Introduction 

Certain toxic chemicals and their precursors are subject to legal requirements under the CWC, the first arms-control treaty to introduce a verifiable ban on an entire class of weapons of mass destruction across 193 countries (including the UK). There are 3 classifications of chemicals:

• Schedule 1 – are particularly hazardous and pose a high risk. They have been developed, produced, stockpiled and used as chemical weapons and have little or no use for activities not prohibited by the CWC.

• Schedule 2 – are chemicals that can either be used as chemical weapons themselves or used in the manufacture of chemical weapons but that have small-scale applications outside of chemical warfare and so can be legitimately manufactured in small quantities.

• Schedule 3 - are chemicals which can either be used as toxic chemical weapons themselves or used in the manufacture of chemical weapons but which also have legitimate large-scale industrial uses.

If you produce, process, consume, import or export any of these chemicals you must meet the legal requirements of the CWC.

Schedule 1 Chemicals

All Schedule 1 chemical possession and usage requires a license. It is a breach of the Chemical Weapons Act 1996 to acquire, produce, possess, or use a CWC Schedule 1 chemical without an appropriate license issued by the UK National Authority based in the Department for Business, Energy and Industrial Strategy (BEIS). If you need a license for any Schedule 1 chemical, you must contact the Chemical Safety Team immediately.

Schedule 2 and 3 Chemicals

The University is required to make a retrospective annual declaration on the production, processing, consumption, and import and export of these substances. If you have bought and used in this calendar year or used any chemicals which were purchased in previous years or imported or exported or produced any of the chemicals in the Schedule 2 list, or in the Schedule 3 list, you need to fill in the relevant section of the annual return, which will take place every January.

Definitions under CWC used in the Schedule 2 and Schedule 3 returns:

• Produced – chemical synthesized through a chemical reaction and the substance isolated.

• Processed – chemical is bought into the University from an external source, and physically manipulated WITHOUT a chemical reaction taking place e.g. purification, crystallization, concentration. For example, compound X is bought from supplier Y and purified by crystallization. If the compound was created internally to the University it was PRODUCED, and no declaration should be returned for processed.

• Consumed- conversion of a chemical into another chemical through a chemical reaction involving the making or breaking of chemical bonds. For example, where a chemical which may or may not have been synthesized internally, and then is used as a reagent in a subsequent reaction.

• Imported - the physical movement of scheduled chemicals into the UK from any other place under the jurisdiction or control of another country.

• Exported- the physical movement of scheduled chemicals out of the UK into the territory or any other place under the jurisdiction or control of another country.

The following table will help you decide which sections of the CWC return you need to fill in:

Regulatory Update

Ricin CAS No. 9009-86-3 : For licensing purposes, the Ricin A chain (CAS No. 96638-28-7) and any hybrids or conjugates containing it are to be considered as Ricin itself. (The Ricin B chain and any hybrids or conjugates containing it are exempt from licensing where the Ricin A chain is not present). However, Ricin, Ricin A chain and their isotopically labelled analogues may be exempted if they are toxoids.

Please note the following additions to the CWC Schedule 1 chemicals licensing regime and Schedule 1 list of toxic chemicals (effective from 8 January 2021):

A. Toxic chemicals:

(1) Р-alkyl (H or ≤C₁₀, incl. cycloalkyl) N-(1-(dialkyl(≤C₁₀, incl. cycloalkyl)amino))alkylidene(H or ≤C₁₀, incl. cycloalkyl) phosphonamidic fluorides and corresponding alkylated or protonated salts

e.g.      N-(1-(di-n-decylamino)-n-decylidene)-P-decylphosphonamidic fluoride (CAS No. 2387495‑99-8)
            Methyl-(1-(diethylamino)ethylidene)phosphonamidofluoridate (CAS No. 2387496‑12‑8)

(2) O-alkyl (H or ≤C₁₀, incl. cycloalkyl) N-(1-(dialkyl(≤C₁₀, incl. cycloalkyl)amino))alkylidene(H or ≤C₁₀, incl. cycloalkyl) phosphoramidofluoridates and corresponding alkylated or protonated salts

e.g.      O-n-Decyl N-(1-(di-n-decylamino)-n-decylidene)phosphoramidofluoridate (CAS No. 2387496-00-4)
            Methyl (1-(diethylamino)ethylidene)phosphoramidofluoridate (CAS No. 2387496‑04‑8)
            Ethyl (1-(diethylamino)ethylidene)phosphoramidofluoridate (CAS No. 2387496-06-0)

(3) Methyl-(bis(diethylamino)methylene)phosphonamidofluoridate (CAS No. 2387496-14-0)

(4) Carbamates (quaternaries and bisquaternaries of dimethylcarbamoyloxypyridines)

Quaternaries of dimethylcarbamoyloxypyridines:
1-[N,N-dialkyl(≤C₁₀)-N-(n-(hydroxyl, cyano, acetoxy)alkyl(≤C₁₀)) ammonio]-n-[N-(3-dimethylcarbamoxy-α-picolinyl)-N,N-dialkyl(≤C₁₀) ammonio]decane dibromide (n=1-8)
e.g.      1-[N,N-dimethyl-N-(2-hydroxy)ethylammonio]-10-[N-(3-dimethylcarbamoxy-α-picolinyl)-N,N-dimethylammonio]decane dibromide (CAS No. 77104-62-2)

Bisquaternaries of dimethylcarbamoyloxypyridines:
1,n-Bis[N-(3-dimethylcarbamoxy-α-picolyl)-N,N-dialkyl(≤C₁₀) ammonio]-alkane-(2,(n-1)-dione) dibromide (n=2-12)

e.g.      1,10-Bis[N-(3-dimethylcarbamoxy-α-picolyl)-N-ethyl-N-methylammonio]decane-2,9-dione dibromide (CAS No. 77104-00-8).

What legislation applies?

• The Chemical Weapons Act 1996
• Anti-terrorism, Crime and Security Act 2001
• Governmental guidance

Last reviewed: 2 December 2024; Next review: 1 December 2025