Russia’s attacks on Ukraine’s Zaporizhzhia nuclear power plant are shocking and dangerous. 

Since March, Russia has seized and repeatedly shelled Zaporizhzhia, the largest nuclear power plant in Europe. The shelling cut power lines to the plant and forced backup diesel generators to kick in as a last line of defense against nuclear disaster. Rafael Grossi, head of the watchdog International Atomic Energy Agency (IAEA), warns that Russia is “playing with fire” and that “something very, very catastrophic could take place.” He is pushing for a demilitarized zone around the facility to avoid catastrophe. Ukraine’s president, Volodymyr Zelenskyy, believes that Russia is trying to turn nuclear energy into a weapon on Ukrainian soil.

What should be done? Beyond an immediate need to stop Russia’s actions in Ukraine, there are calls for a longer-term solution. Some propose a robust global legal regime for the physical protection of nuclear facilities against armed attack, finding existing regulations under the IAEA and Geneva Conventions inadequate. Others argue that it would be a “bad idea” to further complicate these existing protections.

Yet in the collective search for multilateral precedents, both sides of the debate overlook a salient success: Africa’s Treaty of Pelindaba. It’s a regional accomplishment that helps illustrate the promise and pitfalls of any global pact.

Africa’s Experience

In April 1996, 45 African nations signed Pelindaba to make the continent a nuclear-weapon-free zone (NWFZ). Africa was not the first region to reach such an agreement—similar zones existed for Latin America, the South Pacific, and Southeast Asia. But unlike the others, Africa’s zone has a clause that addresses the type of assault that Russia has perpetuated against Zaporizhzhia. Under Article 11 of the treaty, parties agree “not to take, or assist, or encourage any action aimed at an armed attack by conventional or other means against nuclear installations in the African nuclear-weapon-free zone.” Any violation could be dealt with by the African Commission on Nuclear Energy, the IAEA, the Organization of African Unity, or the U.N. Security Council.  

The attack scenario envisioned by Pelindaba was not hypothetical on African soil. In December 1982, the African National Congress, an apartheid-designated terrorist organization in South Africa, bombed the continent’s only nuclear power plant at Koeberg, north of Cape Town. The four explosions delayed the completion of the Koeberg plant for a few years and dealt a propaganda blow to a South African government that had developed nuclear weapons.     

But that incident did not serve as the driving rationale for Article 11. An experience in a different region—and a broader counterproliferation strategy with a long history—took precedence. 

Preventive War: Real and Imagined

The strategy of preventive war against nuclear installations dates to the earliest days of the atomic age. To thwart a Nazi nuclear program during World War II, British commandos bombed a heavy water plant in Norway controlled by Germany. In the early 1960s, the United States considered whether to “strangle the baby in the cradle” with a preventive strike against the nuclear program of the People’s Republic of China before Beijing tested its first nuclear bomb.

For Africa, the most salient lesson came from Israel’s attack on Iraq. In a 1981 airstrike, Israel destroyed Iraq’s unfinished Osirak reactor to derail Baghdad’s nuclear program (a miscalculation, many believe). The airstrike, which killed 10 Iraqi soldiers and one French engineer, garnered widespread international condemnation. With Pelindaba, African states sought to guarantee that a similar attack could not occur against nuclear installations on their continent. The issue appeared particularly important to North African states closest to Israel’s borders.  

The U.S. voiced the greatest opposition to Article 11 during Pelindaba’s negotiations, finding the clause to create a “potentially dangerous loophole,” and considered the prohibition of attacks on “nuclear installations” too broad, as it might allow a state to house radioactive materials on a military base intended for offensive purposes. Instead, the U.S. wanted any ban on attacks to apply only to nuclear sites fully dedicated to peaceful purposes. 

The U.S. also protested the geographic scope. Article 11 implied that all states in the zone—that is, the whole continent of Africa—would be excluded from such an attack regardless of a state’s adherence to Pelindaba. The African states wanted it that way—after all, the dispersal of radioactive materials from any attack would not respect national boundaries. By contrast, it seemed to the U.S. that “aggressive non-parties [to Pelindaba] could exploit” that blanket protection to their advantage. African states, though, kept the article intact, and Pelindaba remains the only NWFZ to ban armed attacks on nuclear installations.

Looking Ahead 

Russia and the U.S. find themselves on opposite sides of the conflict in Ukraine, but both have opposed the idea of banning attacks on nuclear installations. In 2019, Russia pulled out of a protocol to the Geneva Conventions that addresses the issue, one that the U.S. never ratified; Ukraine, however, has ratified it. Past U.S. support for preventive war—along with the Department of Defense’s belief that in a time of conflict the U.S. may wish to destroy nuclear power plants to disrupt enemy power grids—makes the U.S. unlikely to support a future ban, even though U.S. Secretary of State Antony Blinken emphasizes that Russia’s attacks on Zaporizhzhia are “horrific.”     

Yet this same issue occurred with Africa. Pelindaba currently has the support of the five states recognized by international law as nuclear weapon states (China, France, Great Britain, Russia, and the U.S.). While the U.S. is the only one of the group yet to ratify Pelindaba, Secretary Blinken recently reaffirmed U.S. support for the agreement.   

Russia’s attacks on Zaporizhzhia serve as a stark reminder that the impulse to prohibit attacks on nuclear installations through legal means is the right one. As two nuclear scholars write, the goal should be to “unambiguously delegitimize this type of action” that could have global environmental and health consequences. Africa’s example shows that a regional framework can offer one model of multilateral success. To achieve a legally binding agreement, African nations sidestepped initial opposition from a nuclear superpower to establish the standard they wanted. For any future agreement, others will have to do the same.