Aaron advises clients on compliance with U.S. and international rules designed to prevent the diversion of chemical products to illicit use in the production of chemical weapons. He has also been involved in issues related to the destruction of historic stockpiles of chemical weapons and suspected chemical weapons attacks. Examples of his work in this area are provided below.

Applicability Assessments

Aaron advises companies in a variety of industries (e.g., chemicals, electronics, and consumer products) on the extent to which the Chemical Weapons Convention (CWC) may apply to their products and operations, sometimes helping to draft requests to CWC National Authorities for determinations of the applicability of their CWC implementing statutes and regulations to particular materials and processes.

Declarations

Aaron has helped prepare annual CWC declarations of past chemical production activities and anticipated future activities for facilities worldwide, taking into account the unique requirements imposed by some countries. He has also formulated company-specific strategies for key CWC reporting issues, such as how to address chemical intermediates, confidentiality, changes in facility ownership, sites with multiple owners/operators, contract manufacturing, and delineation of individual plants within a plant site.

Inspections

Aaron provides on-site and remote representation of facilities undergoing CWC inspections by the Organization for the Prohibition of Chemical Weapons (OPCW), for example, by preparing Pre-Inspection Briefings and negotiating limits on the scope of document productions and facility tours. He has also developed a detailed guidance manual on inspections for CWC-regulated facilities worldwide.

Chemical Weapons Destruction and Response

The National Academy of Sciences appointed Aaron as the sole attorney on a committee tasked with advising the U.S. Army on certain issues at two facilities being used to destroy the nation’s remaining stockpiles of chemical weapons. He also assisted a client in developing a response to a suspected chemical weapons incident.