VZCZCXRO9875
PP RUEHSL
DE RUEHC #8010/01 2361736
ZNR UUUUU ZZH
P 241718Z AUG 09
FM SECSTATE WASHDC
TO AUSTRALIA GROUP COLLECTIVE PRIORITY
RUEHKV/AMEMBASSY KYIV PRIORITY 1151
RUEHVB/AMEMBASSY ZAGREB PRIORITY 3173
INFO RUEKJCS/SECDEF WASHINGTON DC PRIORITY
RHMFISS/JOINT STAFF WASHINGTON DC PRIORITY
RUEAIIA/CIA WASHINGTON DC PRIORITY
RUCPDOC/USDOC WASHINGTON DC PRIORITY 5535
RHMCSUU/DEPT OF ENERGY WASHINGTON DC PRIORITY

UNCLAS SECTION 01 OF 03 STATE 088010 
 
SIPDIS 
SENSITIVE 
 
E.O. 12958: N/A 
TAGS: PARM PREL
SUBJECT: AUSTRALIA GROUP: ESTABLISHING MINIMUM SURFACE 
COATING THICKNESS FOR LINED CHEMICAL EQUIPMENT (#4 OF 4) 
 
¶1.  (U) This is an action request.  Please see paragraph 2. 
 
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ACTION REQUEST 
-------------- 
 
¶2.  (SBU) Drawing on the background below, Department 
requests AG country Embassies provide the non-paper in 
paragraph 6 to appropriate host government officials and 
elicit a response. (Note: This is the last of four cables 
conveying U.S. proposals. End Note)  In delivering this 
non-paper, posts should indicate that the U.S. is sharing 
this non-paper as part of preparations for the September 
21-25 AG plenary and that we would appreciate hearing their 
views or any suggestions they may have on the non-paper. 
Also, request Embassy Canberra provide the non-paper to the 
AG chair for circulation as an official AG document. 
 
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REPORTING DEADLINE 
------------------ 
 
¶3.  (U) Embassy should report results of this demarche by 
cable before September 7.  Please contact ISN/CB Andrew Souza 
at 202-647-4838 or via e-mail for further information. 
 
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BACKGROUND 
---------- 
 
¶4.  (SBU) The manufacturing process for many chemical warfare 
agents can be extremely caustic, requiring equipment that is 
made of specialized corrosion and heat-resistant materials. 
To help limit the proliferation of chemical weapons, the 
40-country Australia Group (AG) has agreed to require 
government permission for exports of this specialized 
chemical production equipment.  For this year's AG plenary 
session, the United States will present three proposals to 
refine this control list for dual-use chemical equipment. 
One proposal is to address the increasing use of wear 
coatings to protect controlled chemical production equipment 
during shipping (the other three proposals will be sent 
septel). 
 
¶5.  (SBU) U.S. chemical equipment manufacturers sometimes 
apply a thin layer of scratch-resistant material to the 
interior surfaces of their products to keep them clean or 
protect them from damage during shipping, often referred to 
as a 'wear coating.'  Some of these coatings are made from 
the same corrosion-resistant fluoropolymers used to line the 
specialized chemical production equipment controlled by the 
AG.  This can make it difficult to determine whether or not 
the equipment can be used to produce chemical warfare agents. 
 Since fluoropolymer coatings less than a few millimeters 
tend to have too many surface defects to reliably produce 
chemical warfare agents, the U.S. believes the AG should 
adopt a technical note that excludes equipment with 
fluoropolymer coatings less than 2.5mm thick from the Group's 
current controls for dual-use chemical equipment.  We also 
believe the technical note should also indicate that the AG 
controls extend to corrosion-resistant chemical production 
equipment that is shipped with a wear coating made of 
material that is not corrosion-resistant. 
 
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NON-PAPER 
--------- 
 
¶6.  (SBU) Begin text of non-paper: 
 
AG-In-Confidence 
 
AUSTRALIA GROUP 
 
Australia Group Doc 
AG/Jul09/CL/USA/xx 
 
Minimum Surface Coating Thickness for Controlled Chemical 
Equipment 
 
 
STATE 00088010  002 OF 003 
 
 
Issue 
 
Should the Australia Group (AG) specify a minimum surface 
thickness of listed coating materials on the Control List for 
Dual-Use Chemical Manufacturing Facilities and Equipment and 
Related Technology and Software? 
 
Background 
 
At the April 2008 AG Plenary, the United States tables a 
non-paper on clarifications to controls for dual-use chemical 
equipment.  One of the concerns discussed in the paper was 
very thin coatings of controlled materials of construction. 
We posed the question, "Is there any minimum thickness 
required in order for a surface to be considered in contact 
with the chemical(s) being processed?" 
 
For example, some U.S. manufacturers produce chemical 
equipment with with very thin layers of controlled materials, 
primarily fluoropolymers, on top of non-controlled materials. 
 In many instances, the coating is intended to be protective 
coating for shipping purposes.  Other manufacturers produce 
chemical with an additional thin layer of abrasion-resistant 
coating made of non-controlled materials on top of controlled 
materials. 
 
Based on our discussions with AG members during the plenary, 
the United States would to present additional information on 
this issue and recommend the AG consider revising the control 
list for dual-use chemical equipment. 
 
Discussion 
 
Organic coatings, such as fluoropolymers, are frequently used 
as linings in controlled dual-use chemical equipment as an 
effective and economic means of controlling corrosion.  The 
presence of a controlled surface layer may not necessarily 
make the equipment appropriate for handling the chemical 
weapons precursors identified on the Control List for 
Chemical Weapons Precursors.  The coating may be present just 
for sanitation reasons (e.g. in the preparation of food or 
beverages) or for protection during shipping. 
 
At a minimum, organic surface coatings of more than 0.75mm 
(0.03 inch) are needed to prevent immediate and rapid attack 
of the underlying substrate metal.  Furthermore, thin 
coatings, even with thicknesses of greater than 0.75mm, may 
contain defects, be damaged in service or may be selectively 
permeable to some liquids, all of which can lead to corrosion 
of the substrate metal and resultant failure in service of 
the equipment, even though the coating material is still 
resistant.  Therefore, reliable organic coatings for 
corrosive service (fluoropolymers) should have a thickness 
greater than 2.5mm (0.1 inch) (For more information, see 
Perry's Chemical Engineer's Handbook, 7th Edition, by H.R. 
Perry and D.W. Green). 
 
A different, but related problem is when an over-coating of 
abrasion-resistant material is placed on top of a controlled 
material.  This can lead to similar classification 
difficulties.  Therefore, we recommend adopting a minimum 
surface coating thickness of greater than 2.5mm for all 
non-controlled materials placed on top of controlled 
materials.  Thin surface coatings of non-controlled materials 
with thicknesses of 2.5mm (0.10 inch) or less present on top 
of controlled materials should not be considered when 
classifying chemical manufacturing equipment. 
 
In the absences of a minimum surface thickness criterion, 
minimal surface coatings that provide little or no corrosion 
protection can make classifying chemical manufacturing 
equipment difficult.  However, we understand that metal 
alloying technologies, such as Tantaline, exist, which may be 
able to provide reliable corrosion protection in much thinner 
layers, on the order of 0.05mm (0.002 inch.  Also, some AG 
partners have expressed concern about the difficulty of 
enforcing a more general minimum surface thickness criterion, 
applicable to all controlled materials.  Therefore, this 
recommendation for a minimum surface thickness for control is 
limited to fluoropolymers only, which is our primary concern. 
 
A different, but related problem is when an over coating of 
abrasion-resistant material is placed on top of a controlled 
material.  This can lead to similar classification 
difficulties.  Therefore, we recommend adopting a surface 
 
STATE 00088010  003 OF 003 
 
 
coating thickness threshold of greater than 2.5 mm (0.10 
inch) for all non-controlled materials place on top of 
controlled materials.  Surface coatings of non-controlled 
materials with thicknesses of 2.5 mm (0.10 inch) or less 
present on top of controlled materials should not be 
considered when classifying chemical manufacturing equipment. 
 
Recommendation 
 
The United States recommends the Control List for Dual-Use 
Chemical Manufacturing Facilities and Equipment and Related 
Technology and Software include the following technical note: 
 
Technical note: surface coatings made from fluoropolymers 
with a minimum surface thickness of 2.5mm (0.1 inch) or less 
shall be disregarded when classifying dual-use chemical 
equipment.  In addition, surface coatings of non-controlled 
abrasion-resistant materials on top of controlled materials 
shall be disregarded when classifying dual-use chemical 
equipment when the non-controlled material has a surface 
thickness of 2.5 mm (0.10 inch) or less. 
 
End non-paper. 
 
¶7.  (U) Please begin all responses with AUSTRALIA GROUP and 
slug for ISN. 
 
¶8.  (U) Department thanks posts for their support. 
CLINTON