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:

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:

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