considerable periods of time. For example, Iraq claims lack of spare parts and a needed overhaul of some fermentors as an explanation for "idle periods". In fact, UNSCOM has evidence indicating spare parts were available. There is no corroborating documentation to support the less than optimal bulk agent production levels reported in the FFCD. The low production figures are particularly difficult to accept without supporting evidence during a period in mid-1990, when allegedly maximum production was ordered by Lt. Gen. Hussein Kamel Hassan.

72. Clostridium botulinum toxin, Agent A: It is not possible to verify the amount of Agent A produced, placed into munitions or otherwise consumed as presented in the 1997 FFCD. Various accounts of the destruction of bulk Agent A were made in both the FFCD and by independent Iraqi testimony. There is insufficient documentation to verify either the quantity of Agent A destroyed or whether remaining bulk agent in summer 1991was destroyed. Methodology employed in destruction and location of destruction, similarly, can not be determined.

73. Bacillus anthracis spores, Agent B: It is not possible to verify the amount of Agent B placed into munitions or otherwise consumed as presented in the 1997 FFCD. UNSCOM cannot exclude the production of Agent B from facilities other than Al-Hakam based on analytical evidence of Bacillus anthracis spores in equipment (one fermentor and two tanks) located at the FMD facility at Daura. An Iraqi explanation for this finding presented during the inspection was not credible. Overall, bulk agent production quantities and the location of production of Agent B cannot be determined because of the lack of sufficient supporting documentation.

74. There are various accounts derived from both the FFCD and independent Iraqi testimony concerning the destruction of bulk Agent B. Laboratory analysis of samples obtained at Al-Hakam has demonstrated the presence of viable Bacillus anthracis spores at an alleged bulk agent disposal site. Iraqi experts cannot explain adequately how viable Bacillus anthracis spores could have been present at this site. The inactivation procedures described by Iraq for the "excess" bulk agent would preclude any live agents remaining following that inactivation procedure. The explanation provided by Iraq, i.e., endemic contamination is not credible. An alternative explanation proposed by Iraq that the viable organisms came from material discarded during agent production operations in prior years was contradicted by earlier information provided by Iraq. Further, that explanation, if true, would preclude verification of the destruction of bulk agents. There is insufficient documentation to verify either the quantity of Agent B destroyed or whether remaining bulk agent was destroyed. Methodology employed in destruction and location of destruction, similarly, can not be determined.

75. Aflatoxin, Agent C: Declared production of the BW agent aflatoxin could not have occurred using the process stated by Iraq. In its June 1996 FFCD, Iraq claimed that, in September 1990, it had zero balance on hand, having produced only 40 litres of aflatoxin that were nearly all consumed by weapons field trials. Assessments by the Commission show that the quantity produced would have been inadequate for the declared number of field trials. Iraq claimed to have produced 1,782 litres of aflatoxin for filling weapons from 1 October to 31 December 1990 and continued the production two weeks into January 1991 for an additional 119 litres. Taking into account the technology, organization and production limitations including facilities, equipment, and personnel available, such large production volumes are doubtful. The impact on production of aflatoxin of mixing CS, CN, and smut spores with aflatoxin is not clear. A new account of aflatoxin production and weaponization is contained in the September 1997 FFCD, but the changes are not adequately explained or supported by documentary evidence. The new account is no more credible than the June 1996 version. Iraq has not offered any credible explanations to support its statements other than the 1990 Al-Hakam report that cites 2200 litres produced without the details of where and how it was produced. During an inspection in July 1998, Iraq tried to establish among themselves the figures of aflatoxin produced, indicative of Iraq's uncertainty with aflatoxin production quantities.

76. It is not possible to verify the amount of Agent C placed into munitions or warheads or otherwise consumed as presented in the 1997 FFCD. The question remains open regarding the aim and reasons of the choice of aflatoxin as an agent for BW. It is not clear what Iraq expected to obtain as a result of its use. One document refers to military requirements to produce liver cancer using aflatoxin and the efficacy against military and civilian targets. Understanding Iraq's concept of use for this agent may enhance the credibility of otherwise unsupported statements.

77. Iraq has indicated that the production data in the FFCD were based on recollection and back calculations due to a lack of production records.

78. Clostridium perfringens spores, Agent G: Stated amounts of Agent G produced, used, consumed or destroyed cannot be verified because of insufficient documentation. Iraq maintains that small quantities of Agent G, 340 litres, were produced because of limited availability of personnel and lack of critical growth media components. There is no documentation to support this, and the Commission has information which counters the allegation that growth media components represented a limitation. Iraq has not provided a credible material balance accounting for its known Peptone acquisitions by the BW programme. Peptone is a growth media component which appears to have been only used in the production of perfringens spores by the BW group.

79. Smut, Agent D: It is not possible to verify the amount of Agent D produced, used or consumed owing to a lack of sufficient documentation from Iraq.

80. Iraq had stated it produced smut coated with aflatoxin, but neither this statement, nor the destruction of bulk Agent D can be verified.

81. Bacillus subtilis spores, simulant for Bacillus anthracis spores dissemination: Stated amounts of Bacillus subtilis spores produced can not be verified. Stated quantities and time of production appear to be figures contrived to be compatible with the number and dates of field trials reported in the FFCD. Interview information and documentary evidence contradict Iraq's presentation of field trials conducted. Because of this artificial system for deriving production numbers, each additional trial that was not included in Iraq's arbitrary calculations, add to the disparity in quantities of simulant produced.

82. Bacillus thuringiensis spores, simulant for Bacillus anthracis spores drying: Iraq cites the production of ~50 litres of Bacillus thuringiensis (Bt) spores in March 1990 for drying studies which are claimed not to have been done because of a failure to obtain a particular spray dryer. However, Bt spores were taken by Iraq to the supplier in December 1989 to test on the spray dryer it planned to acquire. The quantity of Bt spores produced can not be verified.

83. Ricin: Iraq asserts that 10 litres of ricin were produced from 100 kg of castor beans and that this quantity was used in a field trial using 155mm artillery shells in November 1990. Documents obtained during an inspection in 1997 indicate that far more than 100 kg of castor beans were collected and processed in October, November 1990. If the Commission had a clear understanding of Iraq's objective for including Ricin in its programme, then perhaps much of the uncertainties surrounding Ricin could be resolved.

84. Other agents produced: It is not possible to determine if bacterial or toxin agents other than those stated in the 1997 FFCD were produced. Seed stocks of other agents were actively sought for and obtained by Iraq's BW programme.

85. Drying of agent: It is not possible to determine if bacterial and toxin agents produced were dried to enhance storage stability or for reasons of dissemination. This issue is of significance because Iraq actively procured drying equipment and obtained training in the use of such equipment for key personnel. Drying studies on bacteria started in 1974.

The following table provides a summary of Iraq's declarations concerning the bulk agent production (as active agent), filling and destruction (unless stated otherwise).

FFCD UNSCOM Assessment Comments
Botulinum toxin produced (10 to 20-fold concentrated)

19180 litres

Insufficient documents to support quantities. Equipment and unaccounted for growth media do not support the figures. Quantities could be more at least double the stated amount. Iraq bases this estimate on 1990 "Al-Hakam" report with extrapolations into 1989 and earlier.
Botulinum toxin filled

10820 litres

Nothing to support statements. Iraq acknowledges numbers are estimates. Number of filled munitions could not be verified. See weapons tables. Figure is based on the alleged numbers of munitions filled; 100 R-400 bombs, each filled with 85 litres, and 16 Al-Hussein missile warheads, each filled with 145 litres.
Botulinum toxin used for field trials

499-569 litres

Stated field trials can not be verified as accurate, hence quantities of bulk agent consumed can not be verified. Quantities are based on unsupported number of field trials conducted.
Botulinum toxin wasted during handling

118 litres56

Nothing to support statements. Interviews differ with these estimates in ways that cast doubt in the account of filling. Quantities are estimates. There is no basis for assessment of wastage.
Botulinum toxin destroyed

7665 or 7735 litres

Nothing to support statements as to quantities destroyed and where and when destroyed. Interviews differ from official declaration. Quantities are contrived estimates. Stated as unilaterally destroyed in July 1991.
Bacillus anthracis spores produced (10-fold concentrated)

8445 litres

Insufficient documents to support quantities. Equipment and unaccounted for growth media does not support the figures. Quantities produced could be at least 3 times greater than stated. Iraq bases this estimate on 1990 "Al-Hakam" report with extrapolations into 1989 and earlier.
Bacillus anthracis spores filled

4975 litres

Nothing to support statements. Iraq acknowledges numbers are estimates. Number of filled munitions could not be verified. See weapons tables. Quantities are contrived estimates. Figure is based on the alleged numbers of munitions filled;

5 Al-Hussein missile war-heads, each filled with 145 litres, and 50 R-400 bombs, each filled with 85 litres.

Bacillus anthracis spores used for field trials

None

No evidence has been presented to indicate whether or not Bacillus anthracis spores were ever tested. Iraq states that no field trials were conducted with Bacillus anthracis spores; only a simulant was used.
Bacillus anthracis spores wasted

52.5 litres58

Nothing to support statements. Interviews differ with these estimates in ways that cast doubt on the account of filling. Quantities are estimates.
Bacillus anthracis spores destroyed

3412 litres

Nothing to support statements as to quantities destroyed and where and when destroyed. Interviews differ from official declaration. Quantities are contrived estimates. Stated as unilaterally destroyed in 1991.
Aflatoxin produced

2200 litres

Facilities, equipment, and personnel do not support production statements. Experts assessments are that Iraq could not have produced the quantity of aflatoxin claimed, given the equipment, facilities and personnel stated by Iraq. Iraq bases the production of 2200 litres on the 1990 Al-Hakam report.
Aflatoxin filled

1120 litres

Nothing to support statements. Iraq acknowledges numbers are estimates. Number of filled munitions could not be verified. See weapons tables. Figure is based on the alleged numbers of munitions filled;

7 R-400 bombs, each filled with 80 litres and 4 Al- Hussein missile warheads, each filled with 140 litres.

Aflatoxin used for field trials

231-301 litres

Stated field trials can not be verified as accurate, hence quantities consumed can not be verified. Quantities are based on an unsubstantiated number of field trials conducted.
Aflatoxin wasted

30.5 litres59

Nothing to support statements. Interviews indicate wastage was much higher. Interviews differ with these estimates in ways that cast doubt on the account of filling. Quantities are estimates.
Aflatoxin destroyed

900 or 970 litres

Nothing to support statements as to quantities destroyed and where and when destroyed. Interviews differ from official declaration. Quantities are contrived. Stated as unilaterally destroyed in 1991.
Clostridium perfringens spores produced (10-fold concentrated)

340 litres

Insufficient documents to support quantities. Equipment and unaccounted for growth media does not support the figures. Quantities produced could be at least 15 times the quantity stated. Iraq bases the 340 litres estimate on 1990 Al-Hakam report.
Clostridium perfringens spores filled

None

Nothing to support statements. Stated quantities produced are insufficient for weaponization.
Clostridium perfringens spores wasted

None

Nothing to support statements. No filling, ergo no wastage.
Clostridium perfringens spores destroyed

338 litres

Nothing to support statements as to quantities destroyed and where and when destroyed. Quantities are estimates.
Ricin produced

10 litres

Documents and interviews do not support account. Based on an inaccurate account of Ricin activity.
Ricin used for field trials

10 litres

Nothing to support statements. Based on an inaccurate account of Ricin activity.
Wheat Cover Smut

Not quantifiable

Nothing to support statements. The total quantities remaining are claimed to have been destroyed in July 1991.

86. Mobile storage tanks. Eight mobile double-jacketed tanks were part of the VRL line transferred to Al Hakam. In addition, Iraq has acknowledged the production of an additional 39 mobile tanks by SEHEE. These tanks were used to transfer agent between production and filling or deployment sites and for storage of agent. Owing to their properties, they can be used for long-term storage of agent under controlled conditions or modified to function as fermentors suitable for the production of BW agent.

FFCD UNSCOM Assessment Comments
Mobile tanks acquired.

47

39 indigenously produced at SEHEE

8 from VRL

1990 Al-Hakam report refers to 70 being produced. Serial # 37 seen on remnants. 8 tanks are known to come from the VRL line. 39 tanks stated to have been manufactured by the Heavy Engineering establishment at Daura is based on a document in which SEHEE billed PC2/3 39ss vats (not specified) and 8 came from the VRL Vaccine line. The 1990 "Al Hakam" report cites 70 1m3 tanks.
Mobile tanks destroyed.

Unknown

Remnants of 2 tanks were found at Al-Azzizziyah. Among other remnants turned over to UNSCOM, were the remains of approximately 22 tanks (4 tanks of the VRL line). The number has not been stated in the 1997 FFCD. In the 1996 FFCD, 2 were said to have been destroyed at Al-Azzizziyah, and 22 were cut-up and disposed at Iskanderiah. Thus 20+ tanks remain unaccounted for.

Bacterial Growth Media

Media Acquisition

87. In the early days of Iraq's BW programme based at Al-Muthanna and Salman Pak small quantities (in the order of tens of kilograms) of media of various types were purchased by Iraq through the State Establishment for Pesticide Production (SEPP) for research and pilot scale production for BW agent. . The media, some tens of kilograms, for the initial production runs of botulinum toxin at Taji in early 1988 is stated in the FFCD to have been acquired locally but the details are not provided and it is unknown whether the amounts declared represent the totality of the amount actually acquired. No supporting documentation is provided by Iraq for any of the acquisitions referred to above.

88. In late 1987 and early 1988, enquiries, and ultimately orders, were made for large purchases of media. Iraq acknowledges importing over 40 tons of media in 1988 and although no documentation is provided by Iraq. The Commission can confirm the four largest orders listed in the FFCD. However, the Commission has information that shows that the bulk media acquisitions as declared by Iraq are an incomplete listing and that further amounts in excess of 600 kg were imported and have not been declared. Furthermore, some of this undeclared media was received by Iraq prior to May 1988, suggesting that the statement in the FFCD that the Taji fermentor was shut down between April and July 1988 "due to the non availability of culture media", is incorrect.

89. Given the incompleteness of documentation regarding media acquisitions, particularly for local purchases, and evidence indicating that imports have been understated, the Commission cannot verify Iraq's declaration of media acquisition.

Media Used In Production

90. The account in the FFCD of media consumed in the production of BW agent is acknowledged by Iraq to be a mathematical calculation based on a) the claimed quantity of agent produced and b) the estimate of failed production batches that would have also consumed media. In addition other quantities are said to have been discarded during the production process (Iraq has stated this to be due to spoilage). Other than the 1990 Al-Hakam report outlining agent production at Al-Hakam for that year, Iraq has provided no records or other documentation to support its estimates.

91. Iraq had stated that in June 1991, before the arrival of the first UNSCOM BW team, the media remaining at Al-Hakam was transferred to the State Company for Drugs and Medical Appliances Marketing (otherwise known as Kimadia) within the Ministry of Health. Iraq has explained that the role of Kimadia was to provide a cover story for media that had been consumed in the weapons programme. Subsequently documentation was drawn up to indicate that media consumed in the programme had been sent to hospitals in outlying regions where riots had occurred and hence would no longer be traceable.

92. Thus the difference between the quantity of media imported and that remaining in stock in 1991, i.e., the shortfall, accounted for by Kimadia, represents the media consumed in the Iraqi BW programme between 1988 and June 1991. This provides a snapshot in time immediately following the stated end of the BW programme and potentially is a figure that can be used in the verification of Iraq's FFCD. The picture however became confused in July 1998 when Iraq stated that not all the media left over from the programme was transferred to Kimadia, but certain amounts (undocumented) were retained at Al-Hakam. Thus the Kimadia "shortfall" figures would reflect media consumed in the programme plus any remaining at Al-Hakam in 1991. If this is the case then the Kimadia documents become less useful as a verification tool. Furthermore some of the data from the Kimadia documents is in conflict with the FFCD. In discussions with Iraq during an inspection in December 1998, the issue of what quantity of media remained in 1991, became more unsettled. Iraq submitted "copies of documents" that casts further doubt on the usefulness of the "Kimadia documents" for verification. The "copies" provided during this inspection cast further doubt, however, may not be valid copies.

93. As noted above, Iraq has recently stated that in 1991 some of the media was transferred from Al-Hakam to Kimadia. What is unclear and has not been explained to the Commission is the basis for the retention of media at Al-Hakam. Peptone, for example, which had been used for the production of Agent G had no apparent role at Al-Hakam in 1991 if the BW programme had been abandoned. Also Kimadia had "covered" for all the media remaining in 1991 and therefore any media remaining at Al-Hakam had been written off and was untraceable. It is not clear why this media was not accountable in the Iraqi system if indeed Al-Hakam had been converted to legitimate purposes in 1991.

94. In summary the figures presented in the FFCD for media consumed in the production of BW agent are a theoretical calculation, have little supporting evidence and do not account for all media acquired. This current account therefore can not be verified.

Media Lost, Damaged or Destroyed

95. The FFCD identifies two losses of media prior to the first UNSCOM BW inspection. The first was said to have occurred during the evacuation of Al-Hakam and the relocation of its headquarters to Al-Asma'a school about 30 km away. It is stated that equipment important to the functioning of departments was relocated to the school on 22-23 January 1991. Included was an unknown quantity of media of various, but unidentified, types. At some time before the return to Al-Hakam in May 1991, Iraq claims the school was broken into and some items stolen and damaged including some of the media.

96. Iraq states that no investigation of the loss occurred and that the amounts and types of media cannot now be recalled. The figures in the material balance table of the FFCD indicate that over 900 kg of media were "lost" including over 700 kg of peptone which is relevant to Clostridium perfringens (Agent G) production. There would appear to be no basis for these figures other than a calculation designed to account for all the media i.e. so that the material balance equals zero.

97. The Commission has reason to believe that no media was stored at the schoolhouse and that none was stolen.

98. A second loss of media is stated to have occurred during the clean up of Al-Hakam prior to UNSCOM's arrival in 1991. This was said to be an unquantified amount of media damaged during the evacuation and it is stated to have been burnt and buried at a site adjacent to Al-Hakam. This site was visited by the Commission's inspection team in 1995 and it was confirmed that media was burnt and buried there but the types and quantities are not known. During the inspection in December 1998, Iraq presented several improbable accounts of media lost, damaged and stolen that defies credibility. In conclusion therefore, the Iraqi account of lost media cannot be verified and in the case of the school house media, it is probably not true.

99. During the destruction of Al-Hakam in 1996, 22 tons of media were collected from several facilities and destroyed under the Commission supervision. However some of the 22 tons (unquantifiable) probably came from sources external to the BW programme i.e. some of the media from the original orders is still unaccounted for. It is also uncertain whether all the media acquired for the programme has been identified. Thus there is little confidence that all the media associated with the programme has been located and destroyed.

Material Balance

100. The following tables provides a summary of Iraq's material balance declarations for growth media acquisition, usage, consumption and disposal by four key media types: casein, thioglycollate broth, yeast extract and peptone.

FFCD UNSCOM Assessment Comments

Casein

Casein acquired.*

17554kg

Fails to include several smaller but significant orders acquired for the BW programme. Derived principally from 3 large orders in 1988.
Casein used for botulinum toxin production.

7074 kg

Production quantities are estimates and consequently media consumption figures are estimates that are based on estimates. No supporting data other than the production figures for 1990.
Casein lost and wasted.**

145 kg

Not confirmed but represents 2% of that stated as used and does not therefore seem unreasonable. Unsupported statement.
Casein remaining in 1991.

10335 kg

The 10335 kg figure appears to be based on a 1995 inventory made by Iraq and may have little relation to the actual amount in 1991. Unconfirmed. Iraq also states 970kg remained unused in 1991 at Hakam. No supporting evidence for this
Casein destroyed in 1996.

Not specifically stated: implied 10335kg

Iraq and UNSCOM inventories differ, but for casein, in general agreement. Destroyed under UNSCOM's supervision.

Thioglycollate Broth

Thioglycollate broth acquired.*

6036 kg

Fails to account for additional smaller but significant orders acquired for the BW programme. Derived principally from 1 large order in 1988.
Thioglycollate used for botulinum toxin production.

4130 kg

Production quantities are estimates and consequently media consumption figures are estimates that are based on estimates. No supporting data, other than the production figures for 1990.
Thioglycollate lost and wasted**

58 kg

Not confirmed, but about 1% of total stated to be used and therefore not unreasonable. Unsupported statement.
Thioglycollate remaining in 1991.

1848 kg

The 1848 kg figure appears to be based on a 1995 inventory and may have little relation to the actual amount remaining in 1991. Unconfirmed. No supporting documentation
Thioglycollate destroyed in 1996.Not specifically stated: implied 1848 kg Iraq's and UNSCOM's inventories in 1995 differ, but for Thioglycollate, in general agreement. Destroyed under UNSCOM's supervision.

Yeast Extract

Yeast Extract acquired.*

7070 kg

Fails to include additional smaller but significant orders acquired for the BW programme. Based on 3 large orders and 70 kg from an unidentified internal source.
Yeast extract used for agent production.

Botulinum toxin

1768 kg

Bacillus anthracis spores

185 kg

Perfringens

11 kg

Production quantities are estimates and consequently media consumption figures are estimates that are based on estimates. No supporting data other than the production figures for 1990. Iraq also stated 185 kg used in SCP production post 1991.
Yeast extract lost and wasted**.

15kg

Represents less than 1% of stated usage and not unreasonable. Unsupported statement
Yeast extract remaining in 1991.

5090kg

The 5090 kg figure appears to be based on a 1995 inventory and may have little relation to the actual amount in 1991. Iraq has also stated (unconfirmed) that 4000 kg was retained at Al-Hakam in 1991 and 1807 kg sent to Kimadia, total 5807 kg: this is inconsistent with the FFCD. No supporting evidence for the quantity retained at Al-Hakam in 1991.
Yeast extract destroyed in 1996.

Not specifically stated: implied 4942 kg

Iraq's and UNSCOM's inventories in 1995 differ greatly for yeast extract. The majority of containers had been opened and the inventory was complicated by mis-labelled media, other sources of media possibly being added and duplicate labels.

Destroyed under UNSCOM's supervision.

Peptone

Peptone acquired.

1500 kg

Does not include several smaller but significant orders including one for 100 kg peptone. Quantity is based on a single large order.
Peptone used for Clostridium perfringens production.

45 kg

Production quantities are estimates and consequently media consumption figures are estimates that are based on estimates. No supporting data other than the production figures for 1990. Iraq also stated 125 kg used for civilian work post 1991.
Peptone lost and wasted**.

705 kg

The basis for the figure appears to be a calculation designed to bring the material balance to zero. Unsupported by evidence. The bulk of the 705 kg has been presented as having been stolen from an evacuation site. UNSCOM has reason to believe this is untrue.
Peptone remaining in 1991.

750 kg.

The 750 kg figure appears to be based on a 1995 inventory and appears to have little relation to the actual amount remaining in 1991. Unconfirmed. Additional quantities of peptone were acquired after 1991 from the "local market".
Peptone destroyed in 1996.

Not specifically stated: implied 625 kg

Iraq's and UNSCOM's inventories in 1995 differ greatly for peptone. The majority of containers had been opened and the inventory was complicated by mis-labelled media, other sources of media possibly being added and duplicate labels. Destroyed under UNSCOM's supervision.

101. * Iraq has not reported all the media including casein, Thioglycollate broth, yeast extract, and peptone known by the Commission to have been imported for the BW programme. In response Iraq has suggested that the Commission must be confusing media ordered for the Forensic Laboratory with that ordered for the BW programme since both organizations used the same procurement system. If this is so, it implies that Forensic Laboratory had large quantities of media. However the purpose for this and its present whereabouts have not been declared.

102. ** The "lost" media cited in the FFCD includes media that was wasted during production or handling e.g., by spoilage, and media said to have been lost or stolen during the relocation of the headquarters. There is no further breakdown of these figures so that it is not possible to establish, for example, what media may have been lost through handling errors and what may have been stolen.

Assessment of Material Balance for Bacterial Growth Media

103. The material balance pertaining to media cannot be established. There are several factors which introduce uncertainty. On imports, Iraq's declaration understates the amount by at least 600 kg. Furthermore there is no documentation for the quantities of media said to have been acquired locally, nor any evidence whether this was the total amount. On media consumed, Iraq acknowledges that the figures it presents are derived from estimates of the quantity of agent produced. Since there is little supporting documentation relating to the quantities of agents produced, the amount of each type of media consumed carries similar uncertainties. On losses, Iraq's account of substantial amounts of media said to be lost during the evacuation of Al-Hakam cannot be quantified and furthermore the account of the theft of media from the school house, is probably untrue. The only fixed point in the material balance equation for bacterial growth media is the amount of imported media. Some more data can be derived from the amount of media destroyed by the Commission in 1996. However in relation to yeast extract and peptone there is considerable uncertainty in the destruction of the media. The majority of containers had been previously opened by Iraq and the Commission's assessment of their contents was complicated by mis-labelled media, other sources of media possibly being added and duplicate labels. In particular for peptone, the Commission's assessment of the media destroyed varies between 200 and 470 kg depending on the assumptions made with regard to labelling. This compares with 625 kg implied in the FFCD as having been destroyed. For all the above reasons, the material balance for bacterial growth media cannot be verified.

104. Although a material balance cannot be established, an estimate can be made of minimum amounts of media still unaccounted for. As discussed above, the Commission is aware of additional quantities imported by Iraq. If the quantity of media declared by Iraq to have been consumed and lost is added to the amount of media destroyed by the Commission, and then this addition compared with the amount imported, a minimum figure for media unaccounted for can be derived. This will be a minimum figure because there may be additional quantities of media imported of which the Commission is unaware, and it also relies on the estimates in Iraq's declaration some of which are not accurate.

105. The following table gives the Commission's estimate of key media types unaccounted for.

Media

Minimum unaccounted for (kg)

Remarks

Casein 460 Sufficient for the production of 1200 litres of concentrated botulinum toxin (depending on availability of other components including yeast extract). This would represent an additional 6% of that which has already been declared by Iraq.
Thioglycollate broth 80 A relatively small discrepancy but the estimate depends on the reliability of Iraqi estimates of quantity consumed or lost during the production of botulinum toxin.
Yeast Extract 520 This minimum estimate is uncertain and is likely to be much higher. It is based on a liberal assessment of the contents of many opened and irregularly marked containers. However this minimum figure is sufficient to produce 26000 litres of Bacillus anthracis spores or over 3 times the amount declared by Iraq.
Peptone 1100 Iraq states that about 700 kg of peptone was stolen. UNSCOM has reason to believe this is not true and therefore the estimate includes the entire amount not adequately accounted for. It is sufficient to produce 5500 litres of concentrated perfringens agent or about 16 times the amount declared by Iraq.

106. As evident from the tables the greatest concern is with unaccounted amounts yeast extract and peptone. Although the expiry date for this media would have passed, advice from the manufacturers is that given appropriate storage conditions, particularly away from moisture, the media would still be usable today. The Commission has no information regarding its fate, whether it was retained or used to produce additional undeclared BW agent. The amounts that are "missing" however are significant and would be sufficient to produce quantities of agent comparable to that already declared by Iraq.

Material Balance

107. The most important elements of the FFCD are those related to material balance. That is weapons, filling of munitions, production of munitions, production of types and quantities of BW agents, acquisitions of growth media, supplies, equipment, and other material for the programme; bulk agents, munition and weapon destruction.

108. Establishing a material balance consists of determining the input materials and the output materials. In the case of biological weapons, the input materials are the bulk agents and munitions and the output material are the filled BW weapons. In turn, the input materials for bulk agents are the growth media components and the output materials are the bulk agents.

109. The quantities of bulk agent filled into munitions and allocation of munitions to agents, either by type or number for R-400 bombs or for Al-Hussein warheads cannot be determined from the information provided by Iraq. The munitions available for the BW programme cannot be verified. The lack of adequate documentation prevent the verification of the munitions available for the BW programme.

110. There is no documentation to indicate the number of munitions filled with BW agents. Nor, is there any adequate documentation to support the account of the destruction of the weapons, unfilled munitions and bulk agent.

111. Bulk BW agent must be considered to be a weapon. In addition to the munitions, Iraq developed two types of aerosol dissemination devices that would use bulk agents - the modified drop tank and the aerosol device for slow moving aircraft. There are no production records or production documents to support the stated bulk agent production. The input material for this production is the respective growth media, which is not accurately reported. Production quantities of bulk agent are acknowledged to be estimates and stated media consumption are estimates, based on these estimates. Production quantities of the four types of agents declared by Iraq as produced in bulk cannot be verified.

112. As a result of the above for each of the critical elements of the material balance, Iraq's current account in the FFCD cannot be verified.

113. Determining the number of weapons destroyed is very important but, without knowing the quantity of munitions produced and allocated to BW, determining the quantity destroyed does little to help verify that all weapons have been destroyed, for which documentation has not been provided.

114. In July 1998 international biological experts reviewed with Iraq, at the request of ist Deputy Prime Minister, its biological FFCD, specifically addressing material balance as outlined above. On the material balances for weapons, agents and media the team came to the following conclusions:

Weapons

  • None of the subcomponents of the material balance for R-400 bombs (production, filling, destruction of filled and unfilled bombs) could be verified.
  • None of the subcomponents of the material balance for Al-Hussein warheads (production, filling, destruction of warheads) could be verified.
  • The account in the FFCD on modified drop tanks and the Zubaidy spray device could not be verified.
  • Agents

  • None of the subcomponents of the Clostridium botulinum toxin material balance (production, filling, losses and destruction) could be verified.
  • None of the subcomponents of the Bacillus anthracis spores material balance (production, filling, losses and destruction) could be verified.
  • None of the subcomponents of the aflatoxin material balance (production, filling, losses and destruction) could be verified.
  • None of the subcomponents of the Clostridium perfringens spores material balance (production, losses and destruction) could be verified.
  • None of the subcomponents of the wheat smut material balance (production, losses and destruction) could be verified.
  • Media

  • None of the subcomponents of the media material balance (acquisition, consumption, losses and destruction) could be verified.
  • 115. In its accounting for various BW weapons-programme-related elements, the Commission has achieved various levels of confidence, depending on the quality of information; documentary, physical, and personal testimony provided by Iraq; and the correlation of this information with other information derived from Iraq, information provided by its former suppliers, or otherwise obtained by the Commission.

    116. The Commission has a degree of confidence in the accounting for some proscribed items which were presented by Iraq for verification and disposal. This includes, for example: the destruction of buildings, and equipment at Al-Hakam, the destruction of large quantities of growth media acquired for the programme; and evidence that R-400 aerial bombs and Al-Hussein warheads contained BW agents and consequently that Bacillus anthracis spores and botulinum toxin were indeed weaponized.

    117. The Commission has less confidence in the accounting for proscribed items declared by Iraq as having been unilaterally destroyed. These include, for example: the number and fill of R-400 aerial bombs destroyed at Al-Azzizziyah; the number and fill of BW Al-Hussein warheads destroyed; and the fate of the agent to be used with drop tanks.

    118. The Commission has little or no confidence in the accounting for proscribed items for which physical evidence is lacking or inconclusive, documentation is sparse or non-existent, and coherence and consistency is lacking. These include, for example: quantities and types of munitions available for BW filling; quantities and types of munitions filled with BW agents; quantities and type of bulk agents produced; quantities of bulk agents used in filling; quantities of bulk agents destroyed; quantities of growth media acquired for the programme; quantities of growth media used/consumed; and when or whether the programme ended. In addition the Commission has no confidence that all bulk agents have been destroyed; that no BW munitions or weapons remain in Iraq; and that a BW capability does not exist in Iraq.

    119. Several other outstanding issues also remain. These issues are related: to the scope and extent of R&D activities; the acquisition of supplies and equipment; the involvement of military and other agencies in the BW programme; and deception associated with the concealment of the BW programme.

    STATUS OF VERIFICATION IN THE AREA OF OTHER COMPONENTS OF IRAQ'S BIOLOGICAL WARFARE PROGRAMME

    120. Iraq, under SCR 687 (1991), is required to declare the locations, amounts and types of all biological weapons and all stocks of agents and all related subsystems and components and all research, development, support and manufacturing facilities. In SCR 707 (1991) this requirement was reaffirmed and the Council demanded that Iraq provide a full, final and complete disclosure on all areas related to its BW programme. Part I of this status report reviews those elements of the FFCD that are directly relevant to a material balance. Part II reviews additional elements of the FFCD. The biological TEM conducted in Vienna in 1998 indicated the significance of those issues and it was stated in the expert report: "The FFCD also does not provide a clear understanding of the current status of the BW programme or wether, or when, it was terminated." In April 1998, the Commission's report to the Security Council (S/1998/223) further underlined the significance of these issues by listing the history, the organization, acquisition and research and development among the priority issues to be resolved with regard to the proscribed biological weapons programme.

    Other Acquisition

    121. Iraq has failed to include in its FFCD all the acquisitions of munitions, equipment, media and agents acquired for or used in its BW programme. Iraq has not included all its acquisition of growth media for production purposes which for the four principal components are covered in this report under Part I, para 3. Iraq has not acknowledged all its acquisition of media used in R&D as well as that used in the seed fermenters during production of bulk agents. Neither has Iraq reported all its acquisition of equipment and micro-organisms, nor has Iraq declared all the agencies and individuals involved in that process. Iraq has not provided an adequate account of materials and equipment acquisition. Further, Iraq has failed to provide adequate answers regarding its BW procurement network including the Arabian Trading Company, and other front companies. A complete understanding of acquisition is essential to defining a material balance for Iraq's BW programme.

    122. The FFCD does not contain all imports for Iraq's BW programme known to the Commission, although Iraq claims that all imports for the BW programme were reported. The basis which Iraq claims it used in the FFCD for determining what imports by Iraq to include or exclude among the declared acquisitions was shown not be sound. Thus acquisitions, as measured by the number of orders including Letters of Credit (LCs) and cash deals through attachés at Iraq's Embassies overseas, are substantially under-reported. Without a complete accounting of all BW programme acquisitions, a material balance is not possible.

    123. LCs and cash deals for such items as rotary evaporators, glassware, oven sterilizers, and Petrie dishes, are omitted from items attributed to the programme.

    124. Not all strains of micro-organisms that were acquired bu\y Iraq are included nor are all attempted acquisitions of strains included. The FFCD contains only the Vollum strain of Bacillus anthracis spores to be obtained by TSMID, in 1989, but in 1988 an Iraqi scientist involved in the BW programme had tried to obtain known BW and other virulent Bacillus anthracis spores strains from outside Iraq. All local acquisitions of strains are not included in the FFCD. Further, the fungal and viral strains acquired are not reported in the FFCD.

    125. The media listing is incomplete in that Iraq fails to consider several Letters of Credit and cash deals related to media imports; some of these orders relate to media or media components used in production but other orders relate to media used in R&D and for seed fermenters used during the production process. Media acquisition during the time of the BW programme at Al-Muthanna are understated as well.

    126. There is inadequate or in some cases no supportive evidence for munitions acquisition, both for weaponization and for field trials. Although the account of the acquisition of materials for the aerosol generator (Zubaidy device) was incomplete in the 1996 FFCD, much of the information presented in that version has been intentionally omitted in the 1997 FFCD.

    History of Iraq's BW Programme

    127. Iraq is required to provide a comprehensive account of the history of its BW programme. This may appear peripheral to disarmament and to material balance issues. But lacking documentary or physical evidence to establish a material balance, other elements of the Iraqi BW programme become essential as tools for verification. The history of the Iraqi BW programme is certainly an element of the FFCD, which, if correctly declared, would facilitate verification.

    128. The introduction and chronology presentation of Iraq's BW programme encompasses only a part of the programme, is inaccurate with respect to dates and fails to provide an insight into the decision making process which facilitated its evolution. The account misleads because it presents the programme as an entity which came to fruition in 1990 whereas in reality it was a programme planned to reach maturity some time in the mid/late 1990s. The account also fails to provide any perspective to the programme merely listing a miscellany of chronological events linked only by time rather than requirement, strategic planning, or military utility. As such there is no continuity to the account which limits the Commission's understanding of the BW programme.

    129. Iraq claims that the programme started in 1974 by Presidential decree and by the establishment of the Al-Hazen Institute. Interview evidence shows that consideration of a programme was earlier, as evidenced by the establishment of a functional purpose-built scientific research complex by mid 1974. Planning, design and construction of such a complex would had to have started at least in 1973 with concepts developed earlier. The affiliation of the Institute is not defined other than to a "State Security Organization".

    130. The Al-Hazen Institute terminated on 16 January 1979 not 1978, as declared, because of fraud by the Chairman (Major Ghazan Ibrahim, not stated in the FFCD) and some senior staff, not for reasons of inadequacy of the facility, nor inability to make scientific progress as claimed by Iraq.

    131. Before the apparent "resurrection" of the programme in 1985 work continued at Al-Salman to create resource for biological purposes including buildings established for the Institute including an animal house. Prof. Nasser Hindawi submitted a proposal for BW research in the early 1980s. The date on which the Director of Al-Muthanna Establishment (Gen. Nizar Attar) formally requested the addition of a BW research is not indicated.

    132. It is stated by Iraq that no plans were elaborated for the large scale production, weaponization and storage of BW agents which is contrary to the statement of Gen. Nizar Attar who stated in 1995 that a plan was formulated in 1986 to achieve weaponization within 5 years (which is precisely what happened). The evolution of the programme over the next five years appears to follow a well defined course implemented with urgency, authority, and great secrecy demonstrating considerable planning.

    133. Research and Development at Al-Muthanna is claimed to have been restricted to consideration of just Clostridium botulinum and Bacillus anthracis spores whereas it is known that Clostridium perfringens was received on 10 November 1986 and that "DIALOG" database searches were undertaken for Clostridium perfringens on 13 May 1985 and 10 July 1985. Consultations were undertaken with Prof. Nasser Hindawi when at Mustansiriyah University in 1986.

    134. In reality the Commission assesses that the transfer of the BW work from Al-Muthanna to Al-Salman (TRC) was to preserve secrecy. Al-Muthanna still had a requirement for the agents produced at Al-Taji and subsequently at Al-Hakam for field tests. Al-Muthanna continued to collaborate on both laboratory and field experiments from 1987 to 1991.

    135. The establishment of the BW research group at Al-Salman in 1987 is accepted as stated although the means by which it was established and managed is far from clear. The relationship of the programme within TRC to other organizations is unclear. The responsibility and management for the expansion of the programme to include mycotoxins in 1987/88 and viruses and genetic engineering in 1990 has not been defined adequately.

    136. The establishment of the BW agents production factory at Al-Hakam has not been related to a military requirement or a weapons testing and procurement requirement. The extent of the capability there has not been justified.

    137. Field tests of BW agents started in late 1987/early 1988. The extent of such testing has not been revealed and some previously acknowledged tests are now stated not to have taken place.

    138. The activities undertaken in 1989 and 1990 - field testing aerial bombs, rockets and other munitions; the expansion of the programme in terms of research and agent production, and acquisition of additional facilities remain ill defined and as such a confident determination of the extent and scope of the programme cannot be made.

    139. Since the FFCD falsely states that the BW programme was obliterated in July 1991 no credible account is given of the preservation and concealment of the programme until 1995.

    FFCD UNSCOM Assessment Commentary
    1974 - Initiation BW Programme by Government decree. Establishment of Al-Hazen required planning in earlier years. No decree provided. Al-Hazen Institute established.
    1978 - Liquidation of the Al-Hazen Institute. Formally ceased activity on 16/1/79. Biological work continued at Al-Salman from 1979 to 1985. Legal reports confirming financial fraud by senior staff provided.
    1983 - BW was introduced in Al-Muthanna objectives. This is probably correct. Date probably 1983 from testimony of Lt. Gen. Nizar Attar. No documents to support statement. Statement by Head Al-Muthanna that BW added to CW programme was made in interview testimony.
    1985 - Start Al-Muthanna BW research. This is probably correct Documentary evidence for the appointment of BW staff. Others were already engaged at Al-Muthanna. Requirement and assessment not provided.
    1986 - No formal plans for BW. Planning was an integral and essential part of establishing the BW programme for the military. Contrary to statements of Gen. Nizar Attar and Haidar Farm documents.
    1987 - Transfer BW research to Al-Salman under TRC. It is accepted that this occurred in 1987. Documents support the transfer of personnel. No realistic justification or rationale provided for the move.
    End of 1987 - Production botulinum toxin for weapons tests. Acquisition Al-Taji was Aug 1987 and indicates prior planning for weapons. No documentary evidence of output of botulinum toxin. Acquisition Al-Taji supported by documents.
    1988 - Start planning weapons tests. Weapons were considered from 1986 when Gen. Nizar Attar planned BW programme. Detailed planning started in 1987. No documents provided.
    1988 - Expansion BW activities. It is accepted that this occurred although the extent and scope cannot be assessed. Recruitment of personnel and documented activity confirm this.
    1988 - Establishment of Al-Hakam Factory for the production of BW agent. Plans laid 1987; no justification provided; relation of scale to military requirement not explained. Gen. Nizar Attar started formulating plans in 1986. Acquisition of site on 24 March 1988 documented.
    1988 - Start aflatoxin research. 22nd May 1988 is accepted as the start date. No coherent account of initiation of work has been presented.
    1989 - Start Ricin research. Ricin considered CW agent. The origin of and extent of programme unclear. Started in 1988. No coherent account of initiation of work has been presented.
    1989 - Start Botulinum toxin production on an industrial scale. This is accepted Consistent with evidence of construction and equipping Al-Hakam.
    1990 - Botulinum toxin production continues on an industrial scale. Scale not consistent with admitted weaponization activities. Undertaken at Al-Hakam and Al-Manal.
    September 1990 - Start of Bacillus anthracis spore production on an industrial scale. In response to August order of Lt. Gen. Hussein Kamel Hassan. Production does not make maximum utility of equipment available. Evidence of Bacillus anthracis spore production at Al-Manal. Al-Hakam 1990 report supports Bacillus anthracis spore production at Al-Hakam.
    July 1990 - Start of virus research programme. Appears to be correct, at least for Dr. Hazem Ali's work. Role of Dr. Hazem Ali, a virologist, in programme unclear. Al-Hakam 1990 report supports this.
    March 1990 - Start of genetic engineering programme. Appears to be correct. No clear objectives provided for this. Location of activity unclear. 1990 Al-Hakam report confirms start.
    August 1990 - Decision to produce biological weapons for war. Accepted that the programme changed and was enhanced. No documents provided in support. Presented as a unilateral decision by Lt. Gen. Hussein Kamel Hassan.
    August 1990 - Enhanced production of BW agents. Accepted that the programme changed and was enhanced. No documents provided in support. Presented as unilateral decision by Lt. Gen. Hussein Kamel Hassan.
    [September 1990 - R-400 tests at Al-Mohammediyat.] Tests probably were undertaken with agents deployed. Statement withdrawn by Iraq despite discussion of tests with weapons staff at Al-Mohammediyat which provided clear accounts of the trials.
    September 1990 - Al-Manal established at FMDV facility Daura to produce botulinum toxin for weapons. Evidence that Al-Manal was also used for Bacillus anthracis spores - denied by Iraq. Bacillus anthracis spore genes were found on a fermentor and storage vessels. Documentary evidence that facility was acquired and 5000 litres botulinum toxin were produced.
    January 1990 - Production of aflatoxin at Al-Fudhaliyah (Al-Safa'ah). No technically coherent account for production given. Testimony indicates September 1990 for start. 1990 Al-Hakam report states 2200 litres aflatoxin produced, but location not identified.
    December 1990 and January 1991 - Weaponization of BW agents. The ordering and timing of weapons filling and deployment remains unclear. Timings of activities still not precise. It is unclear what the range of weapons used actually was. R-400 bomb and Al-Hussein missile warhead remnants confirm that BW agents were used with these weapons.
    January - July 1991 - Deployment of weapons. Ambiguities remain on numbers and location of weapons deployed. Iraqi accounts of the deployment of weapons continue to change.
    July 1991 - Destruction of weapons. Destruction of totality of BW weapons can not be verified. Physical evidence of destruction of some R-400 and missile warhead weapons confirming in part the statement.
    June 1991 - Destruction of bulk BW agent. It is possible that bulk agent remains available to Iraq. No physical or documentary evidence of this. Interview testimony supports agent destruction although there are inconsistencies in account.

    Research and Development

    140. Research is a fundamental cornerstone of Iraq's BW programme. It provides a scientific and technical basis for all aspects of the final developed programme. Although not all aspects investigated at the research level will lead to weapons development, the scope of the research programme is an index of the concept, strategy, and extent of the programme. No account whatsoever is given of review, concept, or theoretical projects undertaken by the research staff throughout the programme.

    141. The Commission's understanding of the early years of Iraq's BW programme at the Al-Hazen Institute in the 1970s is poor. It is not credible that a single individual is portrayed as being solely responsible for initiating and planning the research programme. A military input is also denied, although it is acknowledged that officers from the Chemical Corps were members of the staff. A clear definition of the success, or possibly lack of it, is necessary because both outcomes would influence future development of the programme. A full account of the extent of the Al-Hazen programme has not been presented in the FFCD although this programme was offensive in nature. Subsequent clarification (12 May, 1998) provides some further background information but still fails to indicate the strategic planning that initiated a BW programme within Iraq.

    142. The period of 1979 to 1984 remains a void in the Commission's understanding although there is considerable evidence of biological activities during that period - continuation of a building programme originally for the Al-Hazen Institute, retention of Al-Hazen staff at Al-Salman, Prof. Nasser Hindawi's submission for a research programme, acquisition of dual capable equipment, and placement of staff abroad for training. In other words the programme seems to have continued albeit with different objectives, emphasis, management, and resources.

    143. The resurgence of the BW programme is attributed to Gen. Nizar Attar, the State Organization for Technical Industries (SOTI) and MOD, and the appointment of Dr. Rihab Taha as an investigator in early 1985. This resulted in an initial programme of work at Al-Muthanna where Bacillus anthracis spores and Clostridium botulinum are acknowledged to be the cores of the activities. However, according to Iraq, under Gen. Nizar Attar's direction a plan was formulated in 1985 to develop biological weapons which included at least one additional agent, Clostridium perfringens. Iraq states, that basic studies on cultivation, identification, and pathogenicity of only Bacillus anthracis spores and Clostridium botulinum were undertaken. Nevertheless, there are indications that a broader survey of agents was undertaken as evidenced by the range of BW agents and simulants obtained in 1986 together with literature surveys undertaken by Iraq's scientists.

    144. In mid 1987 a group of biology researchers left Al-Muthanna to continue to undertake research within TRC at Al-Salman and to support biological weapons tests. The full circumstance of this transfer has not been presented. In addition it is stated that formal research on Clostridium perfringens started in 1988; aflatoxin, trichothecene and ricin work started, with the recruitment of further experts; and offensive work with Tilletia spp. (Wheat cover smut or bunt of wheat) continued at an increased level of activity. Additional research studies on the dissemination of BW agents using both liquid and dried BW agents was undertaken although the full depths of this work remains to be presented by Iraq. The extent of these studies has not yet been determined but documentation indicates a greater understanding of dissemination than revealed to the Commission.

    145. At Al-Salman some fundamental research work on the enhancement of the toxicity and virulence of agents was also undertaken, some in conjunction with Al-Muthanna. Research on the scale up of agent production was undertaken and the searches for cheap efficient growth materials were undertaken, not all of which have been disclosed in the FFCD although both testimony by Iraq's experts and documents indicate activity undertaken. Studies on the storage and preservation of both seed stocks and bulk agents were undertaken. The effects of Clostridium botulinum and Clostridium perfringens spores were also determined. The rationale for this is not presented in the FFCD and no one accepts responsibility for the scientific and technical basis for this expansion other than Dr. Ahmed Murthada who by his own acknowledgement merely administered the programme. The relationship of the parent organization to Al-Muthanna, the Scientific Research Council, the University of Baghdad, the Iraqi Atomic Energy Agency and the Central Library of Iraq have not been defined. The extent of the research programme remains to be presented. In 1985, 1986, and 1988 a range of defined seed stocks of BW agents were acquired, some of which are not recorded as being a component of the BW programme.

    146. In 1989 much of the research group and its attendant research was transferred to Al-Hakam where experiments on weapons materials compatibility was undertaken as well as quality control on BW agents produced at the industrial scale. The scale of the research work was further extended. In 1990 additional research locations were obtained at the Foot and Mouth Disease Vaccine Institute at Daura and apparently the Agriculture and Water Resources Centre at Fudhaliyah. Research on viruses was started by Dr. Hazem Ali and genetic engineering with Dr. Ali Nuria Abdel Hussein. The logic and intent for the selection of camelpox virus, infectious haemorrhagic conjunctivitis virus, and rotavirus are not stated in the FFCD. The objectives for the genetic engineering unit are not elaborated upon although testimony of Dr. Rihab Taha has indicated initially antibiotic resistant strains of Bacillus anthracis spores were to have been derived. Any relationship with that of the genetic engineering section of Al-Muthanna housed at the Serum and Vaccine Institute at Amiriyah under the direction of Dr. Al-Za'ag is denied.

    147. Iraq's failure to identify and to present technically and scientifically competent staff who will accept intellectual and management responsibilities for the balance and emphasis of the research programme, the planning and development of the research programme makes the determination of the overall extent of the programme difficult. There is a denial that individuals from academia (other than Prof. Nasser Hindawi and Dr. Al-Akidi) or other Ministries (with one exception) contributed to the programme in a consultative or advisory role. There is also Iraq's denial that any coordinating or supervisory committees existed which is unlikely.

    148. Documents concerning the research activities have been provided to the Commission. In August 1991 some ten papers concerning the research of Dr. Rihab Taha were presented to the Commission. These focussed on the three agents Bacillus anthracis, Botulinum toxin and Clostridium perfringens. In 1995 additional information was obtained by the Commission from the Haidar Farm, including research papers that indicateed that papers released in 1991 were carefully edited to mislead the Commission. No documentation concerning research on mycotoxins, smut, viruses, plant toxins and genetic engineering were included in the documents. In 1998 eight documents concerning research, apparently involuntarily provided by Prof. Nasser Hindawi, were provided to the Commission. The documents essentially confirmed earlier papers, although one three-page document which personally reviews Prof. Nasser Hindawi's contribution to the programme, bearing the date 1989, is given great credence by Iraq as defining the scope of the programme.

    149. Iraq claims that research is one of the best documented areas of the FFCD. The account fails to give confidence that the full extent of the research programme has been described and that all achievements have been presented. This is partly because of a lack of documentation in areas of activity outside bacteriological warfare agents and partly inconsistent and reluctant oral accounts of such activities. No indication is given of weapons research which logically would have run in parallel with agent production activities.

    FFCD UNSCOM Assessment Commentary
    1974 - Initial research efforts to achieve a BW capability at Al-Hazen Ibn Al-Haithem Institute. Overall correct but earlier start, probably 1973, based on the requirement to plan the building programme. No documentation of substance provided in support. The account is partially supported by interviews.
    1974 - 1978 - Al-Hazen Programme. The FFCD states that the biological part of Al-Hazen was "research on microorganisms for military purposes". It included antibiotic and environmental resistance, means of production, and agent preservation. The scope can not be defined but broadly the range of research is accepted although the true objectives of the work and the relationship to military requirement is lacking. Clostridium botulinum, Bacillus anthracis spores, Shigella spp., Vibrio cholerae and viruses were among organisms studied. Interview testimony supports much of the statement although accounts vary in terms of the success and outcome of the research.
    1978 - Liquidation of Al-Hazen Institute. Records of imprisonment of senior personnel is cited as evidence. Scientific fraud is asserted. BW Research stated as ending. Formal termination of programme of Al-Hazen Institute occurred allegedly in January 1979 but work continued. Evidence supports formal end of Al-Hazen, but in January 1979. It is probably a temporary end of part of the BW programme; work continued on biological issues. Court documents indicate financial not scientific fraud.
    1979-1984 - Activities - not acknowledged. Work continued at Al-Salman and planning for enhanced programme started. Iraq states no BW activities occurred during this period. Evidence of further work at Al-Salman and other locations. Planning at Al-Muthanna for integration into CW programme. Ba'ath party receptive to research ideas.
    1985 - A new start to BW research. The actual year of initiation of work is not clear. Generally accepted that actual laboratory work of Dr. Taha's group started in late 1985. In February 1985 BW research started at Al-Muthanna involving Dr. Rihab Taha. Documents citing her transfer from the University of Baghdad to Al-Muthanna. Research plans are denied. No theoretical or concept development acknowledged. UNSCOM has evidence of plans. Plans were presumably laid before 1985, Iraq's stated starting point.
    1985 to 1987 - Al-Muthanna research was a basic programme for Bacillus anthracis spores and botulinum toxin only. Restricted to laboratory production, characterization and storage. The time frame of research is accepted but the extent of the research is not determined. No supportive evidence submitted. Such studies were conducted. Not possible to verify that research was as limited as declared. Aerosol studies were conducted. Forged research papers produced in 1991 and presented to UNSCOM in support of these activities.
    1985 - Acquisition of BW agents and simulants. In 1985, 1986, and 1988 a range of agents required to support programme were acquired, or attempted to be acquired, from a number of foreign sources including from ATCC. and Institute Pasteur. Local acquisition also occurred. Documents support overseas sources, but many strains were also obtained from local sources; these are not cited. The rationale for the extensive range is not provided. The 12 May, 1998 declaration provides the year of import using the University of Baghdad as a cover.
    1984 - Smut research at Al-Salman. Smut research started at Salman Pak in 1984 and continued throughout the 1980s. Initially a civilian study, subsequently from 1987 offensive in nature. Partially supported by interviews which also indicate an offensive side of the studies. Origin of offensive work unclear.
    1987 - Transfer of "Biology Group"to Al-Salman. The Al-Muthanna group was transferred to Al Salman from May to July 1987. Various reasons cited. Evidence exists to generally support the time frame. Rationale for the transfer not convincing and conflicts with evidence.
    1987 - Continuation of Bacillus anthracis spores and botulinum toxin research. Advanced research including determination of pilot scale production and storage begun in 1988. Evidence indicates earlier advancement to this stage. FFCD does not include all aspects indicated by interview testimony
    1987 - Aerosol dissemination studies. Aerosol work undertaken at Al-Muthanna in 1987, with small animals, and at Al-Salman, 1987, latterly with a variety of agents. Both dry and liquid forms of agents were evaluated. No documents to support statements. Monkeys exposed at Al-Muthanna. Limited disclosure of this activity provided.
    April 1988 - Clostridium perfringens research starts. Start date of work unclear. The objectives and scope of the work greater than acknowledged. Not all aspects indicated by interview are covered in the FFCD. Start cited as after hiring of a specific individual in 1988 and concentrating on the infectivity of spores, not toxin(s). Toxigenic strains selected. Documentary evidence of earlier interest and research.
    1988 - Additional acquisition of BW agents and simulants Procurement activity greater than disclosed. In 1988, a range of additional agents required to support the programme were obtained.
    1988 - Aflatoxin work started. Work initiated because of ease of production of aflatoxin. Accepted that work started in 1988 with the appointment of Dr. Emad. Origins and extent of this programme still uncertain. No documents concerning research other than weapons research.
    1988 - Production technology. Pilot scale production of Bacillus anthracis spores, botulinum toxin, and simulants undertaken in 1988/89; processing and storage parameters evaluated. Agent drying process under-reported. No documents to support statements. Limited acknowledgement of production and downstream processing provided. Some work started much earlier than acknowledged. Drying know-how was greater than stated by Iraq.
    1989 - Ricin work was initiated at Salman Pak. Research began in 1988 (or earlier) at the request of an Internal Security Officer. Origins and extent of this programme still uncertain. No documentary evidence. Even after Lt. Gen. Hussein Kamel Hassan's departure in 1995, documents were altered to conceal origins and organizations associated with this effort.
    1990 - Trichothecene work starts in March. Work began in 1987 by someone other than Dr Emad. Account for trichothecene work conflicting and under reported. Documents indicate 1987 start to work.
    1990 - Initiation of genetic engineering. Began in 1990. Initiation of programme by acquisition of specific equipment and scientist. Attempted acquisition of equipment documented. Start of effort and other details are not given. The rationale for this work not given. Antibiotic resistance in Bacillus anthracis was the objective according to Iraqi testimony. Denial that Al-Muthanna Genetic Engineering Unit at Amiriyah contributed to the BW programme in 1990 and 1991.
    1990 - Start of virus studies. Preliminary studies on growth and pathogenicity attempted in late summer 1990. Studies focussed on Camelpox, Infectious Haemorrhagic Conjunctivitis virus and rotavirus Partially documented. The rationale for this work not given. Other possible uses include incapacitating agents.
    Al-Muthanna aflatoxin collaboration. In 1989 studies on augmenting aflatoxin with smut, CS, CN and mustard undertaken. Limited disclosure of this activity provided. The role of Al-Muthanna under-played.
    Al-Muthanna ricin collaboration. Documents indicate collaboration was extensive in 1989. Al-Muthanna assisted in set-up for a field trial in November 1990. Role of Al-Muthanna under-played.

    Sites and Buildings

    150. There is a requirement for Iraq to provide the rationale, justification, and requirement for all sites including those for weapons tests, research and development, production, storage, weapons production and filling, deployment, and the destruction sites for weapons, documents and agents. Building diagrams must be provided where appropriate.

    151. Such an account would correspond to one of the few tangible aspects of the programme which can be unambiguously presented - the actual buildings created and used. All that is provided in the FFCD is a physical description of some components. It does not relate activity undertaken or required to facilities available. Iraq has provided 23 site diagrams with little commentary after the Vienna Technical Evaluation Meeting (12 May, 1998) in response to the criticism.

    152. The scale of a facility quite obviously relates to the scale of activities planned to be undertaken. In the case of a key facility within a BW programme it will accommodate the staff and resource required or projected to fulfill the objectives of the programme. The only sites that Iraq has acknowledged to be purpose built for BW purposes are the Al-Hazen Institute and Al-Hakam. It is conceivable that components of Al-Muthanna and Al-Salman were also designed with regard to biological weapons considering the common origin of the Chemical and Biological weapons programmes.

    153. The Al-Hazen Institute was designed specifically for the start of the BW programme. In spite of this, few details have been provided by Iraq concerning the actual design and construction with regard to requirement. In addition the future requirements for Al-Hazen as evidenced by the construction of the "cube" and "L-shaped building" together with an animal house are not acknowledged.

    154. The Al-Salman account describes the accommodation occupied by the staff associated with the biological programme but does not indicate how this matches requirement and utility. The additional buildings erected specifically to support the programme (animal house, fermentor building and incinerator building) have not been related to planning, construction and requirement.

    155. The Al-Hakam Factory is acknowledged to have been built with the objectives of undertaking research and development together with industrial scale production of BW agents. Dr. Rihab Taha has also stated that weapons filling at Al Hakam was also considered for the future. Iraq states that weapons were filled for experimental field tests in 1990 at Al-Hakam and R-400 bombs were assembled at Al-Hakam in preparation for their subsequent filling (which apparently occurred at Al-Muthanna) and their subsequent deployment. Consideration of weapons assembly, filling and storage (empty and full) would have been a part of the consideration of Al-Hakam in 1987/88 as would the storage of bulk agent and the media required to produce such agents.

    156. The biological agent was stored in a bunker and a warehouse at Al-Hakam. The hardened bunker was capable of housing some twenty 5000 litres containers. Just four are acknowledged to have been manufactured and two were placed in the bunker and two were placed in the warehouse. It is not clear how many more 5000 litre containers were made or planned to be fabricated. The containers were specifically designed for pathogen storage and subsequent sterilisation. Containers with a capacity of 1000 litres, which were wheeled and so mobile, were also manufactured. Although the precise number made is uncertain it appears that at least 39 were made in 1989 and 1990. Some 70 were planned to be fabricated. These would serve both as storage and transfer vessels. The total planned storage capability is difficult to ascertain but it is probably in the region of 80,000 to 100,000 litres of agent.

    157. Al-Hakam was intended to accommodate, in 1988, three five-cubic metre fermentors in the first instance. According to a document provided by Iraq two such fermentors were planned to produce Agent A (botulinum toxin) and one for Agent B (Bacillus anthracis spores). This is described as industrial scale production and implicit is that it satisfied the minimum military requirement for Iraq. No account of this requirement has been made. In the event the fermentation line from the Al-Kindi Company was installed comprising seven 1480 litre fermentors and two 1850 litre fermentors (i.e., a total of 14060 litres) which is a similar overall volume confirming the operational scale requirement. Operating at a 5-day cycle about 820,000 litres of agent could be produced per year equivalent to 82000 litres of 10-fold concentrated agent. Assuming an annual replenishment of agent it would appear the initial annual capacity of the factory would be about 80,000 litres. When both areas A and B of the large scale plant became functional the capacity would in essence double and remain at that level until the far larger capability in area D came on stream.

    158. The site was used for the testing of weapons in 1990 and parts of the location lend themselves to experimental weapons tests away from the main production areas. As acknowledged the site is sufficiently remote to minimise contamination in the case of an accident and implicit is that it can be used for agent simulant testing.

    159. This FFCD also omits any reference to mobile production facilities once considered, according to Lt. Gen. Amer Al-Saadi. It omits the rationale for the selection of the geographical location of Al-Hakam and consideration of other sites such as Basrah.

    160. Since Iraq's overall account of sites is poor, and the FFCD fails to provide a coherent account of the overall military programme, it cannot yet be assessed whether the sites identified represent the entirety of the facilities used to support the programme. In the absence of a credible account of the overall planning and evolution of the programme some site related aspects cannot be fully evaluated.

    161. Sites associated with Iraq's BW programme (the list of sites is not necessarily complete).

    SITE Function UNSCOM Assessment Comments
    Abou Obeydi Airbase, near Kut Test Site for drop tank dispersion tests Used to test drop tanks for BW dissemination. Description incomplete. Rationale for BW use of site not given. A poor quality incomplete site diagram is provided.
    Agricultural & Water Research Station, Al-Fudhaliyah BW aflatoxin production claimed. Aflatoxin and genetic engineering research. No evidence, other than testimony, that site was used for this purpose. Partial rationale for site given provided, no site diagrams. Video evidence of MIC interest in site acquisition.
    Agricultural Aviation Division, Khan Bani Sa'ad BW weapons development - Zubaidy device Used for purpose stated - supported by documents. Partial rationale provided on May 12, 1998. No site diagrams provided.
    Airfield 37, near Ramadi BW Storage for BW R-400 bombs R-400 bombs at the site - no evidence of BW weapons at location Poor site diagram provided on May 12, 1998
    House at Al-Amiriyah, Baghdad Preliminary R&D site, Al Hazen Institute. May be correct. No site diagram provided. Rationale not provided.

    Diagrams provided May 12, 1998. Location not known.

    Al-Adile Stores (Kimadia) Forged documents on growth media prepared at site Possible site for preparation of forged media documents Documents in UNSCOM possession. Forged documents acknowledged by Iraq
    Al-Azzizziyah BW Storage and Destruction Site R-400 weapons destroyed at the site; weapons may have been deployed there. Rationale and site diagram provided in May 12, 1998 clarification.
    Al-Dabash Stores, Baghdad Growth media storage Media from BW programme stored at site 1991-96. Iraq acknowledges role of site.
    Al-Fao, Baghdad Design & Construction Center for Al-Hakam Evidence that it contributed to the design and construction of Al-Hakam. No information provided by Iraq.
    Al-Faris Factory, Al-Amiriyah, Baghdad BW weapons development, drop-tanks No information provided. No information provided. Not acknowledged as a part of the programme.
    Al-Hakam Factory BW agent production Accepted that it was one of Iraq's production plant. Justification and rationale inadequately presented. A selection of site diagrams provided but insufficient to provide a definitive account.
    Al-Hazen Ibn Al-Haithem, Salman BW research Accepted that it was a site constructed for research activities. Rationale provided for first phase. Some diagrams provided on May 12, 1998.
    Al-Kindi Company, Abu-Ghraib Training, TRC personnel on fermentation line. Source of fermentors for Al-Hakam. Explanation and rationale only partial.
    Al-Manal, Daura, Baghdad BW Research & Production Stated role may be correct for botulinum toxin production and virus research but evidence of Bacillus anthracis spores work at this site. Explanation and rationale only partial.
    Al-Mansuriyah BW Missile Warhead Storage Role is not confirmed. Rationale only partly provided. A diagram and comments provided May 12, 1998 clarification.
    Al-Meshada, Taji Storage surplus R-400 bombs. Stated role may be correct. No diagrams.
    Al-Mohammediyat Test Site for weapons tests Stated role may be correct. Rationale only partially provided. No diagrams.
    Al-Muthanna, Samara BW Research & Weapons filling Accepted that Al-Muthanna contributed to research and weapons, timing and detail of planning for activities unknown Rationale not totally credible emphasises CW aspects of building planning. Some diagrams provided. Description of buildings minimal.
    Al-Nahrawan, near Baghdad Test site for prototype biological bombs. Site not positively located. Partial rationale. No site diagrams.
    Al-Nibai BW missile warhead destruction. Missile destruction site still under investigation. No site diagrams. Partial account provided May 12, 1998 clarification.
    Al-Numan Factory, Baghdad Fermentor component manufacture. Stated role may be correct. Rationale and site diagrams not provided.
    Al-Qa'a Qa'a, Latifiyah Explosives. Role accepted. Rationale and site diagrams not provided.
    Al-Rasheed Air Base, Baghdad Pilotless MiG 21 test for drop-tank. Stated role may be correct. Partial rationale provided. No diagrams.
    Al-Taji BW Production. Stated role may be correct. Clear rationale not provided.
    Asma School, Al-Hindaya Media, equipment, supplies, and records evacuation site. Stated role may be correct. However media aspect not supported by documentation. Diagrams not provided. Document supports that it served as an alternate site.
    HQ Air Force Technical Depot, Taji Drop-tank storage, destruction. Stated role may be correct. Diagrams not provided.
    Jarf Al-Sakr Test Site - 155mm shells and Ricin. Stated role may be correct. Diagrams not provided.
    Jurf Al-Nadaf Aerosol chamber dump site. Role confirmed by inspection. Diagrams not provided.
    Nasr State Establishment, Taji R-400 bomb manufacture. Stated role may be correct. Rationale for R-400s not provided. Diagram provided May 12, 1998 clarification.
    Project 144, Taji BW weapons development - 122mm rockets and Al-Hussein warheads. Stated role may be correct. Rationale for warheads not provided. Inadequate diagrams provided.
    Serum & Vaccine Institute, Amiriyah Storage BW seed stocks. Genetic engineering. Stated role may be correct. Rationale for Genetic Engineering not provided. Site diagram provided May 12, 1998 clarification.
    Site 85, near Latifiyah BW deception site, acquisition. Stated role may be correct. Description and rationale inadequate.
    State Enterprise for Heavy Engineering, Daura, Baghdad Mobile and Storage Tank Manufacture. Stated role may be correct. Rationale for mobile tanks not provided. May 12, 1998 clarification.
    State Establishment for Mechanical Engineering, Iskanderiah Not acknowledged. Involvement in destruction of mobile tanks. Not acknowledged.
    Store no 6, Misbah, Baghdad Growth media storage. Possible temporary media store. Iraq claims site to be temporary media store.
    Technical Research Centre, Salman BW Research. Stated role may be correct. Rationale and diagrams provided. Destroyed by coalition bombing 1991.
    Tigris Canal, near Fallujah BW missile warhead storage. The site may have been used for storage . Explanation and rationale changed over last two years.
    University of Baghdad, Baghdad Procurement of BW equipment; BW agents procured for and used in the programme; deception. Stated role may be correct. Explanations, rationale, and diagrams not provided.
    University of Technology, Baghdad Design & Construction Al-Hakam. No information provided by Iraq. Explanations, rationale, and diagrams not provided.
    Military Industrial Commission, Baghdad Administrative Centre. No information provided by Iraq. No diagrams provided.

    Organization of Iraq's BW Programme

    162. There is no comprehensive information about the organization of Iraq's BW programme, at all levels, and its relationship to other Iraqi bodies. This makes it impossible to determine the scope and nature of the programme. An understanding of the various relationships and interconnections between the diverse organizations that contributed to the BW programme is essential to gain a full appreciation of the programme and build confidence that the account provided is indeed full and complete. A variety of Government organizations would have contributed to the programme. Among these would have been the State Security and Intelligence, the Ministries of Agriculture, Health and Education, Ministry of Defence and some of its various branches, as well as the industrial and academic base in Iraq. The list of contributing organizations cited in the FFCD is incomplete compared to interview testimony and documentation. This can only be rectified by a full disclosure of relevant information supported by documents and details of funding.

    163. Iraq claims that the Ministry of Defence provided no support to the BW programme. It is also stated that there was no representation on the Military High Command or the General Council of Ministers concerning any aspect of the BW programme. It is explained by Iraq that the Director-General of TRC reported directly to Lt. Gen. Hussein Kamel Hassan in his capacity of head of the State Security Organ, rather than as head of MIC. Despite this, Iraq forcefully denies any interaction between the BW programme and any Iraqi intelligence agencies.

    164. Iraq claims that the BW programme was controlled from the bottom-up. Such a system would not account for the degree of coordination which became evident as the programme progressed.

    165. In contrast with the Al-Hazen Institute, which had a formal personnel recruitment programme for its BW activities, the later BW programme had no such formal arrangements, according to Iraq. Promising people within the BW programme were sent abroad for higher education. It is claimed that no directive or directions to academic institutions existed to conduct research related to BW. The description of academic connections does not accord with the evidence.

    Military Involvement in Iraq's BW Programme

    166. A clear description of the organizations driving, or influencing, the BW programme is critical to assess its dimension and significance. The lack of such descriptions reflects negatively on the credibility of accounts of R&D, production, and the selection and deployment of weapons. Without further physical or documentary evidence, the unclear explanations given, in these areas, make it impossible to confirm the information presented in the FFCD.

    167. The account of military organizations involved in the BW programme is not seriously addressed in the FFCD. The contention that the MOD remained wholly unaware of Iraq's BW programme since 1987 is implausible. The programme started within the Al-Hazen Institute and was headed by a member of the Chemical Corps, Major Ibrahim Ghazim, and the biological component had two senior members recruited from the Chemical Corps. It is acknowledged that MOD was involved from 1983 to 1987 and that it endorsed the addition of BW to the remit of Al-Muthanna in 1983. Although, formally, the chain of command may have altered when the BW research and production component was transferred to TRC within MIC in 1987, it is unlikely that it was not visible to senior military personnel within the MOD. Programming for the formal adoption of BW would have been a factor in the strategic planning of Iraq's military development along with the foreseen nuclear and chemical capabilities.

    168. Iraq would have developed a requirement for a militarily significant arsenal of biological weapons in 1987/88, or possibly earlier, based on strategic planning. This in turn would define the technical scope of the programme and the appropriate funding to ensure the eventual success of the programme.

    169. According to Iraq's account, the involvement of MOD in the BW programme ceased with the transfer of the biology group from Al-Muthanna to TRC that was under the control of MIC. Iraq asserts this MOD link was only re-established specifically for the deployment of weapons in January 1991. The explanation given is that MIC had a higher status than the MOD and was a self-contained entity that could progress from initiation to deployment of weapons without external input. This has not been substantiated.

    170. The BW weapons would have to have been integrated into Iraq's strategic arsenal. For these, military objectives, the concepts of use and the mechanisms for releasing these weapons must have been defined. This would have required extensive planning, which Iraq denies.

    171. The FFCD portrays Lt. Gen. Hussein Kamel Hassan as the sole key decision-maker and controller of the BW programme after 1987. Links between Lt. Gen. Hussein Kamel Hassan, the MOD and other organizations are vehemently denied. It is assessed by the Commission that such links must have existed. Without such links, understanding how Iraq defined its military requirement and planned the use of its BW weapons, is difficult.

    OTHER ISSUES RELEVANT TO VERIFICATION OF IRAQ'S BIOLOGICAL WARFARE PROGRAMME

    172. In Parts I and II the status of verification of elements of Iraq's BW programme described to one extent or another in its FFCD is presented. However, a status report would not be complete without the inclusion of several other issues directly related to the verification of Iraq's BW programme. Iraq has attempted to portray the Commission as stalling in its verification efforts. As part of this effort, Iraq cites the numerous inspections and interviews conducted by biological experts as well as citing approximately 200 documents it has provided in support of its declaration. However, Iraq has failed to cite the obfuscation and deception by Iraq that has necessitated these multiple inspections. It has also not cited the type and nature of the documents provided. Quality is not measured solely on the number of documents or volume of material.

    173. Other issues include the technological coherence of the programme. The less coherent the programme appears to be the greater the dependency for verification on documentation and physical evidence. Iraq tries to portray its BW programme as an inept programme without guidance or direction. The Commission's assessment of Iraq's level of technology does not support this contention. Iraq asserts that its BW programme was obliterated in 1991. There is little confidence that its programme has been ended. Throughout all of the issues in all three parts of this report is the pattern of concealment and deception employed by Iraq to prevent a true picture of its BW programme from emerging. These issues are addressed below.

    Inspections 1991 to 1998

    174. Over the past eight years the Commission has conducted some 70 inspections directly concerned with biological warfare activities undertaken by Iraq. In addition, six joint chemical and biological inspections have been undertaken, including one that included missile experts. Sixteen monitoring teams have followed biological activities in Iraq's industrial, agricultural, medical and academic facilities. More than twenty of these inspections were direct investigations of Iraq's proscribed BW programme and two were involved with destruction of facilities involved in the programme. The remainder included establishing protocols and procedures for monitoring, detailed audits of key facilities, determination of indigenous capability, and searches for documents. In addition two major meetings were held to exchange information, during August 1993, in New York, and March 1998, at the TEM in Vienna. On both occasions, Iraq produced no additional information to enable a true appreciation of its entire BW programme.

    175. The past programme investigation consisted, essentially, of three phases. Firstly, the discovery inspections of 1991 and 1992, that showed that Iraq has not been forthcoming about the scale and scope of its programme. Second, from autumn 1994 to summer 1995, consisting of attempts to uncover the past weapons programme and to establish the credibility of statements being made by Iraq about its past programme and the claimed legitimate activities of sites assessed to have contributed to the programme. After the departure of Lt. Gen. Hussein Kamel Hassan in August 1995, the Commission embarked on a third phase of investigation of the programme using, in part, information derived from the documents released by Iraq from the Haidar Farm. During the first and second phases, Iraq concealed from the Commission, the entirety of its programme. Iraq merely acknowledged a part of its research programme as a military research and development programme and falsely presenting its main BW agent production facility as a Single Cell Protein plant. During this period Iraq actively and deliberately concealed much of the research programme and the entirety of the remainder of the programme. This it achieved by outright lying, evasiveness, intimidation, forging of documents, misrepresentation of sites and personnel, the denial of access to individuals and the issue of successive FFCDs that were fraudulent. The account provided by Iraq wholly lacked credibility.

    176. From September 1994 to July 1995 it became obvious that Iraq was failing to disclose a programme from the inconsistent, often conflicting and changing stories, presented without any substantiation. Eventually the failure of Iraq to account credibly for the vast amount of media imported between 1988 and 1990 led to the acknowledgment that Iraq, indeed, had produced industrial scale quantities of a significant military programme of two biological warfare agents (Bacillus anthracis spores and Clostridium botulinum toxin) although it was stated, incredibly, that this was done with no thought of weaponization.

    177. Iraq has claimed that all documents concerned with its biological weapons programmes were destroyed in 1991. Lacking documents, other approaches have been adopted to investigate and verify Iraq's account of its programme. Interviewing personnel associated with the programme has been the main approach. Iraq has been reluctant to provide personnel to substantiate the details of its programme. Generally, only individuals identified from Haidar Farm documents and documents, otherwise recovered, have been presented. Technical assessments of the facilities and equipment acknowledged to be a part of the programme, sampling, and exploitation of recovered weapons and fragments have also contributed to the inspection process.

    178. In August 1995 weaponization was acknowledged by Iraq including weapons trials and the prior deployment of weapons in January 1991.

    179. From September 1995 the Commission investigated the full programme as revealed by Iraq. Initially the inspections undertaken in the latter part of 1995 were designed to understand and get and clarify information on Iraq's weapons programmes. Subsequently, attempts were made to verify the three succeeding FFCDs produced after August 1995. During these inspections it became obvious that the FFCDs were inaccurate and incomplete and so investigation of the programme was also begun again. The focus of the inspections was the issue of weapons and the production of BW agents, together with the acquisition of bacterial growth media, weapons, and production equipment. Others aspects such as research and development still await thorough examination. Many aspects have not been addressed because Iraq refused to cooperate. The Commission attempted to help Iraq recall further information about its programme by participating in a seminar in May 1996, which dealt with chemical and biological weapons, by submitting detailed questionnaires to Iraq (which were largely ignored, although later incorporated into the 1997 FFCD), and by organizing a TEM (Vienna, March 1998) for extensive evaluation of Iraq's declarations by a full range of international experts. From June 1998, following discussions between the Commission's Executive Chairman and Mr. Tariq Aziz, Deputy Prime Minister of Iraq it was decided to adopt a focussed programme of inspections following a "top down" approach concentrating on establishing a material balance for biological weapons themselves. This started with an inspection concerned with weapons that concentrated on biological R-400 weapons. The decision of Iraq on 5 August 1998 to cease cooperation with the Commission on the issue of verification has meant that verification of Iraq's biological warfare programme is now in abeyance.

    180. Besides weapons related issues, inspections have been conducted to investigate planning, the military and intelligence contributions to the programme, and the acquisition of materiel. Concealment and deception, and the means by which this has been achieved has also been examined with no information of significance provided by Iraq.

    181. Many aspects of the programme now included in the FFCD have been revealed because of the result of the Commission's inspections although it is acknowledged that other aspects have been revealed by Iraq without prompting. Ironically many issues and details discussed in the series of inspections conducted on the past programme are omitted from Iraq's official account directly showing that the FFCD is incomplete.

    General Assessment of Iraq's Documentary Evidence

    182. Notwithstanding the reticence with which Iraq has provided documents needed for verification, the quality of documentation provided by Iraq concerning its past BW programme has presented difficulties in providing a strong evidential base for the verification process. Problems with documentation quality reside in their relevance to the proscribed BW programme, as well as their completeness and finally, their authenticity. With respect to relevance, the bulk of documents provided by Iraq to the Special Commission tends to be removed one or more levels from the key issues central to the BW programme and can be best described as derivative, e.g, rather than presenting documents that unequivocally establish the identities of key personnel in the programme, Iraq has provided documents that track the departure of individuals from one place of employment to another. Alternatively, Iraq has provided documents that add nothing of relevance to its declaration by way of verification. With respect to completeness, Iraq has frequently provided fragmentary documentation which renders assessment and hence, verification, difficult because the lack of a full contextual basis. For example, the source of documentation for the 157 R-400 bombs unilaterally destroyed by Iraq, and which serves as a basis for Iraq's allegation that only this number of R-400 bombs were filled, was from a very few pages of a personal diary belonging to an Iraqi army officer apparently present at the time the bombs were destroyed. Finally, Iraq has "recreated" documents, such as the document on ricin production and research, that are at best questionable and may even hinder the verification process. Had Iraq provided appropriate documents of its BW programme dealing with the key elements of acquisition of materials, production of bulk agents, production of weapons, destruction of weapons, and destruction of bulk agents the verification process would have been better served.

    Technical Coherence

    183. One key factor in determining the veracity and credibility of Iraq's account of its biological weapons programme is the assessment of the coherence of the account. Any programme of activity will be managed to achieve set objectives within a specified, possibly flexible, time frame. Once the shape and coherence of the programme become apparent, verification can be achieved by selecting disclosures of appropriate components and determining that it is a faithful and authentic account. When these reference points are determined, other aspects will fall into place and need not be determined with such extensive rigour. Regrettably Iraq's account is not coherent, the first basic step.

    184. Iraq fails on a number of levels to present a clear account of its programme. At the senior level there is no indication of the determination of a requirement for such weapons and planning for the acquisition and deployment of the weapons. At the management level there is no indication of how the requirement was to be met and how resources were acquired and utilized to fulfil the military need. In particular the scale and scope of the Al-Hakam Factory are not explained or justified; the inevitable weapons development programme to ensure effective BW agent dissemination is not presented at all. At the working level there is no rationale presented for research and development, or the industrial scale production of agent (especially before August 1990). The repeated statement by a senior Iraqi Government representative, that the programme was a minor programme, essentially run by unsupervised technicians who had an unrealistic programme of work, trivialises a serious programme of work and does nothing to help the Commission gain the appreciation of that programme. The denial of planning for the programme, contrary to the evidence, means that the basic coherence for the programme cannot be established.

    185. A weapons programme by definition is a military programme yet apparently there was no military involvement in the claimed last four years of the programme. A philosophy for the programme should have been developed which would require the interaction of military, intelligence, industrial and academic sources. Iraq denies any military committees or individuals contributed to the formulation of policy with regard to the acquisition and implementation of Iraq's BW programme.

    186. The programme for biological weapons was immature in 1991. The failure of Iraq to account for its intended programme of work through 1991 and beyond also prevents the Commission from gaining a perspective of the interrelationships between the various components and so the coherence of the programme. This information will also be essential to determine if Iraq has indeed terminated its programme.

    Technology Assessment

    187. Iraq claims that the BW programme established was an immature programme that was ill considered and ineffectively executed. Further, Iraq claims that it lacked the industrial capability and expertise to manufacture equipment suitable for the production of BW agents and weapons. This is an argument frequently put forward by Lt. Gen. Amer Al-Saadi in his attempts to create the impression that Iraq does not pose a threat to its neighbours with regard to biological weapons.

    188. The Commission could not make an accurate technical assessment of Iraq's scientific, industrial, and technical accomplishments because Iraq has not been transparent in its FFCD nor its clarifications about the BW programme. Since the programme has operated from 1973, it is reasonable to assume that Iraq attempted considerably more than has been revealed and that some components achieved success in areas not revealed to the Commission. Some 400 individuals are known to have contributed to the programme in various ways from research to weaponization. Civilians, civil servants, security, and military personnel were involved. Iraq has a record of denying and understating its weapons programmes. Iraq has preserved components of its BW programme since 1991, and much of the expertise remains in Iraq. The Commission has examined the indigenous capability existing in Iraq and has assessed in the course of inspection that Iraq is capable of manufacturing "dual use" equipment and munitions. The degree of sophistication of these systems may not meet so called "western" standards but none the less are quite capable of fulfilling the requirements.

    189. Iraq has a broad based research community in Universities, Medical and Agricultural Institutes, and the Military Industrial Commission covering microbiology, biological processing, materials science, genetic engineering, pathology, biological production, munitions and weapons.

    Iraq also has an industrial base capable of manufacturing fermentors and their ancillary requirements, spray driers, and storage vessels for agents. The industrial base will also sustain the engineering and manufacture of weapons.

    The End of the Iraqi BW Programme?

    190. In mid-1995 Iraq admitted that it had possessed a BW programme. Since then, Iraq has often stated that its BW programme was 'obliterated' in 1991. Officials cite, as proof of this, the unilateral demolition of the deployed BW weapons, deactivation of bulk BW agents and the destruction some documents associated with the programme. Despite these activities in 1991, Iraq retained the facilities, growth media, equipment and groupings of core technical personnel at Al-Hakam, while denying the very existence of any BW programme.

    191. Although Iraq continues to insist that no elements of its BW programme have been preserved, the Government of Iraq has yet to offer evidence of the formal renunciation of its BW programme. It is explained that a decree was never issued because of a 1991 decision to conceal the BW programme. Again Iraq has produced no information on the decision to conceal the programme.

    192. Iraq insists that all its BW weapons were destroyed in July 1991. The numbers, location and timing of weapon destruction and, indeed, whether all weapons were destroyed, remain in doubt. Iraq's account of the destruction of the BW-filled Al-Hussein warheads changed with virtually every inspection team that addresses the issue with Iraq. No supporting evidence exists for the destruction of the bulk agent, also regarded by the Commission as weapons. Large quantities of bacterial growth media remain unaccounted for.

    193. After 1991, Iraq maintained and expanded the purpose-built major BW production, research and development and storage facility, Al-Hakam. From that time, Iraq asserts that Al-Hakam was solely a single cell protein (SCP) production plant. However, no serious attempts to produce SCP ever occurred. SCP was only produced in insignificant quantities as a camouflage, principally by harvesting SCP from brewers waste rather than de novo production from petroleum products. Individuals, identified as key workers in Iraq's BW programme, continued as members of the staff of Al-Hakam. In the years after 1991, Iraq attempted to obtain dual-purpose equipment including industrial-scale fermentors from within the country and abroad.

    194. In the years since 1995, the Commission's teams have continued to discover significant undisclosed dual-use equipment that could readily be used in a BW programme. In the six months period April to October 1998, some 150 undeclared items were found and tagged by biology monitoring teams. For example, many mobile tanks used in the BW programme are not accounted for. The significance of this lies in the fact that with only minor modifications these could be used as fermentors.

    195. Although Iraq acknowledged its offensive BW programme in 1995, it has yet to make a full disclosure. One of the most obvious omissions is information concerning the termination of its offensive BW programme. The evidence collected by the Commission and the absence of information from Iraq, raises serious doubts about Iraq's assertion that the BW programme was truly obliterated in 1991.

    Concealment and Deception

    196. Verification is the basis of disarmament and arms control. Verification depends on serious cooperation between the parties concerned. It also depends on compliance, in principle. This includes the submission of comprehensive and accurate declarations which can be confirmed by supporting evidence. Without these, confidence in a verification regime as required under SCR 687 (1991) is limited, at best. Concealment of critical facts is a clear sign of non-compliance. It raises serious doubts in the efficiency of disarmament or any arms control work and unavoidably leads to speculations about the reasons motivating it. Concealment effectively precludes verification.

    197. In April 1991, Iraq made a decision to conceal certain aspects of its weapons of mass destruction programmes from the world. With regard to its BW programme it decided to admit only a limited effort of research and development, that was restricted to a single location, never reached the level of production of agent or weaponization, and was terminated unilaterally in August 1990. Iraq maintained this position until in 1995, when the departure of the head of Iraq's weapons of mass destruction programs, resulted in additional aspects of these activities being released. Iraq admitted having had an offensive programme centred around a purpose built research and production facility and including large scale production of BW agents and weaponization and deployment of aerial bombs and long-range warheads.

    198. A high-ranking Iraqi official, Lt. Gen. Amer Al-Saadi, stated in 1998, that Iraq offers no defence for the period of denial of its BW programme. He admitted it was a political decision to conceal both the programme and consequently its obliteration from the Special Commission. In fact, the attempts to conceal the programme caused and continue to cause serious doubts amongst the Commission's experts over Iraq's declarations. This and a lack of documentary or other physical evidence greatly hinders the process of verification of Iraq's disarmament efforts to which it is obligated by international law and its own acceptance of those terms.

    199. A serious concern remaining is that the unilateral destruction of documents, agents and weapons in 1991 was linked to the concealment issue rather than the issue of obliteration of its programme. The difference being, that in the first case, only part of all assets may have been destroyed, purely to deceive the Commission and feign liquidation of the programme. Indeed, the Commission is aware that Iraq at least retained suitable growth media, capable facilities, production equipment, teams of expert personnel, and the essential technical know-how. Until today, no credible declaration has been presented by Iraq as to if and when it obliterated its BW programme.

    200. Since the disclosure of the BW programme in 1995, Iraq has released a number of documents to the Commission. Iraq has ascribed an inflated importance to certain of these documents and dismissed others. Indeed, some documents have been described as "first class", whilst on other occasions the same documents are described as unreliable or trivial. There is an attempt to disregard documentary evidence that contradicts the accounts of officials or material in the FFCD. It is apparent, that Iraq only releases documents and other information to address or respond to information the Commission had already become aware of.

    201. The following tables detail events and actions taken by Iraq as a result and indicative of its decision to conceal the BW programme from the Commission. It portrays a systematic effort to deceive the Commission by a) false or incomplete declarations and b) removal or manipulation of evidence delineating the totality of its BW programme.

    202. Concealment of Iraq's Biological Warfare Programme in its Declarations to the United Nations and its Bodies

    Actions taken by Iraq Comments
    8 April 1991 A letter presented by Iraq implied Ratification of the Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological (Biological) and Toxin Weapons and on their Destruction. Iraq later declared that in April 1991 it still had 157 biological bombs, 25 biological warheads and several thousand litres of unfilled biological agent in storage which would be a violation of the BWC. No article of implementation has been provided.
    18 April 1991 Iraq declares to the Secretary General of the United Nations that it does not possess any biological weapons or related items as described in paragraph 8 of SCR 687 (1991). Iraq possessed at least the weapons acknowledged above on this date.
    2 August 1991 Iraq declares to the first biological inspection team of the Special Commission a limited biological research programme for military purposes focussing on three bacterial agents. It was initiated at Salman Pak in 1986 and abandoned in August 1990 before it reached the stage of production or weaponization of biological agent. Iraq's current declaration of its BW programme describes an offensive military programme initiated in 1973 and abandoned in mid 1991. It comprised several research and production facilities and a variety of bacterial, fungal, viral and plant-derived agents were investigated and produced in large quantities. A number of delivery means were investigated and eventually utilized.
    May 1992 Iraq submits an FFCD of its BW programme as demanded by S.C.R. 707 (1991). It details the activities outlined in its August 1991 declaration. It states that Al-Hakam, FMD facility and VRL were not related to any BW activities. Al-Hakam and FMD facilities were later declared as Iraq's main production sites for Bacillus anthracis spores and botulinum toxin used in their BW programme. Equipment of the VRL company was transferred to Al-Hakam and used in that process.
    Early 1994 False site declarations are submitted on Salman Pak, Al-Hakam and the FMD facility. Salman Pak was described as the exclusive BW site undertaking limited research. Any involvement of Al-Hakam and FMD in the programme was denied.
    March 1995 Iraq submits a second FFCD of its BW programme. It contained no significant additional information from the prior FFCD. The FFCD attempted to explain the import into Iraq in 1988 of 39 tons of growth media - a fact that was discovered by the Commission only in late 1994. Iraq declared that the media was imported for medical diagnostic purposes. Iraq presented documents in support of its declaration but later admitted that these were "recreated" from "originals" that were no longer available.
    April 1995 Iraq declared during high-level talks in Baghdad that no further cooperation with regard to its BW programme could be expected by the Special Commission if the Chairman failed to report to the Security Council that the Missile and Chemical Files were closed and IAEA did not report the same in the nuclear area. No production or weaponization of biological agent was admitted.
    July 1995 Iraq decides that it would cease all cooperation with the Special Commission on 31 August 1995 if there was no progress towards the lifting of sanctions. Iraq on 1 July 1995 in an oral presentation admitted to the Chairman of the Special Commission the large-scale production of biological agent. It still denied weaponization of any biological agent. The quantity of Bacillus anthracis spores was considerably under reported. Production of aflatoxin and Clostridium perfringens spores was not acknowledged.
    4 August 1995 Iraq submits a third FFCD of its BW programme. The large-scale production of two agents, Bacillus anthracis spores and botulinum toxin at Al-Hakam is admitted. Iraq denies any attempts to weaponize these agents. The FFCD was declared null and void on 17 August. This change was precipitated by the departure of Lt. Gen. Hussein Kamel Hassan, who over a considerable period of time was in charge of Iraq's weapons of mass destruction programme.
    17 August 1995 Iraq presents additional information including weaponization of biological agents, research and production of additional agents and additional sites related to its BW programme. Iraq does not acknowledge weaponization of aflatoxin.
    June 1996, September 1997 A fourth FFCD was submitted in June 1996 and a fifth FFCD in September 1997. Both were rejected by the Commission for reasons of a lack of comprehensiveness, accuracy and credibility.

    Concealment of Iraq's Biological Warfare Programme and Deception of the Special Commission

    Actions taken by Iraq Comments
    April 1991 Decision was taken to conceal BW programme from the Special Commission Details of this decision have not been provided to the Commission.
    A Revolutionary Command Council Member under the supervision of the Deputy Prime Minister Mr. Tariq Aziz was responsible for the dealings with the Special Commission. Lt. Gen. Amer Al-Saadi, adviser to the Presidency, explained in 1998, that the decision makers were and still are a group of senior people including Deputy Prime Minister Tariq Aziz, Minister Mohammed Al Sahaf, Minister Lt. Gen. Rashid Amer, Minister Lt. Gen. Murthada and himself. Lt. Gen. Hussein Kamel Hassan was excluded from that group.
    May 1991 Foundation of the Operations Section for the day-to-day dealings with UNSCOM. From this section, the National Monitoring Directorate (NMD) was established.
    Removal of Evidence from Al-Muthanna. Traces of the BW programme were removed from the Toxicology Department and the filling station for Biological Weapons.
    June 1991 Purported instruction by Lt. Gen. Hussein Kamel Hassan to destroy all documents, agent and weapons related to BW. Despite this clear order, an unknown amount of documents "survived". Iraq claims these were collected by Lt. Gen. Hussein Kamel Hassan in November 1991. UNSCOM inspections have repeatedly discovered documents related to issues defined under SCR 687 (1991).
    Transfer of large amounts of bacterial growth media to Kimadia together with forged import documents. An inventory card indicating an arrival date for the media at Kimadia in 1989 was prepared later. In 1992, to explain the missing media that had been used for the production of BW agent, health departments were asked to sign fake receipts for that media for diagnostic purposes. Kimadia, operating under the Ministry of Health, was used as a front to explain the legitimacy of the import of the growth media.
    July 1991 Iraq states that they unilaterally destroyed all biological weapons, bulk agent, related documents and some equipment. There is no documentation for this destruction process. A lack of related documents or physical evidence impedes direct verification of elimination of material as defined in paragraph 8 of SCR 687 (1991).
    August 1991 Rehearsals of answers to expected questions by UNSCOM inspectors.

    Al-Hakam is being systematically cleansed including all the equipment used in the BW programme to conceal any damming evidence

    Preparations for the first UNSCOM Biological Weapons inspection.
    Declaration of limited BW related research on three bacterial agents. A declaration was handed over to the first UNSCOM BW inspection on 2 August.
    Submission of 10 research papers in support of their declaration. The papers were carefully edited to reveal only certain aspects of the programme.
    September 1991 During inspection BW 2, Al Hakam is portrayed as a genuine civilian Single Cell Protein facility. A fake laboratory was presented. This account was maintained until July 1995. Prof. Nasser Hindawi, an expert in SCP, is presented to the team as the director of Al-Hakam. Prof. Nasser Hindawi later admitted that he was not involved in a SCP project at the time of BW 2. He was appointed director of the Al-Hakam SCP project in November of 1991 and on 4 April 1992 director of Al-Hakam, only to be relieved from this post a few weeks later.
    Iraq declares to an UNSCOM team that 58 R-400 bombs located at Al-Muthanna were exclusively for Chemical Warfare (CW) purposes and were never filled. 56 of these bombs were destroyed under UNSCOM supervision and two removed for further study. Iraq later stated that about 36/37 of these bombs were in fact designated for biological purposes. Photo evidence of characteristic markings of the weapons supports this claim.
    November 1991 Instruction by Lt. Gen. Hussein Kamel Hassan claimed to have been given to collect all important remaining documents relevant for BW and hand them over to him. In 1995, following the departure of Lt. Gen. Hussein Kamel Hassan, these documents were handed over to the Special Commission and are referred to as the "Haidar

    Chicken Farm" documents. Despite Iraq's claims, they are judged to be of low significance. The more significant documents, Iraq states to have collected in November 1991, have not been provided to the Commission, yet.

    April 1992
    Iraq presents to UNSCOM an account of the destruction of 40 CW R-400 bombs at Al-Azzizziyah. Iraq states that 157 BW R-400 bombs were destroyed at Al-Azzizziyah. No CW weapons are now stated to have been destroyed there.
    Iraq presents an UNSCOM inspection team with the supposed remains of 45 CW warheads that had been unilaterally destroyed. UNSCOM inspectors counted 43 nosecones as indicators for the 45 destroyed warheads. Iraq later admitted that it seeded about 25 nosecones in the area of excavation to deceive the inspectors. Thus, only the remains of 20 CW warheads were in fact presented. The remaining 25 were biological warheads that were not ready to be disclosed in 1992.
    August/ September 1993 During technical talks in New York, Iraq insisted that the BW programme comprised only limited research. This position was maintained until August 1995, when an offensive programme including agent weaponization was admitted. Since then, no further substantial information was presented to the Commission.

    Summary

    203. Since the adoption of SCR 687 (1991), in April 1991, and until July 1995, Iraq denied that it had any proscribed BW activities. Despite Iraq's denial, the Commission, through its inspection and verification procedures, was able to determine that Iraq had not provided a full and comprehensive disclosure of its biological programme nor had it accounted for items and materials acquired for that programme. The Commission reported these findings to the Security Council in April 1995. On 1 July, 1995, Iraq acknowledged that it had had an offensive BW programme, but denied weaponization. Subsequently, in August 1995, after the departure of Lt. Gen. Hussein Kamel Hassan, Iraq admitted that it had weaponized BW agents and had deployed them for combat use. However, the Commission has a far from complete understanding of all aspects of Iraq's BW programme. The Biological FFCD neither contains the required detail, nor does it cover the full scope of Iraq's BW activities. In particular, a refusal to disclose, or even discuss, details of the military aspects of the BW programme is of concern.

    204. Iraq has released information over the years very selectively. When Iraq is aware that the Commission has details of a particular event or circumstance, then a document will be released. Very little new information has been disclosed since 1995. There are many inconsistencies and contradictions in documents, personal testimony and physical evidence. However, the accumulation of inconsistencies creates patterns, which show that the FFCD is incorrect.

    205. Iraq claims to have produced, filled, deployed and unilaterally destroyed 25 Al-Hussein missile warheads intended for BW use. No evidence exists to confirm the number of warheads produced as 25, or for a greater or lesser quantity. Confusion reigns, even among Iraqi officials, over how many warheads were filled with particular BW agents. There is no evidence of the proportions of weapons filled with particular types of agents. At Al-Nibai the numbers and locations of remnants of warhead stainless steel agent containers, some of which have traces of Bacillus anthracis spores, contradict the account of the weapons' destruction in the FFCD.

    206. The FFCD states that 200 R-400 aerial bombs were manufactured for the BW programme, and that 157 of these were filled with BW agents, deployed and unilaterally destroyed. The evidence available indicates that more than 200 were available for the BW programme. Iraq admits that the numbers filled with particular agents are guesses. Statements in 1998 by Iraq have further confused this matter. The physical evidence from the remnants, accounts for less than one third of those said to have been unilaterally destroyed.

    207. From November 1990 until the cease-fire in 1991 Iraq worked to produce a system able to deliver large volumes of BW agent aerosol from high-performance aircraft. It is stated that four such drop-tank weapons were produced. The remains of three have been accounted for. There is no evidence to establish whether only four were produced nor have other details of this aspect been addressed by Iraq. In tandem with this work, Iraq attempted to develop, apparently unsuccessfully, a pilotless aircraft to carry the drop-tank weapon. Very little information exists on this latter project, and it is possible that it was intended for CW use or both BW and CW.

    208. The first weapon system for delivering BW agent investigated by Iraq was a helicopter-borne aerosol generator. Successful trials led to the manufacture of 12 such items. There is no evidence of their destruction. Also the final, and presumably most effective, prototype of this aerosol generator has never been accounted for.

    209. Besides the weapons that reached the production stage, several other potential delivery systems received some attention by Iraq. 122mm rocket warheads were extensively trialed with BW agent. Iraq claims to have abandoned this development. After briefly admitting that cluster munitions were part of the BW programme, Iraq withdrew the statement. Artillery shells filled with ricin were trialed. The LD-250 aerial bombs made by Al-Muthanna and used in early BW trials, were abandoned in favour of the more robust R-400 according to Iraq. Iraq investigated the use of gas gangrene relevant to application in fragmentation weapons.

    210. A key determinant of the size and capability of the BW programme was the production of bulk agent. Apart from one document referring to a single year, no production records have been given to the Commission. All accounts and assessments are based on the capacities of the known production equipment, the amounts of growth media purportedly available and the time and personnel that could be used. The amounts of agent produced and declared by Iraq are unsubstantiated. Quantities far greater than those declared could have been produced without difficulty. Further to complicate this process, there are no records of storage, filling into munitions or destruction. As a result, experts have very little confidence in the production figures quoted in the FFCD.

    211. The situation regarding bacterial growth media is similar to that of the production of bulk agent. There are disparities between Iraq's declared imports of media and information available to the Commission. The material balance of growth media is flawed. The absence of records of the use and discrepancies in the accountability of this material leaves open the possibility of significant undeclared production of bulk BW agent.

    212. As in other areas of the BW programme there is a dearth of documentation relating to attempts (both successful and unsuccessful) to import the equipment and materials necessary to pursue the acquisition of a larger BW capability.

    213. Research is a fundamental cornerstone of Iraq's BW programme. Although not all aspects investigated at the research level will lead directly to weapons development, the scope of the research programme is an index of the concept, strategy, and extent of the programme. No account whatever is given of review, concept, or theoretical projects undertaken by the research staff throughout the programme.

    214. The account of the history of the BW programme, given by Iraq, encompasses only a part of the programme, it is inaccurate with respect to dates, and fails to provide insight into the decision making process that facilitated its evolution. The account is misleading because it fails to present the underlying strategy and the long-term goals of the programme. Iraq's known concealment and deception activities cast doubts on its claim that the programme was obliterated in 1991.

    215. Iraq is required to provide the rationale, justification, and requirement for all sites including those for weapons tests, research and development, production, storage, weapons production and filling, deployment, and the destruction sites for weapons, documents and agents. The FFCD account fails to state the scale and scope of the requirements for the programme. No information is provided on planning and true objectives. All that has been provided by Iraq is a physical description of some components. It fails to explain the rational behind the selection of BW sites.

    216. The absence of comprehensive information about the organization of Iraq's BW programme, at all levels, and its relationship to other Iraqi bodies, makes it impossible to determine the scope and nature of the programme. An understanding of the various relationships and interconnections between the diverse organizations that contributed to the BW programme is essential to gain a full appreciation of the programme and build confidence that the account provided is indeed full and complete. The list of contributing organizations cited in the FFCD is incomplete compared to interview testimony and documentation. This can be rectified by a full disclosure of relevant information supported by documents and details of funding.

    217. A clear description of the organizations driving, influencing or otherwise participating in the BW programme is critical when assessing its dimension and significance. The lack of such descriptions reflects negatively on the credibility of accounts of research and development, production, and the selection and deployment of weapons. Further physical or documentary evidence in all these areas is needed to confirm the information presented in the FFCD.

    218. Throughout the investigation of the programme there has been a systematic and comprehensive attempt by Iraq to conceal the programme and deceive the Commission. Until 1995 all aspects of the offensive BW programme were concealed and active measures taken to deceive the Commission. Since August 1995, Iraq has submitted a number of FFCDs of its declared BW programme. These declarations have been assessed by the Commission and by international experts as incomplete, inadequate and containing substantial deficiencies. They were not accepted as a full account of the scale and the scope of Iraq's BW programme. This refers in particular to weaponization of produced BW agents, bulk BW agent produced and acquisitions for the BW programme. Consistently Iraq has tried to understate the scale and importance of the BW programme as a whole, and the success of individual components.

    219. In the Commission's view, Iraq has not complied with requirements of the relevant Security Council resolutions on the disclosure of its BW programme. A full, complete and verifiable disclosure of all its biological weapons activities needs to be presented by Iraq.



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