Bioterrorism
A Threat to Agriculture and the Food Supply
Gao ID: GAO-04-259T November 19, 2003
When the President created the Department of Homeland Security, he included U.S. agriculture and food industries in the list of critical infrastructures needing protection. The Secretaries of Agriculture and of Health and Human Services have publicly declared that the U.S. food supply is susceptible to deliberate contamination. GAO was asked to provide an overview of the potential vulnerabilities of the food supply and agriculture sector to deliberate contamination and to summarize four recent GAO reports that identified problems with federal oversight that could leave the nation's agriculture and food supply vulnerable to deliberate contamination.
Bioterrorism attacks could be directed at many different targets in the farm-to-table food continuum, including crops, livestock, food products in the processing and distribution chain, wholesale and retail facilities, storage facilities, transportation, and food and agriculture research laboratories. Experts believe that terrorists would attack livestock and crops if their primary intent was to cause severe economic dislocation. The U.S. agriculture sector accounts for about 13 percent of the gross domestic product and 18 percent of domestic employment. Terrorists may decide to contaminate finished food products if harm to humans was their motive. Four recent GAO reports found gaps in federal controls for protecting agriculture and the food supply. Thus, the United States would be vulnerable to deliberate efforts to undermine its agriculture industries, deliberate tampering of food during production, and the release of deadly animal diseases, some of which also affect humans. GAO found, for example, border inspectors were not provided guidance on foot-and-mouth disease prevention activities in response to the 2001 European outbreak, inspection resources could not handle the magnitude of international passengers and cargo, and new technology used to scan shipments at a bulk mail facility was operating only part-time and in only that facility. Such careful controls over imported foods can help to prevent pathogens from contaminating U.S. cattle with devastating diseases that have struck many other countries. GAO also found that federal overseers did not have clear authority to impose requirements on food processors to ensure security at those facilities. Finally, GAO found security problems at Plum Island--a large government-operated animal disease research facility. GAO found that scientists from other countries, facility workers, and students had access to areas containing high-risk pathogens without having completed background checks and the required escorts. Following are the four reports discussed in this testimony: (1) Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain Vigilant and Resolve Outstanding Issues, U.S. General Accounting Office, GAO-02-808 (Washington, D.C.: July 26, 2002); (2) Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002); (3) Food-Processing Security: Voluntary Efforts Are Under Way, but Federal Agencies Cannot Fully Assess Their Implementation, U.S. General Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 2003); and (4) Combating Bioterrorism: Actions Needed to Improve Security at Plum Island Animal Disease Center, U.S. General Accounting Office, GAO- 03-847 (Washington, D.C.: September 19, 2003).
GAO-04-259T, Bioterrorism: A Threat to Agriculture and the Food Supply
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Testimony:
Before the Committee on Governmental Affairs, U.S. Senate:
United States General Accounting Office:
GAO:
For Release on Wednesday:
November 19, 2003:
Bioterrorism:
A Threat to Agriculture and the Food Supply:
Statement for the Record by Lawrence J. Dyckman, Director Natural
Resources and Environment:
GAO-04-259T:
GAO Highlights:
Highlights of GAO-04-259T, a Statement for the Record for the
Committee on Governmental Affairs, U.S. Senate
Why GAO Did This Study:
When the President created the Department of Homeland Security, he
included U.S. agriculture and food industries in the list of critical
infrastructures needing protection. The Secretaries of Agriculture
and of Health and Human Services have publicly declared that the U.S.
food supply is susceptible to deliberate contamination. GAO was asked
to provide an overview of the potential vulnerabilities of the food
supply and agriculture sector to deliberate contamination and to
summarize four recent GAO reports that identified problems with
federal oversight that could leave the nation‘s agriculture and food supply vulnerable to deliberate contamination.
What GAO Found:
Bioterrorism attacks could be directed at many different targets in
the farm-to-table food continuum, including crops, livestock, food
products in the processing and distribution chain, wholesale and
retail facilities, storage facilities, transportation, and food and
agriculture research laboratories. Experts believe that terrorists
would attack livestock and crops if their primary intent was to cause
severe economic dislocation. The U.S. agriculture sector accounts for
about 13 percent of the gross domestic product and 18 percent of
domestic employment. Terrorists may decide to contaminate finished
food products if harm to humans was their motive.
Four recent GAO reports found gaps in federal controls for protecting
agriculture and the food supply. Thus, the United States would be
vulnerable to deliberate efforts to undermine its agriculture
industries, deliberate tampering of food during production, and the
release of deadly animal diseases, some of which also affect humans.
GAO found, for example, border inspectors were not provided guidance
on foot-and-mouth disease prevention activities in response to the
2001 European outbreak, inspection resources could not handle the
magnitude of international passengers and cargo, and new technology
used to scan shipments at a bulk mail facility was operating only part-
time and in only that facility. Such careful controls over imported
foods can help to prevent pathogens from contaminating U.S. cattle
with devastating diseases that have struck many other countries. GAO
also found that federal overseers did not have clear authority to
impose requirements on food processors to ensure security at those
facilities. Finally, GAO found security problems at Plum Island”a
large government-operated animal disease research facility. GAO found
that scientists from other countries, facility workers, and students
had access to areas containing high-risk pathogens without having
completed background checks and the required escorts.
Following are the four reports discussed in this testimony:
* Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain
Vigilant and Resolve Outstanding Issues, U.S. General Accounting
Office, GAO-02-808 (Washington, D.C.: July 26, 2002).
* Mad Cow Disease: Improvements in the Animal Feed Ban and Other
Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S.
General Accounting Office, GAO-02-183 (Washington, D.C.: January 25,
2002).
* Food-Processing Security: Voluntary Efforts Are Under Way, but
Federal Agencies Cannot Fully Assess Their Implementation, U.S.
General Accounting Office, GAO-03-342 (Washington, D.C.: February 14,
2003).
* Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center, U.S. General Accounting Office,
GAO-03-847 (Washington, D.C.: September 19, 2003).
What GAO Recommends:
The four GAO reports included recommendations to (1) the U.S.
Department of Agriculture and the Food and Drug Administration (FDA)
to strengthen import checks for detecting mad cow and foot-and-mouth
diseases and to address security matters at food processors; (2) FDA
to strengthen enforcement of the feed ban; and (3) the Department of
Homeland Security to correct security deficiencies at Plum Island. The
agencies generally agreed with GAO‘s recommendations and have taken,
or are in the process of taking, actions to address the problems GAO
found.
www.gao.gov/cgi-bin/getrpt?GAO-04-259T
To view the full statement, click on the link above. For more
information, contact Lawrence J. Dyckman at 202-512-3841 or
dyckmanl@gao.gov.
[End of section]
Madam Chairman and Members of the Committee:
I appreciate the opportunity to submit this statement for the record on
the results of our work on potential threats, vulnerabilities, and
risks faced by the nation's agriculture sector and its food supply. As
you know, protecting the nation's agriculture industries and food
supply has taken on increased sense of urgency in the wake of the
terrorist attacks of September 11, 2001. And there is now broad
consensus that American farms, food, and agriculture systems, which
account for about 13 percent of the nation's gross domestic product,
are vulnerable to potential attack and deliberate contamination.
In his October 2001 executive order establishing the Office of Homeland
Security, the President added agriculture and food industries to the
list of critical infrastructure sectors needing protection--
acknowledging that the agriculture sector and the food supply are
indeed vulnerable to bioterrorism. Both the Secretaries of Agriculture
and of Health and Human Services have also publicly recognized that the
U.S. food supply is susceptible to deliberate contamination. Within
this backdrop, federal and state government agencies; industry; and
academic institutions have taken steps, such as, assessing the
potential threats, risks, and vulnerabilities and developing plans to
rapidly detect and respond to any attack on the nation's agriculture
sector and food supply.
This statement (1) provides a brief overview of the potential
vulnerabilities of the food supply and agriculture sector to deliberate
contamination and (2) summarizes four recent GAO reports identifying a
range of problems with federal oversight that could leave the nation's
agriculture sector and food supply vulnerable to intentional
contamination. Included in this discussion are our 2002 reports on
federal efforts to prevent devastating animal diseases--foot-and-mouth
and bovine spongiform encephalopathy (BSE), also known as mad cow--from
entering the United States, and our 2003 reports on security at food-
processing facilities and at the Plum Island Animal Disease Center.
Plum Island studies serious animal diseases, including some that can
cause illness and death in humans. The four reports are discussed in
greater detail in appendix I, which also provides the link to each
report on GAO's Web page.
Summary:
The U.S. agriculture and food sectors have features that make them
vulnerable to bioterrorism attacks. These attacks could be directed at
many different targets in the farm-to-table food continuum--including
crops, livestock, food products in the processing and distribution
chain, wholesale and retail facilities, storage facilities,
transportation, and food and agriculture research laboratories. Indeed,
chemicals and infectious pathogens could be intentionally introduced at
various points in that continuum. Most experts believe that terrorists
would choose to attack livestock and crops if their primary intent was
to cause severe economic dislocation. Such an attack would cause severe
disruption--the U.S. agriculture sector accounts for about 13 percent
of the U.S. gross domestic product and 18 percent of domestic
employment. On the other hand, terrorists would choose to contaminate
finished food products if harm to humans was their motive.
Four recently issued GAO reports found gaps in federal controls for
protecting agriculture and the food supply. As a result of those gaps,
the United States would be vulnerable to deliberate efforts to
undermine its agriculture industries, intentional tampering of food
during production, and the release of deadly animal diseases, some of
which also affect humans. We found, among other things, that the volume
of imported items entering the United States made it impossible for
border inspectors to physically inspect every incoming cargo container
or each and every international passenger's luggage--key pathways
through which foot-and-mouth disease could enter the country. We also
found that new equipment used to scan shipments at one large import
bulk mail facility was operating only part-time and in only that bulk
mail facility. We also reported that discrepancies in the accuracy of
documents provided by the importer posed a risk that BSE-contaminated
food might not be flagged for further inspection. Those careful
controls over imported foods help prevent pathogens from contaminating
American cattle with devastating diseases that have struck many other
countries. In addition, we found that federal overseers did not have
clear authority to impose requirements on food processors to ensure
security at those facilities. And finally, we found security problems
at Plum Island. For example, several scientists from other countries,
facility workers, and students had access to areas containing high-risk
pathogens, even though their background checks were incomplete and they
did not have the required escorts.
Overview of the Vulnerability of the U.S. Agriculture Sector and Food
Supply to Intentional Contamination:
Our current agriculture and food sectors have features that make them
vulnerable to terrorist attacks. These include the high concentration
of our livestock industry and the centralized nature of our food-
processing industry. As a result, chemicals and infectious pathogens
can be intentionally added at various points along the farm-to-table
food continuum. Whether terrorists target food products or animals and
crops for deliberate contamination, serious public health and economic
consequences are at stake. The mere threat of such an attack would
seriously undermine consumer confidence in the safety of our food
supply and destabilize export markets.
The U.S. agriculture sector and food supply have been largely secure
from deliberate contamination, except for a few such incidents. In
1984, for example, in what federal agencies describe as the first
recorded event of bioterrorism in the United States, a cult group
poisoned salad bars at several Oregon restaurants with Salmonella
bacteria. As a result, 750 people became ill. A recent, deliberate food
contamination also highlights how easily someone intent on causing harm
can do so. In January 2003, the Centers for Disease Control and
Prevention reported that 92 persons became ill after purchasing ground
beef from a Michigan supermarket that was intentionally contaminated
with nicotine. An employee of the supermarket that sold the
contaminated meat has been indicted for intentionally poisoning 200
pounds of meat sold in his supermarket.
Naturally occurring outbreaks of diseases affecting livestock, as well
as accidental contamination of food, further illustrate the potentially
horrific effects of a deliberate and carefully choreographed event. For
example, the United Kingdom has estimated that its outbreak of foot-
and-mouth disease resulted in over $10 billion (U.S.) in losses to
tourism and the food and agriculture sectors and the slaughter of over
4 million animals. Estimates of direct costs for a similar outbreak in
the United States run as high as $24 billion with the destruction of
about 13 million animals. Terrorists seeking ways to harm the United
States could deliberately introduce foreign animal diseases into the
country. In addition, according to a recent media report, the USDA
calculated that a foot-and-mouth disease outbreak could spread to 25
states in as little as 5 days. Furthermore, according to the media
report, a simulation exercise by the National Defense University in
June 2002 predicted that a foot-and-mouth disease outbreak could spread
to more than one-third of the nation's cattle herds. As that exercise
demonstrated, diseases affecting livestock could have significant
impacts on the U.S. economy and consumer confidence in the food supply.
With regard to food, one large-scale U.S. foodborne illness outbreak in
1994 sickened 224,000 people nationwide with Salmonella enteritis from
eating a national brand of ice cream. That outbreak, though not
deliberate in nature, is estimated to have cost about $18.1 million in
medical care and time lost from work. Widely publicized illness
outbreaks in 2002 resulted in illnesses, deaths, and costly food
recalls. One involved ground beef produced by a plant in Colorado that
caused at least 46 people in 16 states to become ill from E. coli
O157:H7. The plant conducted a recall to remove about 18 million pounds
of potentially contaminated beef that had entered commerce. The other
outbreak involved fresh and frozen ready-to-eat turkey and chicken
products. Those products, manufactured in a Pennsylvania plant, carried
Listeria monocytogenes, caused 46 illnesses in eight states, as well as
seven deaths and three stillbirths or miscarriages. The plant recalled
approximately 27.4 million pounds of potentially contaminated poultry
products that had entered commerce. However, most foodborne illnesses
are not reported and the vast majority of foodborne outbreaks are never
traced to a specific food source.
Recent GAO Reports Identified Weaknesses in U.S. Systems for Protecting
Livestock and the Food Supply and Preventing the Release of Animal
Diseases that Present Human Health Risks:
We recognize that the U.S. Department of Agriculture (USDA) and the
Food and Drug Administration (FDA)--the federal agencies with primary
responsibility for safeguarding our agriculture and food sectors--have
stepped up their prevention and response efforts. In addition, we
recognize the concerted efforts to better safeguard U.S. borders that
have been taken over by the Department of Homeland Security, which also
recently took over the operation of the Plum Island Animal Research
Facility from USDA. Nevertheless, serious questions remain about
whether the agriculture sector and the food supply are sufficiently
prepared for deliberate acts of terrorism. Over the last 10 years, GAO
has issued many reports that, in aggregate, portray a national food
safety system that is fragmented and problem-laden. It is that system,
however, on which the nation must depend to prevent, prepare against,
and respond to bioterrorism events against our food supply.
Four recently issued GAO reports, in particular, identified weaknesses
in federal systems for protecting U.S. livestock against devastating
animal diseases and ensuring security at food-processing facilities and
at Plum Island--the nation's principal diagnostics laboratory for
foreign animal diseases, including some that can transfer to humans.
The information from these four reports will not provide a
comprehensive presentation of potential risks; there are certainly
other potential targets in the farm-to-table food continuum, including
the food transportation sector, that we have not yet examined for
vulnerability to intentional contamination. These reports do,
nonetheless, highlight weaknesses in U.S. systems for protecting
critical agriculture and food safety sectors.
Two reports we issued in 2002--on foot-and-mouth disease and on mad cow
disease--examined, among other things, U.S. measures for preventing
those diseases from entering the United States.[Footnote 1] We found
that, because of the sheer magnitude of international passengers and
cargo that enter this country on a daily basis and the inspection
resources that are available, completely preventing the entry of those
diseases may be infeasible. Foot-and-mouth disease can be carried on
the shoes of international passengers and the packages they carry, in
international mail, and in garbage from international carriers. We
found that USDA did not provide timely guidance to border inspectors
for screening cargo and international passengers after foot-and-mouth
disease struck Europe in 2001. We also reported that only one
international bulk mail facility used new scanning equipment to help
inspectors more accurately identify products potentially carrying
animal diseases that could contaminate U.S. cattle.
Our 2003 report on food-processing security noted that experts from
government and academia agreed that terrorists could use food products
as a vehicle for introducing harmful chemical or biological agents into
the food supply.[Footnote 2] We found that USDA and FDA had each,
independently, published comprehensive security guidelines for
processors to help them prevent or mitigate the risk of deliberate
contamination at their facilities. Additionally, we reported that USDA
and FDA did not have clear authority to require processors to take
safety measures, such as installing fences, alarms, or outside
lighting. These measures could improve security in the event of
deliberate contamination. In addition, the field personnel at the two
agencies did not have adequate training on security matters, which
would hamper their ability to conduct informed discussion with
processing plant personnel.
In September 2003, we also reported fundamental concerns with security
at the Plum Island Animal Disease Center that leave the facility
vulnerable to security breaches.[Footnote 3] We found that alarms and
door sensors for the biocontainment area were not fully operational;
outdoor lighting was not adequate to support security cameras; and
certain assets, including the foot-and-mouth disease vaccine bank, were
not adequately protected. Controls over access to the pathogens were
also inadequate--scientists from other countries were given access to
the biocontainment area without escorts while their background checks
were incomplete; no background checks were done on students attending
classes in the biocontainment area; and the cleaning crew were among
the unauthorized staff entering the biocontainment area unescorted.
Controlling access to pathogens is critical because a tiny quantity of
pathogen could be removed without being detected and developed into a
weapon. Lastly, we found that the security guards protecting the Island
had been operating without authority to carry firearms or to make
arrests; the facility's written plans for responding to a terrorist
incident exceeded the capability of its security system and the
emergency response plans were not adequately coordinated with state and
local emergency and law enforcement responders. Our report noted that
the Department of Homeland Security officials agreed with our
identification of these problems and stated that they had initiated
actions to address our concerns.
The four reports made recommendations to USDA, FDA, and the Department
of Homeland Security for correcting the problems we found, and the
agencies generally agreed with our recommendations. Appendix I
discusses the four reports, our recommendations, and the agencies'
positions in greater detail.
Contacts and Acknowledgments:
For future contacts regarding this statement, please contact Lawrence
J. Dyckman at 202-512-3841. Individuals making key contributions to
this statement included Maria Cristina Gobin, Erin Lansburgh, Charles
Adams, and Clifford Diehl. This statement will also be available on the
GAO Web site at http://www.gao.gov.
[End of section]
Appendix I: Recent GAO Reports Highlight Gaps in Federal Efforts to
Protect Agriculture and the Food Supply:
Four recently issued GAO reports identified weaknesses in federal
systems for protecting U.S. livestock against devastating animal
diseases and ensuring security at food-processing facilities and at
Plum Island--the nation's principal diagnostics laboratory for animal
diseases. The following reports highlight weaknesses in U.S. systems
for protecting critical agriculture and food safety sectors:
* Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain
Vigilant and Resolve Outstanding Issues, U.S. General Accounting
Office, GAO-02-808 (Washington, D.C.: July 26, 2002).
Because the livestock industry is a key element of the U.S.
agricultural sector and economy, protecting U.S. livestock from foot-
and-mouth disease is an important federal responsibility. The 2001
outbreak of this disease in the United Kingdom clearly illustrated the
destruction that this highly contagious animal disease can cause to a
nation's livestock industry and other sectors of the economy. Foot-and-
mouth disease is one of the most devastating viral animal diseases
affecting cloven-hoofed animals--such as cattle and swine--and has
occurred in most countries of the world at some point over the past
century. The last foot-and-mouth disease outbreak in the United States
was in 1929.[Footnote 4] According to federal officials, even a single
case of the disease would cause our trading partners to prohibit U.S.
exports of live animals and animal products and could result in losses
of between $6 billion and $10 billion a year while the country
eradicated the disease and until it regained disease-free status.
As part of our study, we examined whether U.S. measures for preventing
foot-and-mouth disease from entering the United States were effective
and whether the United States could respond quickly and effectively to
an outbreak of the disease if it were to occur.
We found that, because of the sheer magnitude of international
passengers and cargo that enter this country on a daily basis,
completely preventing the entry of foot-and-mouth disease may be
infeasible. The volume of incoming items make it impossible for border
inspectors to physically inspect every incoming cargo container or each
international passenger's luggage. The U.S. Department of Agriculture
(USDA) has identified key pathways through which this highly contagious
disease might enter the United States, such as on imported live animals
or animal products; on the shoes of, or in packages carried by,
international passengers; in international mail; and in garbage from
international carriers. We also reported that, after the foot-and-mouth
disease outbreak in the United Kingdom in 2001, USDA did not inform
Customs of its decision to prohibit or restrict certain products or
more vigilantly screen passengers arriving at U.S. ports of entry from
the United Kingdom. USDA did not provide such official guidance until
the Acting Commissioner of Customs formally requested such information
more than a month after the outbreak began in the United Kingdom. USDA
and the Department of Homeland Security (DHS) are working to increase
defenses against diseases entering through those pathways.
We further reported that, should preventive measures fail, and the
United States experience an outbreak, the country would face challenges
in responding quickly and effectively. While considerable planning and
testing of emergency response plans had occurred, we noted several
factors that could limit a rapid response to a foot-and-mouth disease
outbreak, including (1) the need for rapid disease identification and
reporting; (2) effective communication, coordination, and cooperation
between federal, state, and local responders; (3) an adequate response
infrastructure, including equipment, personnel, and laboratory
capacity; and (4) clear animal identification, indemnification, and
disposal policies.
Our report recommended that USDA develop a formal mechanism to notify
Customs as outbreaks of foot-and-mouth disease spread in other
countries and develop uniform, nontechnical procedures that Customs
inspectors could use to process international passengers and cargo
arriving from disease-affected countries. USDA agreed with our
recommendations. It said it would work with DHS to ensure that formal
protocols are established for the seamless communication of animal
disease risk information for border inspection.
* Mad Cow Disease: Improvements in the Animal Feed Ban and Other
Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General
Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002).
Mad cow disease--or BSE--is an always fatal, neuro-degenerative disease
that had been found in cattle in 23 countries around the world at the
time we issued this report. Cattle contract the disease through feed
that contains protein derived from the remains of diseased animals.
Scientists generally believe an equally fatal disease in humans--known
as variant Creutzfeldt-Jacob Disease--is linked to eating beef from
cattle infected with BSE; over 100 people have died from the human
variant. During long incubation periods--2 to 8 years in cattle and
possibly up to 30 years in humans--the disease is undetectable.
As part of our study, we assessed the effectiveness of federal actions
to prevent the emergence and spread of BSE and ensure compliance with
the animal feed ban.
We found, among other things, that federal actions could not
sufficiently ensure that all BSE-infected animals or products would be
kept out of the United States or that if BSE were found, it would be
detected promptly and not spread to other cattle through animal feed or
enter the human food supply. The United States had imported about 125
million pounds of beef (0.35 percent of total imported) and about 1,000
cattle (0.003 percent of total imported) from countries that later
discovered BSE--during the period when BSE would have been incubating.
We reported that USDA's and the Food and Drug Administration's (FDA)
import inspection capacity had not kept pace with the growth of
imports. We also found that the one international bulk mail facility
that used the newest technology in scanning equipment that would help
inspectors more accurately identify products that could carry BSE was
not being used during periods of operation when inspectors were not on
duty. We further reported that Customs found discrepancies with the
accuracy of importer-provided information and, as a result, BSE-risk
imports may go undetected.
We also reported that FDA's enforcement of the feed ban, which was put
in place to prevent the spread of BSE if it were found in U.S. cattle,
was limited and that FDA inspection data were flawed. FDA had not
identified and inspected all firms subject to the ban and had not acted
promptly to compel firms to keep prohibited proteins out of cattle feed
and to label animal feed that cannot be fed to cattle. FDA's data on
inspections of feed facilities were so severely flawed that the agency
could not know the full extent of industry compliance.
We noted that, if BSE were found in the United States, the economic
impact on the $56 billion beef industry could be devastating--consumers
might refuse to buy domestic beef; beef exports could decline
dramatically; and sales in related industries, such as hamburger chains
and soup and frozen dinner manufacturers, could be similarly affected.
We recommended that USDA and FDA, among other things, develop a
coordinated strategy to identify resources needed to increase
inspections of imported goods and that FDA strengthen enforcement of
the feed ban and its management of inspection data. USDA and FDA agreed
with these recommendations. Additional funds were requested and
approved to strengthen border inspections. FDA has increased the number
of feed-ban compliance inspections, and implemented a new feed-ban
inspection data system.
* Food-Processing Security: Voluntary Efforts Are Under Way, but
Federal Agencies Cannot Fully Assess Their Implementation, U.S. General
Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 2003).
The food-processing sector is generally described as the middle segment
of the farm-to-table continuum--it extends from the time livestock and
crops leave the farm for slaughter and processing until food products
reach retail establishments and the consumer. Experts from government
and academia agreed that terrorists could use food products as a
vehicle for introducing harmful chemical or biological agents into the
food supply. In June 2002, the National Academies had also reported
that terrorists could use toxic chemicals or infectious agents to
contaminate food production facilities and that FDA should act promptly
to extend the use of its Hazard Analysis and Critical Control Point
methods for ensuring food safety to deal with the risk of deliberate
contamination.[Footnote 5] The Centers for Disease Control and
Prevention had also reported on the need for vigilance in protecting
food and water supplies. Within this context, in 2002 we examined
federal efforts to enhance security at food-processing facilities.
We reported that the two agencies with primary responsibility for
ensuring for food safety--USDA and FDA--had each, independently,
published comprehensive security guidelines for food processors to help
them identify measures to prevent or mitigate the risk of deliberate
contamination at their production facilities. Both agencies encouraged
processors to review their current operations and to adopt those
measures that they believed would be best suited for their facilities.
FDA's guidance contains over 100 suggested security measures and USDA's
some 68 such items. Among other things, the guidelines included
recommendations for improving personnel security by conducting
screening and background checks and controlling entry into the
facilities; securing hazardous materials by controlling access to
storage areas; improving outside security by monitoring all access to
the establishment; installing lighting; ensuring that in-house
laboratories have comprehensive and validated security and disposal
procedures in place; and that parking areas are a safe distance from
the facility.
However, we also reported that USDA and FDA had determined that their
existing statutes did not provide them with absolutely clear authority
to impose security requirements at food-processing facilities. For
example, neither agency had authority to require processors to
implement measures to enhance security outside the food-processing
environment, such as installing fences, alarms, or outside lighting.
Nor did the agencies believe they had authority to require food
processors to conduct employee background checks. Because of these
uncertainties about their authority, the security guidelines they gave
food processors are voluntary. Since the guidelines were voluntary,
USDA and FDA have not been enforcing, monitoring, or documenting their
implementation. We also found that most of USDA's and FDA's field staff
had not received training on security matters. And, although the field
staff were instructed to be vigilant and on "heightened alert," they
were also told not to document or report their observations regarding
security at the plants because the information could be obtained under
a Freedom of Information Act request.
We also reported on recent congressional efforts to protect the
nation's drinking water from terrorist acts that may offer a model for
FDA and USDA to help them monitor security measures at food-processing
facilities and to identify any gaps that may exist. Specifically, the
Public Health Security and Bioterrorism Preparedness and Response Act
of 2002 requires community water systems to assess their vulnerability
to terrorist attacks and develop emergency plans to prepare and respond
to such events. They are also required to submit copies of their plans
to the Environmental Protection Agency. The act specifically exempts
these assessments from the Freedom of Information Act.
We concluded that FDA and USDA could not assess the industry's efforts
to prevent or reduce their vulnerability to deliberate contamination.
Lacking such baseline information, they could not be prepared to advise
food processors on any additional actions needed. We also concluded
that the lack of security training for field personnel hampered their
ability to conduct informed discussion with facility personnel.
We recommended that FDA and USDA study their agencies' existing
statutes and identify what additional authorities they may need
relating to security measures. On the basis of the results of these
studies, the agencies should seek additional authority from the
Congress. While USDA agreed with our recommendation, FDA took no
position. We also recommended that both agencies provide training for
all field personnel to enhance their awareness and ability to discuss
security measures with plant personnel. USDA and FDA agreed with the
need for additional training.
* Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center, U.S. General Accounting Office, GAO-03-
847 (Washington, D.C.: September 19, 2003).
USDA scientists at the Plum Island Animal Disease Center are
responsible for developing strategies for protecting the nation against
animal diseases that could be accidentally or deliberately introduced
in to the country. These scientists--often with the assistance of
scientists from other countries--identify the pathogens that cause
animal diseases in foreign countries and then work to develop vaccines
against them. Some pathogens maintained at USDA's Plum Island
laboratory, such as foot-and-mouth disease, are highly contagious to
livestock and could cause catastrophic economic losses if they were
released outside the facility. Questions about the security of Plum
Island arose after the September 2001 terrorist attacks and when
employees of the contractor hired to operate and maintain the Plum
Island facilities went on strike in August 2002. About 10 months later,
in June 2003, DHS became responsible for Plum Island while the USDA
staff are continuing their research programs.
In September 2003, we reported that our review of security at Plum
Island identified fundamental concerns that leave the facility
vulnerable to security breaches. We found that immediately after the
September 2001 terrorist attacks, USDA began a concerted effort to
assess security at many of its laboratories, including Plum Island.
Using a risk management approach, USDA identified certain pathogens as
the primary asset requiring protection, the potential threats to this
asset, and the associated risk. USDA also began to upgrade security at
Plum Island. For example, USDA hired armed guards to patrol the island
and installed fingerprint recognition locks on freezers containing
pathogens.
Despite these improvements, we identified shortcomings in Plum Island's
security arrangements. We found that Plum Island's physical security
was incomplete and limited. For example, the alarms and door sensors
that were recommended for the biocontainment area were not fully
operational; outdoor lighting was not adequate to support security
cameras; and physical security was not sufficient for certain assets,
including the foot-and-mouth disease vaccine bank. DHS officials said
the alarms and door sensors will be in place by December 2003 and they
were evaluating other physical security matters.
Furthermore, we found that Plum Island officials had not adequately
controlled access to the pathogens. Eight scientists from other
countries were given access to the biocontainment area without escorts
while their background checks were incomplete; no background checks
were done on students who regularly attended classes within the
biocontainment area; and individuals entering the biocontainment area
to perform nonlaboratory functions, such as cleaning, were not always
escorted. Controlling access to the pathogens is particularly important
because no security device is currently capable of detecting a
microgram of pathogenic material. Therefore, a scientist could remove a
tiny quantity of pathogen without being detected and potentially
develop it into a weapon. Many facilities take measures to minimize
this risk. For example, at the U.S. Army Medical Research Institute of
Infectious Diseases, background checks must be updated regularly to
evaluate the continued suitability and reliability of employees working
with pathogens. According to DHS officials, they are taking action to
revise policies for access to the biocontainment area.
We also found limitations in Plum Island's incident response
capability. For example, the guard force had been operating without
authority to carry firearms or to make arrests. Plum Island's incident
response plan does not address what to do if an incident, such as a
terrorist attack, exceeds the capability of the security system, and
officials have not tested the facility's response capability to ensure
its effectiveness. DHS officials told us they have started to take
actions to fully address these incident response issues and are
obtaining assistance from the Federal Protective Service.
Because of the strike that occurred in August 2002 and the hostility
surrounding it, the risk that someone may try to steal pathogens has
increased. One striker was convicted of tampering with the island's
water distribution and treatment system as he walked off the job the
day the strike began, and USDA officials suspect that this individual
did not act alone. The intelligence community considers disgruntled
employees as posing a security risk. Although USDA did consider the
possibility that it could have a disgruntled worker, it did not
reevaluate the level of risk, the assets requiring protection, or its
incident response plans for Plum Island in light of specific events
related to the strike. Furthermore, USDA did not discuss the defined
threat with the intelligence community and local law enforcement
officials to ensure that threats particular to Plum Island and its
vicinity were taken into consideration.
We concluded that further actions are needed to provide reasonable
assurance that pathogens cannot be removed from the facility and
exploited for use in bioterrorism. Particularly, it is important to
better secure the foot-and-mouth disease vaccine bank to ensure its
availability for combating an outbreak. The lack of comprehensive
policies and procedures for limiting access to pathogens unnecessarily
elevates the risk of pathogen theft. Moreover, because physical
security measures alone are not adequate to secure pathogens, all
laboratories containing these materials face the challenge of
developing other approaches to mitigate the risk of theft. By
consulting with other laboratories to discover methods they are using
to mitigate the risk to pathogens, Plum Island officials can learn more
about safeguards being employed elsewhere.
We recommended that DHS (1) correct physical security deficiencies at
Plum Island; (2) limit access to pathogens and identify ways to
mitigate the inherent difficulty of securing pathogens; (3) enhance
Plum Island's incident response capability; and (4) reconsider the
risks and threats to Plum Island and revise the security and incident
response plans as needed. DHS has agreed with the report and has
started to implement these recommendations.
FOOTNOTES
[1] Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain
Vigilant and Resolve Outstanding Issues, U.S. General Accounting
Office, GAO-02-808 (Washington, D.C.: July 26, 2002) and Mad Cow
Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas
Would Strengthen U.S. Prevention Efforts, U.S. General Accounting
Office, GAO-02-183 (Washington, D.C.: January 25, 2002).
[2] Food-Processing Security: Voluntary Efforts Are Under Way, but
Federal Agencies Cannot Fully Assess Their Implementation, U.S. General
Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 2003).
[3] Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center, U.S. General Accounting Office,
GAO-03-847 (Washington, D.C.: September 19, 2003).
[4] The foot-and-mouth virus is relatively hardy and can survive in
certain environments for considerable periods of time. For example, it
can live in salted bacon for up to 183 days or in air-dried animal
hides or skins for 6 weeks. Should a person step in manure from an
infected animal, the virus can live on the shoes for up to 9 weeks in
summer conditions or up to 14 weeks in winter.
[5] USDA requires meat and poultry plants to use a Hazard Analysis and
Critical Control Point system and FDA requires that system for juices,
fish, and shellfish.