Homeland Security
Much Is Being Done to Protect Agriculture from a Terrorist Attack, but Important Challenges Remain Gao ID: GAO-05-214 March 8, 2005U.S. agriculture generates more than $1 trillion per year in economic activity and provides an abundant food supply for Americans and others. Since the September 11, 2001, attacks, there are new concerns about the vulnerability of U.S. agriculture to the deliberate introduction of animal and plant diseases (agroterrorism). Several agencies, including the U.S. Department of Agriculture (USDA), the Department of Homeland Security (DHS), the Department of Health and Human Services (HHS), the Environmental Protection Agency (EPA), and the Department of Defense (DOD), play a role in protecting the nation against agroterrorism. GAO examined (1) the federal agencies' roles and responsibilities to protect against agroterrorism, (2) the steps that the agencies have taken to manage the risks of agroterrorism, and (3) the challenges and problems that remain.
After the terrorist attacks of September 11, 2001, federal agencies' roles and responsibilities were modified in several ways to help protect agriculture from an attack. First, the Homeland Security Act of 2002 established DHS and, among other things, charged it with coordinating U.S. efforts to protect against agroterrorism. The act also transferred a number of agency personnel and functions into DHS to conduct planning, response, and recovery efforts. Second, the President signed a number of presidential directives that further define agencies' specific roles in protecting agriculture. Finally, Congress passed legislation that expanded the responsibilities of USDA and HHS in relation to agriculture security. In carrying out these new responsibilities, USDA and other federal agencies have taken a number of actions. The agencies are coordinating development of plans and protocols to better manage the national response to terrorism, including agroterrorism, and, along with several states, have conducted exercises to test these new protocols and their response capabilities. Federal agencies also have been conducting vulnerability assessments of the agriculture infrastructure; have created networks of laboratories capable of diagnosing animal, plant, and human diseases; have begun efforts to develop a national veterinary stockpile that intends to include vaccines against foreign animal diseases; and have created new federal emergency coordinator positions to help states develop emergency response plans for the agriculture sector. However, the United States still faces complex challenges that limit the nation's ability to respond effectively to an attack against livestock. For example, USDA would not be able to deploy animal vaccines within 24 hours of an outbreak as called for in a presidential directive, in part because the only vaccines currently stored in the United States are for strains of foot and mouth disease, and these vaccines need to be sent to the United Kingdom (U.K.) to be activated for use. There are also management problems that inhibit the effectiveness of agencies' efforts to protect against agroterrorism. For instance, since the transfer of agricultural inspectors from USDA to DHS in 2003, there have been fewer inspections of agricultural products at the nation's ports of entry.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-214, Homeland Security: Much Is Being Done to Protect Agriculture from a Terrorist Attack, but Important Challenges Remain
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Report to Congressional Requesters:
March 2005:
Homeland Security:
Much Is Being Done to Protect Agriculture from a Terrorist Attack, but
Important Challenges Remain:
GAO-05-214:
GAO Highlights:
Highlights of GAO-05-214, a report to congressional requesters:
Why GAO Did This Study:
U.S. agriculture generates more than $1 trillion per year in economic
activity and provides an abundant food supply for Americans and others.
Since the September 11, 2001, attacks, there are new concerns about the
vulnerability of U.S. agriculture to the deliberate introduction of
animal and plant diseases (agroterrorism). Several agencies, including
the U.S. Department of Agriculture (USDA), the Department of Homeland
Security (DHS), the Department of Health and Human Services (HHS), the
Environmental Protection Agency (EPA), and the Department of Defense
(DOD), play a role in protecting the nation against agroterrorism. GAO
examined (1) the federal agencies‘ roles and responsibilities to
protect against agroterrorism, (2) the steps that the agencies have
taken to manage the risks of agroterrorism, and (3) the challenges and
problems that remain.
What GAO Found:
After the terrorist attacks of September 11, 2001, federal agencies‘
roles and responsibilities were modified in several ways to help
protect agriculture from an attack. First, the Homeland Security Act of
2002 established DHS and, among other things, charged it with
coordinating U.S. efforts to protect against agroterrorism. The act
also transferred a number of agency personnel and functions into DHS to
conduct planning, response, and recovery efforts. Second, the President
signed a number of presidential directives that further define
agencies‘ specific roles in protecting agriculture. Finally, Congress
passed legislation that expanded the responsibilities of USDA and HHS
in relation to agriculture security.
In carrying out these new responsibilities, USDA and other federal
agencies have taken a number of actions. The agencies are coordinating
development of plans and protocols to better manage the national
response to terrorism, including agroterrorism, and, along with several
states, have conducted exercises to test these new protocols and their
response capabilities. Federal agencies also have been conducting
vulnerability assessments of the agriculture infrastructure; have
created networks of laboratories capable of diagnosing animal, plant,
and human diseases; have begun efforts to develop a national veterinary
stockpile that intends to include vaccines against foreign animal
diseases; and have created new federal emergency coordinator positions
to help states develop emergency response plans for the agriculture
sector.
However, the United States still faces complex challenges that limit
the nation‘s ability to respond effectively to an attack against
livestock. For example, USDA would not be able to deploy animal
vaccines within 24 hours of an outbreak as called for in a presidential
directive, in part because the only vaccines currently stored in the
United States are for strains of foot and mouth disease, and these
vaccines need to be sent to the United Kingdom (U.K.) to be activated
for use. There are also management problems that inhibit the
effectiveness of agencies‘ efforts to protect against agroterrorism.
For instance, since the transfer of agricultural inspectors from USDA
to DHS in 2003, there have been fewer inspections of agricultural
products at the nation‘s ports of entry.
Burning Carcasses during the 2001 U.K. Outbreak of Foot and Mouth
Disease:
What GAO Recommends:
To enhance the agencies‘ ability to reduce the risk of agroterrorism,
GAO recommends, among other things, that (1) USDA examine the costs and
benefits of developing stockpiles of ready-to-use vaccines and (2) DHS
and USDA determine the reasons for declining agricultural inspections.
USDA, DHS, and HHS generally agreed with our recommendations. DOD and
EPA made technical comments but took no position on the report‘s
recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-05-214.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert Robinson, 202-512-
3841, Robinsonr@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Federal Agencies' Roles and Responsibilities Were Modified to Protect
against Agroterrorism:
Since the Terrorist Attacks of 2001, Federal Agencies Have Taken Steps
to Manage the Risks of Agroterrorism:
The United States Still Faces Complex Challenges and Management
Problems in Protecting against Agroterrorism:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Response:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: List of Experts GAO Consulted and Summary of Observations:
Appendix III: Animal and Plant Diseases that Pose a Severe Threat to
Agriculture:
Appendix IV: U.S. Concentration of Cattle, Chicken, and Corn Production
in 2002:
Appendix V: Additional Information on National and Agency-Specific
Steps Taken to Protect against Agroterrorism:
Appendix VI: Comments from the U.S. Department of Agriculture:
GAO Comments:
Appendix VII: Comments from the Department of Homeland Security:
GAO Comments:
Appendix VIII: Comments from the Department of Health and Human
Services:
Appendix IX: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Acknowledgments:
Related GAO Products:
Tables:
Table 1: List of Select Animal Diseases Identified by USDA Pursuant to
the Bioterrorism Act of 2002 as a Severe Threat to the Livestock
Industry and Human Health:
Table 2: List of All Plant Diseases Identified by USDA as Severe
Threats to Plants Pursuant to the Bioterrorism Act of 2002:
Figures:
Figure 1: Top Hog-Producing States in 2002:
Figure 2: Top Soybean-Producing States in 2002:
Figure 3: Agricultural Inspector Transferred to DHS Inspecting Suspect
Cargo:
Figure 4: Federal Agencies' Roles and Responsibilities as Defined by
Homeland Security Presidential Directive 9:
Figure 5: Game Bird Infected with Exotic Newcastle Disease during the
2002-2003 Outbreak in California:
Figure 6: Top Cattle-Producing States in 2002:
Figure 7: Top Chicken-Producing States in 2002:
Figure 8: Top Corn-Producing States in 2002:
Abbreviations:
APHIS: Animal Plant Health Inspection Service:
ARS: Agricultural Research Service:
CBP: Customs and Border Protection:
CDC: Centers for Disease Control and Prevention:
DHS: Department of Homeland Security:
DOD: Department of Defense:
EPA: Environmental Protection Agency:
FDA: Food and Drug Administration:
FEMA: Federal Emergency Management Agency:
FMD: foot and mouth disease:
GAO: Government Accountability Office:
HHS: Health and Human Services:
HSPD: Homeland Security Presidential Directive:
NVSL: National Veterinary Services Laboratories:
OIE: Office Internationale des Epizooties:
PPQ: Plant Protection and Quarantine:
USDA: United States Department of Agriculture:
Letter March 8, 2005:
The Honorable Daniel K. Akaka:
Ranking Minority Member:
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Bennie G. Thompson:
Ranking Minority Member:
Committee on Homeland Security:
House of Representatives:
U.S. agriculture annually generates more than $1 trillion in economic
activity, including more than $50 billion in exports, and provides an
abundant and economical supply of food for Americans and others around
the world.[Footnote 1] Protecting agriculture is therefore critically
important to the well-being of Americans and the U.S. economy. While
the United States has never experienced a terrorist attack against
agriculture, this important industry is vulnerable for a variety of
reasons, including the relative ease with which livestock and crop
diseases could be obtained and disseminated. Many of these diseases are
endemic in other parts of the world and can be extracted from common
materials, such as soil. Farms in general are easily accessible because
they are located in rural areas and have minimal security, especially
crop farms. Moreover, the highly concentrated breeding and rearing
practices of our livestock industry make it a vulnerable target for
terrorists because diseases could spread rapidly and be very difficult
to contain. For example, between 80 and 90 percent of grain-fed beef
cattle production is concentrated in less than 5 percent of the
nation's feedlots. Therefore, the deliberate introduction of a highly
contagious animal disease in a single feedlot could have serious
economic consequences.
Most experts believe that the major effect of an attack on agriculture
would be economic.[Footnote 2] While many animal diseases are not
transmissible to humans, others are, and when this occurs there could
be serious human health consequences. For example, one of these
transmissible diseases, avian influenza, has caused 42 human deaths in
Asia since January 2004, when accidental outbreaks infected poultry
flocks. Experts also believe that livestock and poultry are more likely
to be targets of a terrorist attack than crops because deliberately
spreading plant diseases is inherently more difficult, requiring, among
other things, favorable weather conditions such as wind. One scenario
of particular concern is the intentional introduction of foot and mouth
disease, a highly contagious livestock disease that does not typically
affect humans. The 2001 accidental outbreak of the disease in the
United Kingdom caused approximately $5 billion dollars in losses to the
food and agriculture sector, as well as comparable losses in the
tourism industry. By the time this disease was eradicated, over 4
million animals had been slaughtered and burned, and the nation was
banned from exporting livestock and animal products that could transmit
the virus. Numerous other animal and plant diseases are also of
concern, including classical swine fever and soybean rust. Appendix III
provides information on the animal and plant diseases of primary
concern that the U.S. Department of Agriculture (USDA) believes could
be used in an attack against agriculture.
In 1998, we reported that the United States did not have a process in
place to detect and respond to a terrorist attack against agriculture
and that if such an attack were to occur, the country would rely on the
process used to respond to naturally occurring diseases.[Footnote 3]
Specifically, we reported that USDA--the agency primarily responsible
for responding to major outbreaks of disease involving livestock,
poultry, and crops--lacked a comprehensive, national strategy for
responding to a widespread attack. Among the problems we identified
were concerns about the ability of farmers, local veterinarians, and
other experts to detect, correctly identify, and report cases of
disease in a timely manner.[Footnote 4] We also found that some states
had not developed or tested emergency response plans.
Since we last reported, the terrorist attacks of September 11, 2001,
have heightened concerns about agriculture's vulnerability to
terrorism, including the deliberate introduction of livestock, poultry,
and crop diseases. Attacks targeted at agriculture are commonly
referred to as agroterrorism. For the purposes of this report,
"agroterrorism" refers to the deliberate introduction of animal and
plant diseases at the farm level, prior to further processing or
production. Although other definitions of agroterrorism can be broader
and include the entire food chain, our definition does not refer to the
deliberate contamination of manufactured food items, which was outside
the scope of this review. In this context, you asked that we address
(1) changes that have taken place since September 2001 in the roles and
responsibilities of federal agencies to protect against agroterrorism,
(2) specific steps that the United States has taken to manage the risks
of agroterrorism, and (3) what challenges and problems remain.
To identify the changes in agencies' roles and responsibilities to
protect against agroterrorism, we reviewed laws, regulations, and
presidential directives prior to and after the terrorist attacks of
September 11, 2001. We also interviewed officials from the Department
of Homeland Security (DHS); the USDA; the Food and Drug Administration
(FDA)[Footnote 5] and Centers for Disease Control and Prevention (CDC)
within the Department of Health and Human Services (HHS); the
Environmental Protection Agency (EPA); the Department of Defense (DOD);
and the Department of Justice. To examine the specific steps that the
United States has taken to manage the risks of agroterrorism, we
reviewed and analyzed unclassified agency documents and contacted
federal and state offices of Inspectors General to assess what work has
been done in relation to agroterrorism.[Footnote 6] We also conducted
structured interviews in person or via telephone with officials in five
states, selected in part for their leading role in producing
agricultural commodities sold before processing. These officials
included representatives from state departments of agriculture,
emergency management, and homeland security offices; agricultural
inspectors from DHS and USDA; and veterinarians, plant health, and
other officials from regional USDA and FDA offices. We examined the
steps taken by the agencies in the context of our work on homeland
security risk management.[Footnote 7] To determine what challenges may
remain, we conducted structured interviews with experts from academia,
private think tanks, and other research institutions. We also reviewed
an extensive body of relevant literature, attended conferences, and
spoke with industry and agency officials. Additional details about the
scope and methodology of our review are presented in appendix I. We
conducted our review from February 2004 through January 2005 in
accordance with generally accepted government auditing standards.
Results in Brief:
Since the terrorist attacks of 2001, federal agencies' roles and
responsibilities have been modified to protect against agroterrorism.
Under the Homeland Security Act of 2002, DHS was established and
charged with responsibility for coordinating national efforts to
protect against terrorism, including agroterrorism. As a result of this
legislation, DHS also assumed responsibility for certain functions
previously performed by other agencies, and some personnel who
performed those functions were transferred to DHS. For example, the
Federal Emergency Management Agency (FEMA), including its personnel,
was transferred to DHS which gave it the responsibility for planning
for emergencies and major disasters. Most of USDA's agricultural
inspectors were transferred to DHS, although USDA retains some
functions related to inspecting agricultural products, such as
conducting specialized inspections; developing and supervising
training; and developing policies and procedures. This transfer gave
DHS the role to prevent the entry of infectious diseases and pests into
the United States. As a part of this transfer, DHS and USDA signed an
interagency memorandum of agreement that, among other things,
authorized USDA to request the use of DHS inspectors during a major
outbreak--whether intentional or natural--of agricultural pests and
diseases. Also, a number of presidential directives were issued that
further define agencies' roles and responsibilities for protecting
against agroterrorism. For example, Homeland Security Presidential
Directive (HSPD)-9 defines how the various agencies will work together
to protect the agriculture and food industries. Legislation has also
expanded the responsibilities of USDA and HHS. Specifically, through
the Public Health Security and Bioterrorism Preparedness and Response
Act of 2002 (the "Bioterrorism Act of 2002"), USDA and HHS gained
authority to regulate agents and toxins that pose a serious threat to
public health, animals, plants, and animal and plant products. The
agencies believe these agents could be used in a terrorist attack.
In carrying out their new roles and responsibilities, federal agencies
have taken steps to better manage the risks of agroterrorism, including
development of national plans and the adoption of standard protocols.
For example, DHS led the development of a National Response Plan that,
for the first time, spells out how the nation would work together in
the event of a terrorist attack on its critical infrastructure sectors,
including agriculture. In addition, federal agencies have adopted
standard protocols for managing such emergencies and, through federal
grants, have provided incentives for states to adopt similar protocols.
Among other things, these protocols include establishing emergency
operation centers and a chain of command. To test these protocols and
response capability in general, federal and state officials are
conducting test exercises. At the federal level, a number of other
agency-specific actions are also under way, including the following:
* FDA and USDA are in varying stages of conducting vulnerability
assessments to determine which agricultural products are most
vulnerable to terrorist attacks.
* USDA and HHS are enhancing their diagnostic and monitoring capability
by creating laboratory networks.
* Agencies have formed numerous working groups to protect agriculture.
For example, DHS created a Food and Agriculture Sector Coordinating
Council to help the federal government and industry share ideas about
how to mitigate the risk of an attack on agriculture. DHS recently
created a Government Coordinating Council to oversee the tasks of the
various working groups.
* USDA has established a steering committee to guide efforts to develop
a National Veterinary Stockpile that, among other things, is intended
to address what vaccines are needed to respond to animal diseases most
damaging to human health and the economy.
* DHS, USDA, and HHS have funded research to address a range of issues
related to agroterrorism. For example, DHS provided $33 million in 2004
to establish two university-based Centers of Excellence to oversee
research on post-harvest food protection and on diseases that affect
livestock and poultry.
* USDA created 16 Area and Regional Emergency Coordinator positions to
help states develop individual emergency response plans and to serve as
a technical resource for states, industry, and other stakeholders.
While these actions are important and necessary steps, the United
States still faces several complex challenges that limit the nation's
ability to quickly and effectively respond to a widespread attack on
livestock and poultry:
* Many United States' veterinarians lack training needed to recognize
the signs of foreign animal diseases. According to a 2004 report
produced for USDA, while all U.S. veterinary schools offer information
about foreign animal diseases, only about 26 percent of their graduates
have taken a course specifically dedicated to foreign animal diseases.
Furthermore, foreign animal disease training is not required for USDA-
accredited veterinarians, the ones most likely to be called upon if
livestock were attacked. Two years ago, USDA drafted a rule to make
such training a prerequisite for accreditation, but other draft rules
have taken precedence and caused it to be delayed.
* USDA does not use rapid diagnostic tools to test animals at the site
of an outbreak. They employ this technology only within selected
laboratories. According to experts, on-site use of these tools is
critical to speeding diagnosis, containing the disease, and minimizing
the number of animals that need to be slaughtered. DOD uses rapid
diagnostic tools to identify disease agents on the battlefield, but
USDA officials consider this technology to be still under development.
Nevertheless, USDA officials told us that they agree it is important to
evaluate the costs and benefits of developing and validating these
tools for use outside of a laboratory setting.
* Vaccines cannot be deployed within 24 hours of an outbreak as called
for in HSPD-9. First, supplies are limited because USDA maintains
vaccines for only one foreign animal disease--foot and mouth disease--
since this disease is so highly contagious. USDA generally prefers to
immediately slaughter diseased animals rather than to vaccinate them.
Also, these vaccines cannot be rapidly deployed because they are not
stored in a "ready-to-use" state and would first need to be sent to the
United Kingdom for bottling and testing. USDA officials told us that it
has recently established a steering committee that will address vaccine
stockpiling issues, but it is not clear that the committee will address
the costs and benefits of developing ready-to-use vaccines that can be
quickly deployed against animal diseases of primary concern.
* Current USDA policy requires a complex process for deciding if and
when to use vaccines--a process that could be too lengthy during an
attack. USDA officials agree that they can explore the possibility of
designing a more rapid decision-making process but cautioned this
process is complex and takes into consideration many variables, such as
the location of outbreaks in relation to susceptible animal
populations, as well as trade concerns and restrictions.
We also found several management problems that reduce the effectiveness
of the agencies' routine efforts to protect against agroterrorism.
* Agricultural inspections at ports of entry--the first line of defense
against the entry of foreign animal and plant diseases--have declined
over the past 2 years at a time when imports have increased. Neither
USDA nor DHS officials can fully explain why this drop occurred. Since
the transfer of most USDA agricultural inspectors to DHS, data show a
decline in the number of agricultural inspections at ports of entry
nationwide from 40.9 million in fiscal year 2002, when USDA was fully
responsible for agricultural inspections, to 37.5 million in fiscal
year 2004, when DHS had primary responsibility. However, officials
pointed out some factors that may be contributing to this reduction,
most importantly, the large number of unfilled vacancies for
agricultural inspectors. DHS officials told us they plan to address
this shortage by hiring more than 500 inspectors by fiscal year 2006,
but also stated that the ability to hire and deploy new inspectors is
impeded by the length of time needed for background checks. Inspectors
also told us that another factor contributing to the decline in
inspections is that they do not always receive timely information about
high-risk cargo that needs to be inspected. While DHS officials told us
these instances represent a small fraction of inspections, they agreed
that changes can be made to improve the flow of information.
* There are weaknesses regarding the flow of critical information among
key stakeholders. First, DHS is not promptly and effectively seeking
input from key stakeholders on critical national guidance documents.
For example, officials in key agricultural states and industry
representatives told us that DHS did not give them enough time to
review and comment on draft federal guidance, including the National
Response Plan. As a result, state officials and industry
representatives we spoke with are concerned that the response plan may
set unrealistic expectations regarding the states' capabilities to meet
the requirements of the plan. Second, "after-action" reports on the
results of national and state-level test exercises that simulate the
consequences of a major agroterrorism event and test the response
capabilities needed to manage such an event, are not systematically
shared among key stakeholders. DHS officials told us that they are
developing a Homeland Security Information Network that could
facilitate sharing this information.
* States are not receiving sufficient technical federal assistance in
developing emergency response plans and other activities to effectively
prepare them to deal with agroterrorism. This lack of assistance
results in part from implementation problems associated with the Area
and Regional Emergency Coordinators positions--USDA has not yet filled
all 16 of these positions. USDA officials told us they face
difficulties hiring these coordinators due to the extensive travel
required since each coordinator must cover a broad geographic area.
Federal and state officials we interviewed told us that, even if the
vacancies were filled, the current number of emergency coordinators is
insufficient, as each coordinator is responsible for up to 6 states on
the animal health side and 27 states on the plant side.
* Shortcomings exist in DHS' coordination of federal working groups and
research efforts. Although DHS has lead responsibility for coordinating
efforts to protect against agroterrorism, officials from other agencies
told us that the tasks assigned to various interagency working groups
are not consistent with activities outlined in national guidance,
including important documents such as the National Response Plan. This
could lead to confusion and undermine the efforts of "national"
planning. DHS has also not developed controls to coordinate research
efforts with other agencies, even though HSPD-9 specifically designates
DHS as the agency responsible for coordinating research efforts to
protect against agroterrorism. For example, some of the DHS-supported
activities at the Centers of Excellence, such as vaccine research,
appear to duplicate research conducted by USDA. USDA officials told us
they agree that there needs to be more coordination and cooperation
between USDA and DHS on research activities.
* Finally, while steps are being taken to integrate agencies'
diagnostic laboratory networks, USDA has not yet integrated the
databases of the member laboratories within its own networks, nor have
they integrated with HHS laboratories for diseases of common concern.
As a result, USDA's ability to look at diagnostic data from across the
country, detect trends, and implement a response is limited, and HHS
may not receive timely information from USDA on agricultural diseases
that could spread to humans. USDA plans to integrate information from
its laboratory networks for diseases of concern by mid-2005 and has
established an interagency working group with HHS to discuss
integrating their respective laboratory networks.
We are making several recommendations aimed at improving agencies'
efforts to mitigate and quickly and effectively respond to a widespread
attack on animal agriculture and to address routine management problems
that impair the agencies' ability to protect against agroterrorism in
general. For example, we are recommending that the Secretary of
Agriculture, within the context of the agency's overall risk management
efforts, expedite the review and issuance of the draft rule on USDA's
accreditation process for veterinarians, which would require training
in recognizing foreign animal diseases; evaluate the costs and benefits
of using rapid diagnostic tools at the site of an outbreak; examine the
cost and benefits of developing stockpiles of ready-to-use vaccines
that can be quickly deployed against animal diseases of primary
concern; and simplify the decision-making process for determining if
and/or when to use vaccines to control an outbreak to ensure that rapid
decisions can be made in the event of a terrorist attack. We are also
recommending that the Secretaries of Agriculture and Homeland Security
work together to analyze agricultural inspections data to identify
reasons for the decline in agricultural inspections and areas for
improvement.
In commenting on a draft of this report, USDA, DHS, and HHS generally
concurred with the report's recommendations. USDA said that it found
the report offered a number of insightful and appropriate
recommendations but also raised some concerns regarding rapid
diagnostic tools and vaccines. DHS noted that it was in the process of
implementing several corrective actions in response to our report. HHS
welcomed the attention to animal diseases. The agencies also provided
additional information, comments, and clarifications on the report's
findings that we have addressed as appropriate throughout the report.
DOD and EPA took no position on the report's contents but provided
minor technical comments that we incorporated as appropriate.
Background:
Experts believe that the deliberate introduction of animal and plant
diseases at the farm level would cause severe economic disruption given
that agriculture accounts for 13 percent of the U.S. gross domestic
product and 18 percent of domestic employment. In the event of
agroterrorism, losses to farmers could result from decreases in the
price of livestock, poultry, and crops; reductions in sales due to a
decline or halt in productivity; inability to move animals to the
market; and costs associated with disease control, including disposal
of contaminated animals or plants. Losses could be particularly severe
in states where animal and crop production is concentrated. For
example, three states produce 53 percent of the total U.S. hog
production and three states produce 39 percent of the total U.S.
soybean production.[Footnote 8] (See figs. 1 and 2.) Substantial losses
could also arise from halting exports; the value of U.S. agricultural
exports in fiscal year 2003 exceeded $56 billion.
Figure 1: Top Hog-Producing States in 2002:
[See PDF for image]
Note: Three states did not disclose their information.
[End of figure]
Figure 2: Top Soybean-Producing States in 2002:
[See PDF for image]
Note: Nine states do not produce soybeans. Six states did not disclose
their information.
[End of figure]
USDA has primary responsibility for protecting the agriculture sector.
Within USDA, the Animal and Plant Health Inspection Service (APHIS) is
responsible for protecting America's animals and plants from
agricultural pests and diseases. APHIS's Veterinary Services operates
the National Veterinary Services Laboratories (NVSL), which is
responsible for activities such as training and approving personnel
from state and university diagnostic laboratories to conduct diagnostic
tests for foreign animal diseases. NVSL is composed of four facilities,
three of which are located in Ames, Iowa. The fourth, the Foreign
Animal Disease Diagnostic Laboratory, is located at the Plum Island
Animal Disease Center off the coast of New York. The Plum Island Animal
Disease Center also houses the North American Foot and Mouth Disease
Vaccine Bank.[Footnote 9] Regarding plant health, APHIS' Plant
Protection and Quarantine (PPQ) program is responsible for safeguarding
crops from pests and diseases.[Footnote 10]
USDA also supports research into protecting the agricultural sector.
USDA's Cooperative State Research, Education, and Extension Service
funds university-based agricultural research, including research on
agricultural biosecurity. In addition, USDA's in-house research agency,
the Agricultural Research Service (ARS), conducts research in fields
that complement homeland security efforts, such as the development of
vaccines. The Agricultural Research Service also conducts research at
the Plum Island Animal Disease Center.
USDA's Food Safety and Inspection Service is responsible for the safety
of meat, poultry, and certain egg products, while FDA is responsible
for shell eggs, seafood, and milk. In fiscal year 2003, USDA received
approximately $495 million for homeland security activities, which
included those that address agroterrorism and other routine USDA
programs. FDA received approximately $160 million in fiscal year 2003
for homeland security efforts, including protecting against
agroterrorism.
Other federal agencies play a part in protecting the agriculture
sector. Examples include:
* If an outbreak of zoonotic disease--that is, a disease that can
infect and possibly cause death to both animals and humans--occurs, CDC
becomes involved to help control the spread of the disease and minimize
the impact of the outbreak.
* In the event of a disease outbreak, EPA provides technical support to
federal and state agencies and the private sector to ensure protection
of land, drinking water, and air from potential contamination
associated with the disposal of diseased animal carcasses and infected
plant material. EPA is also responsible for reviewing and approving the
use of pesticides to prevent the spread of crop and animal diseases,
both during an emergency and for prevention purposes.
* In the event of an agricultural emergency that USDA cannot handle
alone, DOD provides veterinarians from its Veterinary Corps to USDA
under a Memorandum of Understanding. In addition, the U.S. Army Medical
Research Institute of Infectious Diseases in Fort Detrick, Maryland,
conducts research designed to help protect soldiers from diseases,
including many that are zoonotic and may be potential agroterrorism
threats.
International organizations also play a role, particularly the Office
Internationale des Epizooties (OIE), an organization headquartered in
Paris, France, that has 166 member countries, including the United
States.[Footnote 11] OIE classifies member countries or certain zones
within these countries as being disease-free if they meet certain
criteria detailed in the OIE International Animal Health Code. The
international community generally places a high value on products from
countries that OIE classifies as disease-free without the use of
vaccination. Such countries can export both live animals and animal
products easily to other countries. In contrast, countries that are
classified as disease-free but who use vaccines are restricted in their
ability to trade. Most countries that are foot and mouth disease (FMD)
- free without vaccination resort to a "stamping out," or cull and
burn, process to eradicate the disease. The United Kingdom followed
this process during the FMD outbreak in 2001. As a member state of OIE,
the United States would also generally follow this process.[Footnote 12]
Federal Agencies' Roles and Responsibilities Were Modified to Protect
against Agroterrorism:
Following the terrorist attacks of 2001, Congress and the President
modified the roles and responsibilities of federal agencies to better
protect against agroterrorism. Congress passed the Homeland Security
Act of 2002,[Footnote 13]establishing the Department of Homeland
Security as the chief coordinating agency for efforts to protect the
United States from terrorist acts, including agroterrorism. To outline
agency goals and tasks for protecting against agroterrorism, the
President issued four Homeland Security Presidential Directives.
Congress also passed legislation that clarifies USDA's responsibilities
over agriculture and food security.
The Department of Homeland Security Is Responsible for Coordinating
Efforts to Protect against Agroterrorism and Has Absorbed Staff and
Functions from Other Agencies:
The Homeland Security Act of 2002 created the Department of Homeland
Security and assigned the new agency lead coordinating responsibility
for protecting the nation against terrorist acts, including
agroterrorism. The act transferred functions and personnel from other
agencies to DHS, which allowed it to accomplish this role. For example,
the Homeland Security Act of 2002 transferred the functions and
personnel of FEMA, which had been responsible for mitigating, planning
for, and responding to natural emergencies and major disasters, into
DHS to support the new agency's responsibility for protecting the
United States from terrorist attacks. In addition, DHS is responsible
for consolidating federal response plans for various emergencies,
including agroterrorism, into a single coordinated plan, which is
called the National Response Plan. DHS is also responsible, through
FEMA, for providing emergency response to terrorist attacks, including
managing the response, coordinating federal response resources, and
aiding recovery.[Footnote 14] Under federal law, once the President
makes an official declaration of an emergency or a major disaster, DHS
is authorized to direct federal agencies to support state and local
efforts; coordinate relief assistance; provide technical and advisory
assistance to state and local governments for management, control, and
reduction of immediate threats to public health and safety; and provide
financial assistance.[Footnote 15]
The Homeland Security Act of 2002 transferred most of USDA's
responsibility for conducting agricultural import inspections to DHS,
which provided DHS with the capability to recognize and prevent the
entry of organisms that may be used for agroterrorism. The act also
authorized the transfer of no more than 3,200 inspector positions from
USDA's Plant Protection and Quarantine Unit to DHS.[Footnote 16] DHS
and USDA signed an interagency Memorandum of Agreement that, among
other things, further clarified the responsibilities of both agencies
at the border. Pursuant to this agreement, USDA may request the use of
DHS inspectors during a major animal or plant health incident of
national significance--whether intentional or natural.[Footnote 17] DHS
acquired USDA's authority to inspect passenger declarations and cargo
manifests, international passengers, baggage, cargo, and
conveyances,[Footnote 18] and hold suspect articles for quarantine to
prevent the introduction of plant or animal diseases. (See fig. 3.)
USDA retained its traditional authorities to conduct veterinary
inspections of live, imported animals; establish policy for inspections
and quarantine functions; provide risk analysis; develop and supervise
training on agriculture for DHS and USDA inspectors; conduct
specialized inspections of plant or pest material; and identify
agricultural pests. Under DHS' usual practices, a DHS inspector who
comes across a questionable agricultural product should hold it and
turn the item over to USDA inspectors for a more thorough analysis of
its potential threat to U.S. agriculture.
Figure 3: Agricultural Inspector Transferred to DHS Inspecting Suspect
Cargo:
[See PDF for image]
[End of figure]
The Homeland Security Act of 2002 also consolidated research efforts in
chemical, biological, and nuclear defense by transferring a number of
research facilities to DHS, including USDA's Plum Island Animal Disease
Center. The center is the only place in the United States where certain
highly infectious foreign animal diseases are studied, including FMD.
Since the transfer, DHS has assumed responsibility for the security and
management of the facility. Although USDA still administers its own
research and diagnostic programs on the island, DHS and USDA have
established a Senior Leadership group at the center to integrate
research efforts in general and to coordinate the management for joint
research projects. For example, this group integrates USDA and DHS
research efforts on FMD.
The Homeland Security Act of 2002 transferred the Office for Domestic
Preparedness and its grant-making functions from the Department of
Justice's Office of Justice Programs to DHS.[Footnote 19] This transfer
established DHS as the primary source of much federal homeland security
funding to state and local governments. In fiscal year 2005, DHS will
distribute formula and discretionary grants to the states through the
Homeland Security Grant Program.[Footnote 20] These grants have 2-year
performance periods and support expenditures, which include planning,
organizing, equipment, training, test exercises, and management and
administration. DHS gives states the flexibility to choose which
emergency "disciplines"--such as law enforcement, hazardous material
response, and public works--to fund, using the grants. Most DHS grant
programs require states to obligate not less than 80 percent of the
total grant award to local units of government.[Footnote 21] In the
program application kit, DHS provides guidance on the types of
expenditures that are allowable. Beginning in fiscal year 2004, DHS
provided states with examples of resources, which could be acquired
with grant funds for prevention, response, and recovery efforts related
to agricultural and/or food security preparedness. These resources
include agricultural response equipment, and agriculture-related test
exercises and training.
Finally, the Homeland Security Act of 2002 created the Information
Analysis and Infrastructure Protection Directorate in DHS and
transferred intelligence, law enforcement, and vulnerability assessment
functions from other agencies into the directorate.[Footnote 22]
Congress and the President have tasked DHS, through this directorate,
with developing a comprehensive national plan to secure critical
infrastructure sectors of the United States. Accordingly, DHS has
developed its interim National Infrastructure Protection Plan, which
includes strategies for securing the agriculture sector. In addition to
developing the plan, DHS is responsible for assessing and identifying
the nature and scope of terrorist threats to the homeland based on
information received and analyzed by other government agencies. To do
so, DHS receives information from the Federal Bureau of Investigations,
the Central Intelligence Agency, and other intelligence agencies and
assesses whether the combined information indicates a threat to
critical infrastructures.
Presidential Directives Define Agency Responsibilities for Protecting
against Agroterrorism:
Following the creation of DHS, the President issued four directives
that further define agencies' roles and responsibilities for protecting
against terrorism. The most important of these directives in relation
to agriculture is HSPD-9, which was released in January 2004. The
directive establishes a national policy to defend the agriculture and
food system against terrorist attacks, major disasters, and other
emergencies. Specifically, HSPD-9 outlines goals and assigns lead and
supporting roles to agencies to achieve these goals. (See fig. 4.)
There are seven categories outlined in HSPD-9: awareness and warning;
vulnerability assessments; mitigation strategies; response planning and
recovery; outreach and professional development; research and
development; and budget. Federal agencies, especially DHS, USDA, and
HHS, are assigned lead responsibilities to achieve the stated goals. To
accomplish the tasks outlined in the seven categories, lead agencies
often must coordinate with secondary or supporting agencies and, in
some instances, with states and private industry as well. For example,
HSPD-9 directs DHS to improve awareness and warning capabilities by
coordinating with other agencies to develop a biological threat
awareness capacity that will enhance detection and characterization of
agroterrorism. The directive also designates DHS as the lead agency in
ensuring that the combined federal, state, and local response
capabilities are adequate to respond quickly to a terrorist attack or
other emergencies affecting agriculture or food. HSPD-9 also directs
DHS to oversee a national biological surveillance system that will
combine surveillance information collected from several agencies with
threat and intelligence information to allow DHS to characterize
threats more quickly. According to DHS officials, this interagency
effort will help them differentiate between natural and intentional
outbreaks.
Likewise, HSPD-9 assigns lead tasks to USDA and HHS for agriculture and
food matters, respectively. Specific tasks for USDA and HHS include
developing safe, secure, and state-of-the-art agriculture laboratories
that research and develop diagnostic capabilities for foreign animal
and zoonotic diseases.[Footnote 23] Also under HSPD-9, USDA and HHS, in
coordination with EPA and DHS, are the lead agencies responsible for
improving existing recovery systems that will stabilize agriculture
production and rapidly remove and dispose of contaminated animals,
plants, and food products, and decontaminate premises following an
agroterrorism attack.
Figure 4: Federal Agencies' Roles and Responsibilities as Defined by
Homeland Security Presidential Directive 9:
[See PDF for image]
[End of figure]
HSPD-9 builds upon and augments tasks outlined in prior Homeland
Security Presidential Directives. HSPD-5 directs DHS to coordinate
development of the new National Response Plan that incorporates
national prevention, preparedness, response, and recovery plans into a
single, all-hazard plan. USDA, in collaboration with other agencies
including DHS, were tasked with writing the sections of the National
Response Plan guiding U.S. efforts to respond to an attack on U.S.
agriculture. HSPD-5 also directs DHS to consult with other federal
agencies, state, and local governments to implement a common National
Incident Management System, which standardizes planning,
communications, and public information during an incident in which
multiple federal and state agencies are involved. A key component of
the National Incident Management System is the Incident Command System,
which is designed to allow multiple agencies to coordinate the command,
operations, planning, logistics, finances, and administration during an
incident. HSPD-5 further directs agencies to require the adoption of
the National Incident Management System as a condition for states to
receive federal preparedness assistance.
HSPD-7 defines USDA and HHS as "sector-specific agencies" with
responsibilities for securing the agriculture and food sectors. These
agencies, in coordination with DHS, are tasked with collaborating with
federal, local, and state governments, as well as private industry and
other stakeholders to help protect their respective critical
infrastructure sectors, including agriculture. Among other things, HSPD-
7 directs DHS to establish systems, mechanisms, and procedures to share
homeland security information relevant to threats and vulnerabilities
in critical infrastructures with other federal departments and
agencies, state and local governments, and private industry in a timely
manner.
Finally, HSPD-8 sets out a national preparedness goal for all hazards,
including agriculture. The directive calls on federal agencies to
establish readiness priorities, to deliver federal assistance to state
and local governments effectively and expeditiously, and to ensure that
first responders are prepared to respond to major events. The directive
outlines criteria for federal preparedness assistance to the states
based on assessments of population concentrations, critical
infrastructure, and other risk factors such as terrorism threats.
Other Legislation Has Expanded USDA's and HHS's Traditional
Responsibilities to Protect against Agroterrorism:
The traditional responsibilities of USDA and HHS have been augmented
through Congress' passage of the Bioterrorism Act of 2002.[Footnote 24]
This act made USDA and HHS responsible for requiring companies,
laboratories, and other entities to register materials that could be
dangerous to agriculture production and human health. It also required
USDA and HHS to develop an inventory of potentially dangerous agents
and toxins that cause animal, plant, or human diseases. Furthermore,
individuals who possess or use such materials must register with the
Secretary of Agriculture or HHS and submit to a background check by the
U.S. Attorney General. Also, the act directed USDA and HHS to take a
number of steps to improve surveillance for such materials.
Specifically, the act directed USDA and HHS to coordinate surveillance
activities to detect zoonotic diseases. The act also authorized USDA to
conduct and support research into the development of an agricultural
bioterrorism early warning system. The system would enhance the
capacity of and coordination between state veterinary diagnostic
laboratories, federal and state agricultural research facilities, and
public health agencies. The act also gave USDA the authority to
coordinate with the intelligence community to better identify research
needs and evaluate materials or information acquired by the
intelligence community relating to potential threats to U.S.
agriculture.
Since the Terrorist Attacks of 2001, Federal Agencies Have Taken Steps
to Manage the Risks of Agroterrorism:
In carrying out their new roles and responsibilities, federal agencies
have taken steps to manage the risks of agroterrorism, including the
development of a comprehensive national strategy that did not exist
before September 11, 2001. As part of this strategy, DHS has overseen
the development of national plans and the adoption of standard
protocols that will help agencies coordinate in protecting against and
responding to agroterrorism. Federal and state officials are also
conducting joint exercises to test the new plans and protocols. In
addition, federal agencies are taking a number of specific actions to
protect against agroterrorism, including those summarized as follows.
National Plans Are Being Prepared, Emergency Protocols Have Been
Adopted, and Test Exercises Are Being Conducted:
DHS coordinated with other agencies to create an interim "National
Infrastructure Protection Plan" to guide the efforts of federal, state,
and local governments and private industry to protect critical
infrastructure sectors, including agriculture, against terrorist
attacks.[Footnote 25] The overall plan incorporates sector-specific
plans that include processes, guidance, and mitigation strategies that
address how DHS and other agencies will work with state and local
governments, private industry, and foreign governments to safeguard the
sectors. Additionally, the plan includes initiatives for sharing
warning data with state and local governments and the private sector.
(See app. V for more details about these plans.)
To outline how the nation will respond in the aftermath of an emergency
or major disaster such as a terrorist attack, DHS released a "National
Response Plan" in January 2005. The National Response Plan differs from
earlier federal emergency plans in that it describes the roles and
outlines the responsibilities for federal, state, and local responders
in addressing the national response to outbreaks or other emergencies
in the food and agriculture sector. DHS coordinated with USDA, HHS, and
EPA to develop the appendixes contained in the plan that pertain to
protecting agriculture and the food supply in emergencies, from first
detection to the response and recovery phase.[Footnote 26]
To further improve the response to emergencies such as agroterrorism,
DHS established the "National Incident Management System" in March
2004. A key component of the National Incident Management System is the
"Incident Command System," which is designed to coordinate the
communication, personnel, and procedures of different agencies and
levels of government within a common organizational structure during an
emergency that requires the resources of multiple federal, state, and
local responders. HSPD-5 directs federal agencies to require that
states become compliant with the National Incident Management System in
fiscal year 2005 as a condition for receiving federal grant aid for
emergency preparedness. To support this directive, DHS has established
a number of minimum requirements for states to implement during fiscal
year 2005. A DHS official noted that as of December 2004, most states
had already implemented the Incident Command System and other
components of the National Incident Management System. (See app. V for
more information on the National Incident Management System.)
To test response capability, including aspects of the National Incident
Management System, federal and state agencies have collaborated in
conducting test exercises to simulate outbreaks of foreign animal and
plant diseases. For example, USDA, along with numerous other agencies,
conducted a 1-day exercise in September 2002 called "Crimson Sky,"
which simulated the intentional introduction of the FMD virus in five
different locations across the United States. Exercises have also been
conducted to test response capability to address plant diseases. For
example, USDA and Minnesota, with the assistance of Iowa,[Footnote 27]
simulated an outbreak of soybean rust using the Incident Command System
in September 2004. Two months later, there was an apparently natural
outbreak of soybean rust in Louisiana and other southern states, and
USDA officials told us that the lessons learned from the test exercise
in coordinating their communications were incorporated in response to
the real outbreak. Federal, state, and industry officials whom we
interviewed said that these test exercises in general have been useful
in allowing players to better understand their roles and
responsibilities in a real-life event, to uncover shortfalls they had
not necessarily foreseen in planning, and to test solutions. For
instance, exercises have shown that some areas of agencies'
jurisdiction needed to be better defined. Many participants have
written unclassified "after-action" reports incorporating the lessons
they learned and raising key issues to be resolved. (See app. V for
more information on test exercises.)
A Number of Agency-Specific Actions Are Under Way:
In addition to the broad national planning efforts discussed, other
specific actions that federal agencies responsible for protecting
against agroterrorism have taken since 2001 include the following:
* FDA and USDA are in various stages of developing vulnerability
assessments of the agriculture and food sectors, as called for in HSPD-
9. As part of a continuing effort to anticipate threats to farm
products, FDA has conducted vulnerability assessments of different
categories of food for which FDA has statutory responsibility, to
identify those products most vulnerable to deliberate contamination.
Similarly, USDA is assessing vulnerabilities in USDA-regulated products
but had not completed its preliminary assessments at the time of our
review. Such assessments are generally not consistent across program
areas because different maximum values for the impact of terrorist
events are sometimes used. (See app. V for more details about FDA and
USDA vulnerability assessments.)
* To increase early warning and monitoring capabilities, USDA and HHS
have created laboratory networks to integrate existing federal, state,
and university laboratory resources. These networks are intended to
link laboratories that screen for animal, plant, and human health
diseases across the nation and help to provide diagnostic surge
capacity in the event of a disease outbreak. Within each network, the
laboratories use standardized diagnostic protocols and procedures to
ensure consistent results. For example, USDA provided funding and
leadership for two networks that serve the nation: the National Animal
Health Laboratory Network, which originally consisted of 12 state and
university veterinary laboratories nationwide, and the National Plant
Diagnostic Laboratory Network, which consists of 5 laboratories located
at land grant universities. By December 2004, the National Animal
Health Laboratory Network had expanded to 47 laboratories in 39 states
surveying domestic and foreign animal diseases. When these network
laboratories find positive test results for foreign diseases, USDA's
own federal laboratories in Ames, Iowa; Plum Island, New York; and
Beltsville, Maryland, still conduct their own diagnostic tests to
confirm results before USDA announces the outbreak of a disease.
Meanwhile, FDA, in conjunction with other agencies including USDA's
Food Safety and Inspection Service, developed and have continuously
expanded, the Food Emergency Response Network to integrate 93 local,
state, and federal laboratories for the detection of biological,
chemical, and radiological agents in food.[Footnote 28] Likewise, the
CDC has expanded its Laboratory Response Network to address public
health emergencies. This network now enlists the technology and
capacity of 138 laboratories across the United States and abroad in the
event of a suspected or known release of biological or chemical agents.
These federal laboratory networks have operated during animal, plant,
and human health emergencies in the past few years. For example, USDA's
animal and plant laboratory networks tested samples in the 2002-2003
exotic Newcastle disease outbreak in poultry and in the sudden oak
death outbreak in California in 2004.[Footnote 29]
* Agencies are also working to enhance coordination and communication
among multiple stakeholders. In particular, DHS, USDA, and other
agencies have established numerous interagency working groups to
coordinate their efforts to protect against agroterrorism. These
working groups are, in turn, coordinated through a Government
Coordinating Council, which DHS finalized in the fall of 2004. DHS,
USDA, and HHS alternately chair the Government Coordinating Council on
a rotating basis.[Footnote 30] DHS also helped the food and agriculture
industry to establish the Food and Agriculture Sector Coordinating
Council to facilitate the flow of alerts, plans, and other information
between the federal and state governments and industry groups. Through
the Food and Agriculture Sector Coordinating Council, DHS has been
seeking the expertise of the industry groups to develop national
guidance, such as the interim National Infrastructure Protection Plan.
In turn, this plan is intended to provide industry with a blueprint to
develop strategies to protect their assets. (See app. V for more
details about interagency working groups.)
* USDA has established a steering committee, which includes
representatives from FDA and CDC, to guide efforts to develop a
National Veterinary Stockpile that, among other things, is intended to
address vaccines needed to respond to animal diseases most damaging to
human health and the economy. The steering committee will also identify
such things as reagents, personal protection equipment that would be
needed, how to obtain vaccines, as well as prioritizing a stocking
schedule for the National Veterinary Stockpile. This stockpile is being
developed for foreign animal diseases other than FMD, since there is
already a North American FMD Vaccine Bank. USDA is also creating a
separate vaccine bank for certain strains of avian influenza that will
be completed by May 2005.
* DHS, USDA, and HHS are funding research to enhance the nation's
protection against agroterrorism. Of note, DHS is providing $33 million
over 3 years to establish two university-based Centers of Excellence to
oversee research into post-harvest food protection and diseases that
affect livestock and poultry. In addition, as of 2004, USDA is
supporting homeland security research, including university-based
efforts to evaluate contaminated carcass disposal efforts, assess
animal and plant disease test exercises, and analyze pathways by which
foreign animal and plant diseases can enter the United States.[Footnote
31] CDC has also provided $1 million in annual funding to a university
for developing a center for food security and public health that will
support efforts such as online programs to educate veterinarians in
foreign animal diseases. (See app. V for more details about research
efforts.)
* USDA's Veterinary Services has developed a National Animal Health
Emergency Management System that provides comprehensive guidance on
mitigating, preparing for, responding to, and recovering from an animal
health emergency, including a terrorist attack. USDA officials believe
the system's guidance is more efficient than that provided by previous
animal health manuals. For example, rather than changing with each
disease, the roles of various emergency response personnel change to
fit only three scenarios: an outbreak of a highly contagious disease
(e.g., FMD); an outbreak of a disease spread by "vectors" such as
mosquitoes (e.g., Venezuelan equine encephalomyelitis); or an outbreak
of a disease that is not highly contagious (e.g., bovine spongiform
encephalopathy). USDA officials believe that this approach will speed
response times and be more effective in containing any outbreaks,
whether natural or intentional. (See app. V for more details about
USDA's National Animal Health Emergency Management System.)
* Since 2002, USDA has created 14 Area Emergency Coordinator positions
across the nation for animal health, and 2 Regional Emergency
Coordinator positions for plant health, to coordinate federal and state
efforts in the event of an emergency, including agroterrorism.[Footnote
32] Among other duties, these coordinators have assisted states in
developing emergency response plans in keeping with federal guidelines,
and helped organize test exercises.[Footnote 33] For example, an Area
Emergency Coordinator was involved in developing Wisconsin's Animal
Health Emergency Management System, the nation's first statewide plan
that parallels the National Animal Health Emergency Management System
and outlines tasks and responsibilities of agencies and organizations
in an animal health emergency. The USDA emergency coordinators have
also responded to recent natural outbreaks of plant and animal
diseases, acting in key roles under the Incident Command System. For
example, an Area Emergency Coordinator served as the liaison officer to
the command staff for the widely reported bovine spongiform
encephalopathy case in Washington state in January 2004. The Western
Regional Emergency Coordinator helped respond to the soybean rust
outbreak in Louisiana in November 2004 and acted as a coach for the
incident management team.
The United States Still Faces Complex Challenges and Management
Problems in Protecting against Agroterrorism:
Although many important steps have been taken to prevent or reduce the
impact of agroterrorism, the United States still faces complex
challenges that limit the nation's ability to quickly and effectively
respond to a widespread attack on animal agriculture. There are also
some less complex management problems that impair the effectiveness of
federal agencies' efforts to protect against agroterrorism.
The United States Faces Challenges in Quickly Responding to a
Widespread Attack on Animal Agriculture:
Experts we spoke with told us that to effectively control the spread of
highly contagious foreign animal diseases, such as FMD, it is critical
to quickly identify animals that may have the disease, promptly confirm
the presence of the disease with diagnostic tools, and rapidly
vaccinate animals in the surrounding area. However, the United States
faces a shortage of veterinarians trained in foreign animal diseases,
does not use rapid diagnostic tools at the site of an outbreak, and has
insufficient vaccine stockpiles. These complex challenges impair the
nation's ability to contain the spread of animal diseases that are of
potential use in agroterrorism.
Many Veterinarians Lack Training in Foreign Animal Diseases:
Many U.S. veterinarians lack training to recognize the signs of foreign
animal diseases, according to a 2004 report produced for USDA. The
report notes that while all U.S. veterinary schools offer information
about foreign animal diseases, only about 26 percent of the nation's
veterinary graduates have taken a course specifically dedicated to
foreign animal diseases.[Footnote 34] According to the report, only 12
of the 28 veterinary schools in the United States offer courses
dedicated to foreign animal diseases. Further, among the 12 veterinary
schools that offer such courses, 5 offer them as electives rather than
as core courses. As a result, when federal or state veterinarians are
called to determine whether symptoms suggest the presence of a foreign
animal disease, they may not have the training or expertise needed to
identify it, and the disease could go undetected. According to USDA
officials, however, all veterinary students must take instruction in
infectious diseases and pathology which, according to these officials,
includes foreign animal diseases. USDA officials also told us they have
worked to develop Web and CD-Rom-based training to strengthen
veterinary student training in foreign animal diseases.
Another reason for this lack of expertise in foreign animal diseases is
that such training is not required to obtain USDA accreditation. More
than 80 percent of veterinarians in the United States are USDA-
accredited and are intended to be instrumental in maintaining effective
disease surveillance and monitoring by accurately diagnosing and
reporting animal diseases.[Footnote 35] To be accredited, an individual
must have graduated from an accredited school of veterinary medicine,
submitted an application certifying the ability to complete 16 tasks
such as recognizing common breeds of livestock, completed a core
orientation session, and be licensed or legally able to practice
without supervision. USDA officials believe that because an accredited
veterinarian must be licensed, this is an indication that they have
received basic training in foreign animal diseases. However, this
accreditation process does not require veterinarians to demonstrate
their ability to recognize or diagnose basic clinical signs of foreign
animal diseases.[Footnote 36] Furthermore, once granted, accreditation
is valid for life and no continuing education is required.[Footnote 37]
The Association of American Veterinary Medical Colleges believes that
this process could be more rigorous if, as a condition of
accreditation, veterinarians were required to demonstrate an ability to
recognize clinical signs of foreign animal diseases at the time of
accreditation and also periodically throughout their careers. USDA
recognizes the need to modernize its accreditation process and agrees
that continuing education is needed. APHIS drafted a rule to modify its
current program by developing a two-tiered National Veterinary
Accreditation program, which would have requirements for supplemental
training in such areas as emergency management and foreign animal
diseases;[Footnote 38] however, after more than 2 years, it is still
not in effect. According to the Chief of Staff of Emergency Management
and Diagnostics at APHIS, the draft rule has been undergoing revisions
but had to be set aside several times in an effort to pursue the
development of other more important draft regulations and emergency
regulations. According to this official, the draft rule is now being
reviewed by USDA's Office of General Counsel. This official told us
that this review can take several months, but if no problems are
encountered, it is anticipated that the draft rule will be published as
a proposed rule in the Federal Register during the first or second
quarter of calendar year 2005. USDA officials told us that new efforts
are also being made to strengthen APHIS' role in colleges of veterinary
medicine to provide information on various aspects of regulatory
medicine.
Finally, expertise in foreign animal diseases is lacking because most
veterinarians work in private practice where this skill is not
required. According to the American Veterinary Medical Association,
approximately 74 percent of practicing veterinarians in the United
States work in private practice.[Footnote 39] Similarly, the
Association of American Veterinary Medicine reports that only about
5,000 veterinarians work in public service,[Footnote 40] some of whom
play an essential role in the detection, prevention, and control of
foreign animal diseases. USDA officials told us they intend to increase
the number of veterinarians entering public service by making new
efforts to increase veterinary students' awareness of potential careers
in public service.
USDA Does Not Use Rapid Diagnostic Tools on Site:
Another complex challenge impairing the ability of the United States to
quickly contain an outbreak and limit the loss of animals is the
inability to rapidly diagnose diseases at the site of an outbreak.
Currently, if an animal is suspected of having a foreign disease, a
sample would be collected from the sick animal and a federal official
would send it by Express Mail to one of USDA's reference laboratories-
-either the NVSL in Ames, Iowa, or the Foreign Animal Disease
Diagnostic Laboratory located on Plum Island, New York.[Footnote 41]
Using traditional techniques, USDA technicians would generally diagnose
the disease in 3 to 4 days. During this time, the affected animals and
other animals within the vicinity, or those that had recent contact
with the sick animal, would be quarantined. Should USDA officially
confirm the presence of a disease, such as FMD, the affected herd and
all cattle, sheep, goats, swine, and susceptible wildlife--infected or
not--within a minimum 10-kilometer zone around the infected farm would
be killed. USDA would wait for confirmation before slaughtering animals
to avoid causing unnecessary panic among producers and severe market
fluctuations.[Footnote 42] If the disease were to spread beyond the
initial zone, authorities would continue to quarantine and kill animals
until the disease was "stamped out." USDA's "Crimson Sky" test exercise
in 2002, estimated that, under the current "stamping out" approach, FMD
would spread rapidly, necessitating the slaughter of millions of
animals and cause staggering financial losses--precisely the type of
high-visibility destruction that some experts told us terrorists seek.
According to the former Associate Administrator for Special Research
Programs at USDA's Agricultural Research Service, the impact of a
disease such as FMD can be mitigated if rapid diagnostic tools are used
on site to speed diagnosis. In 2000, under the direction of this
official, USDA developed state-of-the-art, rapid diagnostic tools to
detect FMD, classical swine fever, African swine fever, Rinderpest,
avian influenza, and Newcastle disease.[Footnote 43] According to this
official, the rapid diagnostic tools are designed to yield results in
less than an hour and are intended to be used outside of specialized
laboratories, at the site of an outbreak. Importantly, the tools can
detect disease before the animal shows clinical signs of infection.
According to USDA, symptoms of FMD may take up to 14 days to appear, or
even longer in sheep and goats. In fact, animals may show no symptoms
at all. USDA's draft guidance for controlling FMD warns that if the
first animal infected with FMD does not outwardly show clinical signs,
detection may be delayed. The guidance further states that potential
delays and difficulty in detection may complicate the decision-making
process regarding appropriate disease control measures. According to
the former Associate Administrator, rapid diagnostic tools would not
only allow for a rapid diagnosis but would also permit the monitoring
of nearby herds before symptoms appeared so that only infected herds
would have to be killed. Slaughter would, therefore, be based not on
proximity but on actual infection, thereby reducing the number of
animals lost and lessening the impact of the attack.[Footnote 44]
Overall, rapid diagnostic tools would be helpful because FMD would be
detected in less than an hour, informed control measures could be
implemented, and herds in the area would be under regular surveillance.
According to state officials, the use of these rapid tools on site
would also help prevent laboratories from becoming overwhelmed with
test samples, which would be an advantage if a terrorist attack
involved the introduction of disease at multiple locations. In 2003,
California state officials used rapid diagnostic tools to test animals
for exotic Newcastle disease--a contagious and fatal viral disease
affecting birds of all species. (See fig. 5.) These state officials
told us that the tools used at the time allowed diagnostic results
within 6 hours and enabled them to test up to 1,500 samples per day,
many more samples than traditional testing methods. State officials
also told us that rapid diagnostic tools would be useful during a
widespread outbreak so that individual animals or herds could be tested
in a temporary laboratory at the site of an outbreak, rather than
waiting for results while samples were sent to laboratories distant
from the outbreak.
Figure 5: Game Bird Infected with Exotic Newcastle Disease during the
2002-2003 Outbreak in California:
[See PDF for image]
[End of figure]
USDA officials believe that rapid diagnostic tools can be useful, but
they told us most such technologies are not yet ready to be used at the
site of an outbreak.[Footnote 45] While USDA has employed some of its
rapid diagnostic tools for exotic Newcastle disease and avian
influenza, it has done so only in select laboratories within the
National Animal Health Laboratory Network.[Footnote 46]
There are several reasons why USDA is reluctant to use the tools
outside of a laboratory setting. One reason is that samples put into
the rapid diagnostic tests may contain a live virus. For highly
contagious diseases such as FMD and classical swine fever, USDA
believes that rapid diagnostic testing must be conducted in a
specialized laboratory setting where certain procedures are taken to
prevent the virus from escaping and infecting livestock and wildlife.
According to the former Associate Administrator for Special Research
Programs at ARS, this precaution is unnecessary. Once a sample is
taken, it is inserted into a tube containing reagents that inactivate
the virus if it is present. The tube, as well as the person who
collected the sample, can then be decontaminated using a common
solution, such as acetic acid in the case of FMD, and the sample can be
tested using the rapid diagnostic tool in a mobile unit at, for
example, the entrance to the farm.[Footnote 47] USDA officials agree
that samples can be taken in this manner but told us that their current
technique for collecting samples for the rapid diagnostic tools that
USDA uses in its laboratories does not inactivate the sample. For that
reason, samples of highly contagious diseases must be processed under
special laboratory conditions. USDA uses this sampling technique in
order to preserve the "live virus" sample necessary for the traditional
method of diagnosing diseases. USDA officials told us they have
initiated discussions about sampling using an "inactivation model" such
as discussed above, but the sample would still be diagnosed using a
rapid diagnostic tool located in a laboratory.
Unlike USDA, agencies within DOD are using rapid diagnostic tools in
the field to obtain quick results during emergency situations or when a
laboratory setting is not possible, such as in combat zones.[Footnote
48] For example, the Army is using various types of rapid diagnostic
tools in Iraq to detect pathogens used in biological warfare, such as
anthrax. DOD officials told us that for samples that are a "true
unknown," such as chemical substances they encounter in combat, they
utilize many safety procedures, such as wearing protective clothing and
opening samples in safety cabinets. The officials also told us that the
reagents they use to detect agents used in biological warfare will
inactivate viruses, allowing the test to be safely conducted without
contaminating the surrounding area. A DOD official noted that with
animal diseases, if samples are positive for a disease, then
contaminating other animals within that herd is not a concern since
these animals would have to be destroyed anyway.[Footnote 49]
Another reason USDA is reluctant to use rapid diagnostic tools at the
site of an outbreak is that personnel need training to use the tools.
According to the former ARS Associate Administrator, however, the tests
are designed to be performed by persons with limited training, using
quality-controlled standardized reagents and protocols that are
consistent with international standards.[Footnote 50] DOD concurs that
the tools are not difficult to use, but to ensure that samples are not
contaminated and results are rigorous, the U.S. Army Medical Research
Institute of Infectious Diseases requires personnel to undergo a 4-week
training program and follow strict procedures, such as loading and
capping pathogen samples before adding the control samples to help
eliminate cross-contamination.[Footnote 51] To help increase confidence
in the accuracy of the results, DOD also uses more than one type of
rapid diagnostic tool to test a sample if it comes back positive.
[Footnote 52]
USDA officials told us that although the rapid diagnostic tools have
been developed, these tools still need to be validated before they can
be used in order to rule out diseases with similar clinical signs or
protein sequences that might result in a false positive result.
Therefore, USDA would still make an initial diagnosis using traditional
test procedures and confirmatory testing would still be done at NVSL in
Ames, Iowa, or at the Foreign Animal Disease Diagnostic laboratory on
Plum Island in New York. Once the initial diagnosis is confirmed, USDA
believes there may be opportunities to use validated rapid diagnostic
tools to evaluate herd health either on site or at a nearby laboratory.
USDA further agrees that it is important to evaluate the costs and
benefits of developing and validating these tools for use outside of a
laboratory setting.
Vaccines Cannot Be Rapidly Deployed to Contain a Widespread Disease
Outbreak:
For several reasons, USDA would not be able to deploy vaccines rapidly
enough to contain a widespread animal disease outbreak caused by a
deliberate attack. First, USDA has very few supplies of vaccines. The
only vaccines currently stored in the United States against foreign
animal diseases are for various strains of FMD because this disease is
so highly contagious. In place of vaccination, USDA generally prefers
to immediately slaughter diseased animals because international rules
that the United States and other countries have agreed to abide by are
designed to prevent trade in infected or vaccinated animals. As a
result, vaccine stockpiles have traditionally not been needed to
control natural outbreaks. Also, vaccines have not yet been developed
for all foreign animal diseases that USDA considers to be of primary
concern.[Footnote 53] For example, worldwide, there is no vaccine
currently available for African swine fever. USDA's ARS is researching
new vaccines, but it is unlikely that vaccines will ever be developed
for all strains of these diseases because of the vast number of strains
and subtypes for each disease. For example, there are 7 different types
of FMD with more than 60 different subtypes. According to an expert we
consulted, it is not realistic to develop vaccines for all of these
subtypes. It is also conceivable that a terrorist could genetically
engineer a new strain.
Second, the only vaccines that are stockpiled in the United States--
vaccines for FMD--cannot be rapidly deployed because they are not
stored in a "ready-to-use" state. Although HSPD-9 states that vaccines
should be capable of deployment within 24 hours, USDA's stockpiles are
concentrates that require additives to become a vaccine. Because the
additive for the FMD vaccine is manufactured in the United Kingdom,
USDA must first ship the stock there for bottling and subsequent
testing. It can take up to 3 weeks to transform the stock into a
vaccine once the concentrate arrives in the United Kingdom. Vaccines
are not stockpiled in a ready-to-use state because vaccines generally
have a shelf life of only 1 or 2 years before they must be used or
destroyed, and replacing stocks on a regular basis would be expensive.
Yet until animals are vaccinated, USDA will have no recourse but to
slaughter animals in a systematic manner to contain the spread of the
disease. While this approach may be adequate for containing a limited
outbreak, the recent USDA test exercise of an intentional introduction
of FMD in multiple locations suggests that this approach would have
catastrophic results.[Footnote 54] Although USDA officials raise
concerns about the use of vaccination to control an outbreak, such as
the limited number of fully trained personnel to administer the
vaccine, it is now acknowledged that the ability to vaccinate, in
conjunction with culling, may be a necessary measure to contain an FMD
outbreak. A recent evaluation by the National Audit Office in the
United Kingdom reports that the government has substantially increased
stocks of vaccines for FMD to better contain the spread of FMD should
another outbreak occur.[Footnote 55] Furthermore, USDA's draft response
plan for an outbreak of FMD disease or other highly contagious animal
disease notes that vaccines may be used strategically to create
barriers between infected zones and disease-free zones.
The Centers for Disease Control and Prevention faces similar challenges
in stocking vaccines used to protect humans. Because many animal
diseases can affect humans, CDC is participating in the steering
committee to help USDA create its National Veterinary
Stockpile.[Footnote 56] An expert suggests, and CDC officials agree,
that USDA could contract with pharmaceutical companies to supply a
stockpile of ready-to-use vaccines. Once the shelf life for those
vaccines neared expiration,[Footnote 57] the contractor could replenish
the stock and then sell the supply of vaccines nearing expiration in
the commercial marketplace to countries that routinely vaccinate
livestock. Where the market would not support such sales, USDA could
donate the old, yet still effective, vaccines to other countries where
the disease is endemic and there is still a demand.[Footnote 58] USDA
officials agree that it would be useful to have the FMD virus vaccine
available within 24 hours.[Footnote 59] They also told us they have
plans to consider options to cut some of the time delay for obtaining
finished, ready-to-use vaccines. One option could be storing the frozen
bulk antigen concentrate needed to produce the vaccine at the site of
the foreign manufacturer. While it is the responsibility of the
steering committee to consider options and recommend specific processes
for each of the foreign animal diseases of concern to the United
States, it is not clear if the steering committee will address the
costs and benefits of developing ready-to-use vaccines that can be
quickly deployed against diseases of primary concern.
Finally, even if USDA were to overcome the difficulties discussed above
and develop adequate stockpiles of ready-to-use vaccines, current USDA
policy would require a complex decision-making process to determine if
vaccines would be deployed in an outbreak. In 2000, USDA decided to use
a decision tree flowchart combined with decision matrices that evaluate
multiple factors to determine when and if to use vaccines to control an
outbreak. Because the use of vaccines would affect trade and have major
consequences for both USDA and producers, the decision tree is complex
and may not be designed for rapid decision-making, such as would be
needed during a terrorist attack.[Footnote 60] For example, it requires
information on the availability of human resources, public opinion and
perception of government, industry acceptance, and vaccination costs,
as well as slaughter and disposal capacity. USDA officials agree that
this process is lengthy, but this is because of the many variables,
including the location of the outbreak in relation to susceptible
animal populations as well as trade concerns and restrictions that
impact this decision-making process. As previously noted, HSPD-9
requires that vaccines be deployed within 24 hours of an outbreak, but
such rapid deployment may not be achievable under the current, complex
decision-making process. USDA officials told us they can explore the
possibility of designing a more rapid decision-making process; however,
they noted that it would take additional time to select, deploy, equip,
and direct vaccination crews in a manner that would be advantageous to
disease eradication and not cause the virus to spread from farm to farm
due to the vaccination process. Hastily applied vaccination programs
could prove detrimental. A USDA official also told us that it is not
possible to estimate how long it would take to determine whether to use
FMD vaccines based on the decision tree flow chart, due to the many
variables involved in the process.
Federal Agencies Have Not Addressed Several Management Problems:
In addition to the complex challenges discussed above, federal agencies
are encountering management problems that further impair the
effectiveness of their efforts to protect against agroterrorism. First,
since the transfer of agricultural inspectors to DHS, inspections and
interceptions of prohibited agricultural products and pests have
declined nationally, and inspectors are less available to respond to
agricultural emergencies. Second, there are weaknesses regarding the
flow of critical information among key stakeholders. Third, USDA has
not hired a sufficient number of Area and Regional Emergency
Coordinators to help states prepare for an agricultural emergency.
Fourth, DHS has not developed controls to avoid duplication of effort
among agencies. Finally, federal agencies' diagnostic laboratory
networks are not yet integrated for diseases of common concern.
Agricultural Inspections and Interceptions Have Declined, and Fewer
Inspectors Are Available to Respond to Agricultural Emergencies since
the Transfer of USDA Inspectors to DHS:
Since the transfer of most USDA Plant Protection and Quarantine (PPQ)
inspectors to DHS in March 2003,[Footnote 61] government officials,
reports, and data indicate that the nation may be more vulnerable to
the introduction of foreign animal and plant diseases through ports of
entry into the United States.[Footnote 62] In addition, the transfer of
inspectors has reduced USDA's ability to respond to agricultural
emergencies.
Inspectors Have Performed Fewer Agricultural Inspections and Made Fewer
Interceptions of Prohibited Plant and Animal Products and Pests:
USDA officials, as well as agricultural inspectors who now work at DHS,
told us that inspections of agricultural products have decreased at
some land border crossings, airports, and maritime ports--including
three major ports that receive a high percentage of the nation's
agricultural imports and international flights. USDA provided us with
data showing an overall decline in the number of inspections nationwide
since 2002[Footnote 63]--the last year when USDA had sole
responsibility of agricultural inspections. This decrease occurred at a
time when imports and international air traffic have increased. In
fiscal year 2002, there were 40.9 million agricultural inspections at
ports of entry; in fiscal year 2003, the year when USDA inspectors
transferred to DHS, 35.0 million inspections were conducted; and in
fiscal year 2004, there were 37.5 million agricultural inspections.
USDA data also show that inspections have decreased at certain types of
ports and by certain modes of entry nationwide, such as passenger
baggage and cargo.[Footnote 64] In particular, USDA officials and DHS
inspectors told us that the number of agricultural inspections has
declined at three specific air and sea ports that receive a large
proportion of international cargo and passenger baggage. For example,
at one of these ports, former and current DHS agricultural inspectors
told us they had cut their inspections in late 2004 by more than 50
percent, from an average of about 1,200 cargo containers per week to
500 per week. These inspectors said they reduced inspections, in part,
because of an instruction by the DHS port director to cut their "holds"
of agricultural cargo and conduct fewer inspections of tile, which are
often packed in a regulated material that can contain pests such as
snails and beetles.[Footnote 65] In August 2004, this port intercepted
a species of live, wood-boring beetles as a result of holding and
inspecting cargo tile shipments. However, another shipment at this port
that was not inspected was later found to contain the same beetles,
which belong to the Asian longhorned beetle family and are costly to
treat. These inspectors were concerned that if DHS continued to
decrease agricultural inspections at that port, importers would direct
more illegal shipments there. DHS officials acknowledged that, since
the transfer of inspectors, inspections have declined overall. However,
they also pointed out that some ports have increased their inspections
in the past 2 years. For example, USDA data show that inspections at
land border crossings increased from 21.2 million agricultural
inspections in fiscal year 2002 to 22.5 million such inspections in
fiscal year 2004.
USDA data also indicate a decline in the number of agricultural
interceptions--seizures of prohibited plant and animal products, and
agricultural pests--at ports of entry nationwide since the transfer of
inspectors to DHS. Interceptions dropped from 1.8 million in fiscal
year 2002, when USDA had sole responsibility for inspections, to 1.6
million in 2004, when DHS had primary responsibility for agriculture
inspections. However, in 2003, a transitional year, interceptions
totaled 1.8 million. Interceptions of reportable pests in particular
have declined each fiscal year--from 77,886 in 2002, to 72,988 in 2003,
and to 54,109 in 2004. USDA officials told us that interceptions are a
meaningful indicator of effective inspections because the purpose of
inspecting agricultural products is to intercept prohibited items and
pests. USDA is concerned that the decrease in interceptions may
indicate a decline in the quality of inspections or a switch to less
effective methods. For example, USDA and DHS officials told us that
while agricultural inspectors rove several ports of entry with sniffing
dogs--an effective method for detecting and therefore intercepting
prohibited items--they are now used less frequently. DHS and USDA
officials also noted that the number of interceptions can vary based on
a number of factors aside from inspection quality, including changes in
the amount or type of agricultural products entering the country and in
international passenger travel patterns. However, we found that both
agricultural imports and international air passengers entering the
United States had increased over the past 2 fiscal years.[Footnote 66]
USDA officials told us that the number of interceptions should
generally increase accordingly. At the time of our report, DHS
officials told us they were not aware of changes in inspection methods
or the risk management approach used at ports that could account for
the decline in agricultural inspections and interceptions. According to
agency officials, neither USDA nor DHS has analyzed the inspections and
interceptions data to identify trends and potential areas for
improvement, but headquarters officials at both agencies told us they
would analyze the data in early 2005.[Footnote 67]
Although USDA and DHS officials have not begun an analysis to determine
the reasons for declining agricultural inspections, they believe that
several factors are responsible for the decline in agricultural
inspections and interceptions. First, there is a shortage of
agricultural inspectors nationwide. In March 2003, USDA transferred
1,517 full-time inspectors, according to DHS officials.[Footnote 68]
Recently, DHS has been able to hire new agricultural inspectors, but
numerous departures left DHS with 1,446 agricultural inspectors and 426
vacancies as of mid-October 2004.[Footnote 69] DHS told us that the
agency intends to hire more than 500 additional agricultural inspectors
by February 2006. However, DHS officials said the agency's ability to
quickly hire new inspectors is impeded by the length of time needed for
conducting security background checks. These background checks, which
are required before a newly hired inspector can report for duty, can
take more than a year to process, by which time applicants might find
other work. Agricultural inspectors working at the ports suggested to
us that DHS could allow new inspectors to perform nonsensitive
procedures while background checks are pending. According to a DHS
headquarters official, the agency is allowing some new inspectors with
modified background checks to start work under certain circumstances
while their full background investigations are pending.
Second, DHS agricultural inspectors are sometimes used for other
purposes, such as helping reduce immigration lines at airports. For
example, a DHS supervisor of agricultural inspectors at a capital city
airport told us that his inspectors are regularly pulled from their
agricultural duties to inspect other types of cargo or to assist in
clearing passengers though immigration. DHS officials told us that they
need the flexibility to occasionally shift inspectors' duties to
respond to different priorities and needs, such as searching for drugs
rather than inspecting agricultural products for diseases or pests. For
this reason, all customs, immigration, and agricultural inspectors are
cross-trained to perform aspects of each other's work.
Third, DHS agricultural inspectors do not always receive timely
information about high-risk cargo that should be held for inspection.
For example, after Canada confirmed a case of bovine spongiform
encephalopathy in 2003, inspectors at one border crossing did not
receive a warning from USDA to hold shipments of Canadian beef in time
to intercept it, and let the shipment through. In another instance, DHS
inspectors at a sea port in a major agricultural state told us they did
not receive an alert in late 2004 about an outbreak of a strain of
avian influenza that can cause death in humans, until a week after the
warning was released. DHS headquarters officials told us that while
some cargo alerts issued by USDA do not get to every agricultural
specialist in a timely manner, these instances represent a small
fraction of inspections. However, these officials agreed that
improvements can be made to improve the flow of information.
Agricultural inspectors and other port officials attributed the delay
in receiving information to the transfer of some inspection roles and
responsibilities from USDA to DHS. This transfer has created additional
layers of communication that have impeded the rapid delivery of
critical information to port inspectors. Whereas USDA used to
communicate critical information directly to its agricultural
inspectors, DHS inspectors told us that now they receive information
indirectly through DHS headquarters. While DHS officials told us this
practice is not the agency's policy, they acknowledged that some ports
follow a hierarchical chain of command. The memorandum of agreement
between the two agencies, which is designed to delineate new roles and
responsibilities, does not detail how DHS should convey alerts,
warnings, directives, or guidelines that come from USDA.
Finally, DHS and USDA have different databases and information
technology systems, including email, which has further hindered their
ability to share information. For example, agricultural inspectors who
transferred to DHS have experienced difficulty in accessing USDA's
intranet site, where the Work Accomplishment Data System, the primary
agricultural inspections database, can be viewed. DHS agricultural
inspectors told us they still cannot enter USDA's electronic Emergency
Action Notification System, which was created after September 11, 2001,
to track problematic or prohibited imported goods at ports of entry.
DHS officials acknowledged technical problems in the integration of the
two agencies' systems, but said that they are working with USDA to
address these problems.[Footnote 70]
As a related matter, some DHS inspectors we spoke with expressed
concern that the cross-training for "legacy" customs and immigration
inspectors on agricultural laws, policies, and inspection procedures is
insufficient--and that these legacy inspectors are thus not able to
increase the number of items they refer to agricultural inspectors for
further examination.[Footnote 71] For example, while legacy customs
inspectors receive weeks of cross-training on immigration functions,
they receive only 3 hours of computer-based training on agriculture.
Inspectors told us that while the computer-based training raises
awareness of the importance of agriculture, it has not enabled legacy
customs and immigration inspectors to increase the amount of prohibited
items they refer to agricultural inspectors. Furthermore, the training
is not always supervised by an agricultural inspector who could answer
questions.[Footnote 72] DHS officials agree that training for legacy
customs and immigration inspectors should be enhanced, and told us that
much training enabling legacy officers to make referrals to agriculture
specialists has been accomplished. These officials also told us that
all inspectors will be required to take a new course on agriculture
procedures that will be launched in fiscal year 2005. This course,
which will combine 16 to 24 hours of classroom and on-the-job training,
is intended to help customs and immigration inspectors better screen
and refer suspicious items to agricultural inspectors.[Footnote 73]
Fewer Inspectors Are Available to Help USDA Manage Agricultural
Emergencies:
In addition to the decline in inspections and interceptions, DHS has
not been able to loan sufficient numbers of inspectors to respond to
agricultural emergencies managed by USDA, according to USDA
officials.[Footnote 74] Since the transfer of agricultural inspectors
to DHS, the memorandum of agreement between the two agencies
implementing the transfer provisions of the Homeland Security Act of
2002 states that DHS and USDA agreed to develop procedures for USDA use
of DHS employees, but it does not detail how many employees DHS must
loan, or for what time period. While DHS has dispatched some
agricultural inspectors on temporary duty, USDA officials said that
compared to the assistance available prior to the transfer to DHS, the
number of such personnel and the length of time they were available
have been inadequate. For example, USDA's Western Regional Office
requested 83 agricultural inspectors from DHS to help control and
contain the exotic Newcastle disease outbreak in California over 2
months in 2003. DHS provided 26 employees, but declined USDA's requests
for further assistance. As a result, USDA officials are concerned that
DHS will not loan a sufficient number of specialists to help treat and
contain future agricultural emergencies, including the likely infection
of the 2005 soybean crop with soybean rust--a plant disease identified
by USDA pursuant to the Bioterrorism Act of 2002 as having the
potential to pose a severe threat.[Footnote 75] DHS officials told us
they have not been able to loan greater numbers of inspectors to USDA
to respond to agricultural emergencies because of the staff shortage.
DHS officials also said their policy is to loan agricultural inspectors
with specific expertise, but the agency's first priority is to clear
ports of entry. Once DHS feels the ports are adequately staffed with
agricultural inspectors, the agency will be in a better position to
dispatch agricultural inspectors to USDA for emergency purposes.
Experts say that routine inspections at ports of entry cannot, by
themselves, prevent the accidental or intentional introduction of
diseases. However, experience has shown that inspections can be
successful in intercepting harmful diseases. In 2004, for example, DHS
and USDA agricultural inspectors at a California mail facility
prevented an outbreak of citrus canker when they successfully
intercepted an illegal package of branch cuttings from Japan that were
intended to start a new variety of citrus groves. An outbreak of citrus
canker--a highly contagious bacterial disease--would threaten the
state's crop and billion-dollar citrus industry, the second-largest in
the nation.[Footnote 76] The state of Florida, for example, has lost
2.1 million citrus trees due to the spread of the disease since 1995.
There Are Weaknesses Regarding the Flow of Critical Information Among
Key Stakeholders:
Federal agencies face barriers to promptly and effectively sharing
critical guidance that is important to state and industry stakeholders
to better protect the agriculture sector. State and industry officials
told us they did not receive draft national guidance in a timely
fashion; DHS may not be providing states sufficient guidance to
allocate homeland security grant funding for agriculture; and after-
action reports on test exercises and real outbreaks are not routinely
shared with many stakeholders who could benefit from the lessons
learned.
While efforts have been made to include agricultural stakeholders in
the development of national guidance through various working groups,
state and industry officials told us they were not given sufficient
time to review and comment on key draft national guidance from DHS
pertaining to protecting infrastructure and preparing for emergencies.
Specifically, officials said that they had as little as 3 days to
review and submit comments on both the draft National Response Plan and
the draft National Infrastructure Protection Plan, even though they
will be expected to implement critical sections of these plans. As a
result, state and industry officials we spoke with are concerned that
these plans may set unrealistic expectations. Although we asked, DHS
officials did not explain to us how they distributed the National
Response Plan to stakeholders. When distributing the National
Infrastructure Protection Plan, DHS officials sent the plan to the
offices of State Homeland Security Advisors, which had the
responsibility to solicit comments from appropriate stakeholders within
a 2-week period. DHS officials told us that they had no input over
which state agencies received the draft plan, and they believe that in
some instances state officials may have delayed distribution to state
departments of agriculture. DHS also distributed the draft plan for
review through the Government Coordinating Council and the Food and
Agriculture Sector Coordinating Council. DHS officials told us that
limiting the comment period to 2 weeks was necessary in order to meet
the timelines set by HSPD-7. DHS officials further noted that because
of the limited time allowed for initial review of the National
Infrastructure Protection Plan, they released the plan as an interim
document, allowing public and private stakeholders to have more input
in the final plan. DHS officials acknowledged that in the future, they
will use different procedures to distribute drafts for state and
industry comments.
Furthermore, DHS may not be providing sufficient guidance to the states
on how to use the Homeland Security Grant Program to obtain federal
emergency preparedness assistance to support the agricultural
sector.[Footnote 77] Although states must fulfill a number of
requirements to receive DHS emergency preparedness grants, DHS gives
leeway regarding which disciplines--such as fire, law enforcement, or
agriculture--states choose to fund with DHS grants. However, according
to federal and state officials, in the past, states used grant funding
mainly for "traditional" emergency disciplines such as law enforcement.
Prior to 2004, DHS grant application kits did not refer to agriculture
as a sector eligible for emergency assistance. DHS grant program
officials told us that, based on feedback from the states, in 2004 they
included agriculture as an emergency discipline toward which states can
apply DHS funding. However, despite the inclusion of agriculture in the
application guidance, state officials told us that they have received
limited funding from DHS relative to other emergency disciplines. For
example, one official from a major agriculture state told us that in
fiscal year 2004 the state had set aside less than $600,000 for
agroterrorism projects out of a total of over $20 million that DHS had
allocated to the state.[Footnote 78] The same state had received a $2-
million grant to head a multistate partnership to protect against
agroterrorism in fiscal year 2003, but because this amount was in the
form of a directed grant, it could not be used to purchase equipment or
training for state or local responders. Federal officials believe that
agriculture continues to receive limited emphasis in the fiscal year
2005 grant kit relative to other funding priorities. For example, in
several instances throughout the fiscal year 2005 grant kit,
agriculture does not appear in lists of other disciplines that are
eligible for funding. Federal officials told us that without additional
guidance or emphasis, state governments would continue to fund
traditional emergency preparedness disciplines without considering
agriculture.
Finally, state and industry officials told us that there is no
mechanism to share lessons learned from federal and other state or
industry test exercises or from real-life animal and plant disease
outbreaks--such as the exotic Newcastle disease outbreak in California
or from the karnal bunt outbreak in Texas. Several state and industry
representatives expressed interest in receiving after-action reports so
they could benefit from lessons learned. They also believe that lessons
learned do not have to be industry-specific. For example, one crop
industry group official told us it would be helpful to learn from FMD
exercises, as well as the real-life bovine spongiform encephalopathy
outbreak, about ways to better communicate during an outbreak. DHS
officials told us that they will soon deploy a secure Web site for the
food and agriculture sector as a component of DHS' Homeland Security
Information Network. According to these officials, this new Web site,
now in development, will provide government and industry the capability
for information sharing; disseminating alerts and warnings; sharing
best practices; and coordinating efforts between the states, industry,
and federal agencies in a protected environment. However, this effort
is still in its early stages, and to date the proposed Web site does
not include after-action reports. In addition, federal, state, and
industry officials we spoke with were apparently unaware of the Web
site's development.
USDA Currently Has an Inadequate Number of Area and Regional Emergency
Coordinators, Resulting in Insufficient Technical Assistance to the
States:
USDA faces another management challenge in helping states prepare for
animal and plant emergencies because of an insufficient number of Area
and Regional Emergency Coordinators. As a result, states are not
receiving sufficient federal assistance in developing emergency
response plans and other activities. In 2002, USDA created 14 Area
Emergency Coordinator positions for animal health issues, and 1
Regional Emergency Coordinator position for each of the eastern and
western regions for plant disease outbreaks. By the time of our report,
USDA had filled 13 of the 14 coordinator positions on the animal side,
and both of the plant health positions. However, 2 of the animal health
emergency coordinator positions--which together span six states,
including the two biggest agricultural states--were vacant until late
2004. Federal officials also told us that the current number of
emergency coordinator positions is insufficient to cover their areas or
regions, even if all the positions were filled. This is because the
emergency coordinators are responsible for large geographic areas. On
average, Area Emergency Coordinators cover 3 states, while Regional
Emergency Coordinators are responsible for up to 27 states, plus
territories. As a result of this heavy workload, USDA officials said,
states are not receiving the maximum benefit of a coordinator's
guidance and assistance in preparing state emergency response plans and
other preparedness activities. For example, 10 states had not completed
their required planning documents to identify resources needed in a
plant health emergency, by the September 30, 2004, deadline.[Footnote
79] And of those plans submitted, USDA found some to be of
unsatisfactory quality. USDA officials attributed these delays and
deficiencies, in part, to the fact that the Regional Emergency
Coordinators cannot spend adequate time with state and federal
agricultural officials in each state. They added that if there were a
greater number of emergency coordinators, each coordinator would have
fewer states to cover and thus more time to devote to their advisory
responsibilities.
USDA is also struggling to attract an adequate number of qualified
applicants due to the heavy travel involved to cover their areas or
regions.[Footnote 80] In addition, the job requires traveling to animal
or plant health emergency locations anywhere in the United States with
as little as 24 hours notice, and for several weeks or more at a time.
For example, one animal health emergency coordinator made 29 trips away
from his duty station in 14 months on the job, not including other
meetings in his three-state area. These trips were necessary for test
exercises, conferences, regional FEMA meetings, USDA meetings, and the
exotic Newcastle disease outbreak, which occurred in a state outside
his area. USDA officials say that APHIS' goal is to put an Area
Emergency Coordinator in each of the 43 states where there is an Area
Veterinarian in Charge, and to increase the Regional Emergency
Coordinators for plant disease outbreaks.
Shortcomings Exist in DHS' Coordination of Federal Working Groups and
Research Efforts:
Government and industry officials have expressed concern about
shortcomings in DHS' coordination of national efforts to protect
against agroterrorism. Since the issuance of HSPD-9 in January 2004,
DHS and other federal agencies established several interagency working
groups to address the tasks set out in the directive. To oversee these
working groups, DHS recently established a Government Coordinating
Council for agriculture. According to DHS officials, the council's
charter outlines the specific tasks for federal agencies and the
numerous working groups that have been established to address HSPD-
9.[Footnote 81] However, other federal officials have expressed concern
that because the working groups were established prior to the
development of the council, activities under way are not well
coordinated. For example, according to agency officials, the task list
developed by the Government Coordinating Council Charter does not
correspond to the tasks outlined in other important national guidance
documents, such as the National Response Plan. This discrepancy could
lead to confusing implementation of national guidance. Furthermore,
state and industry officials we interviewed said they did not
understand the roles and responsibilities of these various groups and
that no one seemed to be tracking the specific purpose of various
efforts.
In addition, DHS lacks controls to coordinate research efforts with
other agencies, even though HSPD-9 specifically designates DHS as the
agency responsible for coordinating research efforts to protect against
agroterrorism. For example, some of the DHS-supported activities at the
Centers of Excellence appear to duplicate research conducted by USDA's
Agricultural Research Service and the Cooperative State Research,
Education, and Extension Service. Specifically, one center is
developing rapid diagnostic tools for FMD and other foreign animal
disease research that is apparently already under way at USDA. DHS
officials told us that while program staff at DHS, HHS, USDA, and other
agencies have engaged in some preliminary discussions, there is no
overall departmental coordination of policy and budget issues
concerning agriculture and food security within DHS and with other
departments and agencies. USDA officials stated that while they are not
aware of any overlap in the programs supported by USDA and DHS, they
are also not aware of the full scope of the activities of the Centers
of Excellence.[Footnote 82] USDA officials agree that more coordination
and cooperation is needed between USDA and DHS regarding research
activities.
Agencies' Diagnostic Laboratory Networks Are Not Yet Integrated:
While the development of USDA and HHS national diagnostic laboratory
networks is a positive step, their effectiveness in sharing diagnostic
information about diseases is compromised because their databases are
not yet integrated. At the time of our review, USDA had not integrated
the databases of its own national laboratory networks due to
compatibility and confidentiality issues. Because the USDA-affiliated
laboratories operated independently prior to the creation in 2002 of
the National Animal Health Laboratory Network and the National Plant
Diagnostic Network, the member laboratories are still using their
individual databases. USDA officials say these individual databases use
different codes and messaging systems and thus do not communicate well
with each other. For example, each National Animal Health Laboratory
Network facility enters animal disease diagnostic information into its
own database, but neither of the other laboratories in the network nor
USDA's NVSL--which is responsible for officially testing foreign animal
diseases--can read that information. Instead, USDA relies on
traditional communication channels, such as emails and phone calls, to
relay test results and the recipients do not have electronic access to
the detailed data. This approach limits USDA's ability to look at
diagnostic data from across the country, detect trends, and implement a
response as quickly as it could with an integrated, real-time system.
USDA officials told us that if their laboratories' diagnostic databases
were linked to each other nationally, the agency would be able to
better monitor and respond more quickly to disease outbreaks. USDA
stresses that the ability to share diagnostic information quickly is
particularly important for diseases that spread rapidly, such as FMD,
because response time is critical in controlling the spread of the
disease and reducing the economic impact.
In addition, the Food Emergency Response Network, CDC's Laboratory
Response Network, and USDA's National Animal Health Laboratory Network
and National Plant Diagnostic Network have not yet linked their
databases to each other for diseases of common concern. USDA and HHS
officials say it is important for their agencies to rapidly share
complete diagnostic test results with each other regarding diseases of
concern to all of the agencies involved. For example, if USDA found a
chicken with a strain of avian influenza that is transferable to
humans, it would be important for CDC to immediately become aware of
this information so that it could take appropriate measures to protect
human health. Similarly, if USDA confirmed a cow with bovine spongiform
encephalopathy, it would be important for FDA to know quickly so that
it could investigate whether the infected products had entered the food
chain and take any necessary action. In addition, USDA officials say
that an integrated diagnostic information system would aid federal
agencies' ability to gather evidence in investigations, including
criminal ones, of disease outbreaks.
Federal agencies are aware of the importance of integrating databases
and are taking steps to link their networks. As authorized by the
Bioterrorism Act of 2002, USDA is currently working on integrating all
of the National Animal Health Laboratory Network facilities so that
they are able to send diagnostic information in real-time to a
national, electronic database. This new database will allow diagnostic
information to be sorted and analyzed by USDA's Centers for
Epidemiology and Animal Health to track animal diseases across the
United States and detect any trends. If a positive test result from any
of the laboratories enters this new database, it will automatically
trigger a series of events to notify relevant parties. USDA officials
say that while they will still rely on phone calls and other
communication channels, this integrated, real-time database will
improve accuracy and speed in the event of an emergency. So far, USDA
has piloted the integration of some of the National Animal Health
Laboratory Network facilities' databases for two foreign animal
diseases, and it plans to launch the national database for one of those
diseases in February 2005. By the end of 2005, USDA plans to integrate
information from 12 pilot National Animal Health Laboratory Network
laboratories into the database for the eight diseases of highest
concern if this project is fully funded.[Footnote 83] In addition, USDA
is planning to integrate its plant disease and pest databases for use
in the National Plant Diagnostic Network to monitor outbreaks
nationwide.[Footnote 84]
USDA officials told us that integrating the different laboratories'
databases is a challenge because of the concern for the leak of
information. This concern arises because in the event of an outbreak,
there would be international trade repercussions, and USDA would be
responsible for reimbursing producers for animals that would have to be
destroyed. Other laboratories face similar security concerns. However,
the member laboratories within CDC's Laboratory Response Network, which
has been in place since 1999, are able to securely share diagnostic
results with each other, and officials told us it is important for USDA
to overcome this problem. Similarly, FDA uses a secure data exchange
vehicle to share information across its diagnostic laboratory network.
In an effort to address security concerns, USDA has begun building
firewalls and developing a set of protocols to protect data and ensure
confidentiality in such an environment.
As called for in HSPD-9, USDA and HHS created an interagency working
group in late 2004 to begin the process of coordinating their networks
for zoonotic disease surveillance.[Footnote 85] For example, USDA and
FDA are looking at how they can share animal disease and food pathogen
test results through a secure data exchange. However, the agencies must
also work out common testing benchmarks and protocols in order to
interpret each other's diagnostic information accurately. For instance,
if CDC was aware of the type of diagnostic tools that USDA was using,
the agency would be better able to interpret results and take
appropriate action. Agency officials added that DHS' planned National
Biosurveillance Integration System intends to use information from the
various federal laboratory networks and combine this with threat and
intelligence data to further improve surveillance efforts for potential
terrorist activity. DHS officials indicated that the National
Biosurveillance Integration System would have an initial capability for
integrating data from these laboratories by spring 2005.
Conclusions:
Prior to the terrorist attacks of 2001, relatively little attention had
been focused on agroterrorism. Recently, however, agriculture is
receiving more attention as experts and government officials
increasingly recognize the need to reduce the vulnerability of this
sector to the deliberate introduction of animal or plant diseases.
Federal and state agencies are investing considerable resources to
better identify and manage the risks of agroterrorism and have ramped
up planning and coordination efforts to respond to such an event. There
are still, however, several important challenges that should be
addressed to better equip our nation to manage agroterrorism. First,
the United States must enhance its ability to quickly identify and
control diseases. Until USDA requires accredited veterinarians to be
trained to recognize the clinical signs of foreign animal diseases,
such diseases may not be detected and confirmed as early as possible,
wasting valuable time that could be spent containing them. Similarly,
until USDA evaluates the costs and benefits of using rapid diagnostic
tools at the site of an outbreak, the agency may be missing an
opportunity to reduce the impact of agroterrorism. Without on-site
diagnosis to help monitor neighboring herds, animals would likely be
slaughtered based on proximity rather than confirmed infection,
unnecessarily magnifying the impact of an attack. Once diseases have
been accurately diagnosed, the United States needs to quickly decide
whether vaccines should be used to control an outbreak and have the
ability to deploy ready-to-use vaccines within 24 hours. Otherwise,
during an emergency, valuable time could be lost while deliberating
whether to use vaccines and waiting for vaccines to be transformed into
a ready-to-use state.
Several less complex managerial problems should also be addressed in
the short term to improve the nation's ability to protect against
agroterrorism. Our nation's ports could be unnecessarily vulnerable to
the intentional introduction of a disease or pest, unless agencies
analyze the reasons for declining agricultural inspections and
streamline the flow of information between USDA and DHS inspectors at
ports of entry. Furthermore, states and industry may not have the
ability and information to fulfill their assigned roles in protecting
agriculture unless DHS provides them with meaningful opportunities to
comment on national guidance; agencies share after-action reports of
test exercises and real-life emergencies with these stakeholders; and
USDA identifies ways to fill and expand Area and Regional Emergency
Coordinator positions. Finally, until DHS ensures that tasks outlining
agency responsibilities are consistent with national plans and
guidelines and DHS develops a method to adequately track federally
funded research efforts, the United States will lack a coordinated
national approach to protect against agroterrorism, possibly resulting
in gaps or needless duplication of effort. By overcoming these
challenges, the United States will be in a better position to protect
against and respond to a disease outbreak, whether natural or
intentional.
Recommendations for Executive Action:
To address significant and complex challenges that limit the United
States' ability to quickly and effectively respond to a widespread
attack on animal agriculture, we recommend that the Secretary of
Agriculture address the following four challenges in the context of the
agency's overall risk management efforts:
* expedite the review and issuance of the draft rule on USDA's
accreditation process for veterinarians, which would require training
in recognizing foreign animal diseases;
* evaluate the costs and benefits of using rapid diagnostic tools at
the site of an outbreak;
* examine the costs and benefits of developing stockpiles of ready-to-
use vaccines that can be quickly deployed against animal diseases of
primary concern; and:
* simplify the decision-making process for determining if and/or when
to use vaccines to control an outbreak to ensure that rapid decisions
can be made in the event of a terrorist attack.
To address management problems that reduce the effectiveness of
agencies' routine efforts to protect against agroterrorism, we
recommend the following seven actions:
* the Secretaries of Homeland Security and Agriculture work together to
identify the reasons for declining agricultural inspections and to
identify potential areas for improvement;
* the Secretaries of Homeland Security and Agriculture streamline the
flow of information between USDA and DHS agricultural inspectors, and
expedite the integration of the two agencies' databases and information
technology systems at the port level;
* the Secretary of Homeland Security develop a mechanism to promptly
and effectively seek input from key stakeholders on national guidance
that affects their roles in protecting agriculture and responding to an
emergency;
* the Secretaries of Homeland Security, Agriculture, and Health and
Human Services, and the Acting Administrator of the Environmental
Protection Agency compile relevant after-action reports from test
exercises and real-life emergencies and disseminate the reports through
the Homeland Security Information Network that DHS is developing;
* the Secretary of Agriculture develop a strategy to increase the
number of Area and Regional Emergency Coordinator positions so that the
agency faces less difficulty filling these positions and is better able
to assist states in preparing for an agriculture emergency, including a
terrorist attack;
* the Secretary of Homeland Security work to ensure that task lists for
the various agencies and working groups engaged in securing agriculture
are consistent with national plans and guidelines; and:
* the Secretary of Homeland Security develop controls to better
coordinate and track federally funded research efforts with other
agencies to protect against agroterrorism.
Agency Comments and Our Response:
We provided USDA, DHS, HHS, EPA, and DOD with a draft of this report
for their review and comment. We received written comments on the
report and its recommendations from USDA, DHS, and HHS. EPA and DOD
provided minor technical clarifications.
USDA commented that the report provided a number of appropriate and
insightful recommendations. In several instances, USDA said it could
take actions that relate to our recommendations. For example, USDA said
that the department could explore the possibility of speeding up its
process for deciding when to use vaccines and that it will consider
options to cut some of the delay in obtaining ready-to-use vaccines.
The department also raised some concerns regarding various aspects of
our report. For example, as we recommend, USDA noted that there may be
opportunities to use rapid diagnostic tools to help with diagnosis of
animal diseases, but said that the tools need to be validated. Further,
USDA commented that the agency would in all cases still require
confirmation that relies on traditional testing procedures. As stated
in our report, we continue to believe that use of these tools at the
site of an outbreak would help reduce the impact of a terrorist attack
because, among other things, these tools would help prevent
laboratories from becoming overwhelmed with test samples. USDA's
written comments and our detailed responses to their concerns appear in
appendix VI. USDA also provided technical comments that we
incorporated, as appropriate, throughout the report.
DHS generally concurred with the report's recommendations and indicated
that the agency is in the process of taking several corrective actions
addressing two of our recommendations. For example, as we recommend,
DHS is working with USDA to identify the reasons for declining
agriculture inspections and to identify potential areas for
improvement. Regarding our recommendation that DHS and USDA streamline
the flow of information between the two agencies' agricultural
inspectors, DHS stated that it is already working with USDA to enhance
communication; that is, the two agencies are working to finalize the
section in the Memorandum of Agreement governing the sharing of
information. DHS also provided technical comments that we incorporated
as appropriate. DHS's written comments and our detailed responses
appear in appendix VII.
Overall, HHS agreed with the report's recommendations. In commenting on
our recommendation that the agencies compile relevant after-action
reports from test exercises and real-life emergencies and disseminate
the reports through the Homeland Security Information Network that DHS
is developing, HHS officials noted that CDC already has standardized
after-action reporting procedures in place. HHS officials also noted
that another challenge in protecting the nation against agroterrorism
is the shortage of laboratory space to conduct trials for vaccine
development. HHS's written comments appear in appendix VIII. HHS also
provided technical comments that we incorporated, as appropriate,
throughout the report.
We are sending copies of this report to the Secretaries of Agriculture,
Homeland Security, Health and Human Services, and Defense; the Acting
Administrator of the Environmental Protection Agency; and interested
congressional committees. In addition, this report will be available at
no charge on the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions concerning this report, I can
be reached at (202) 512-3841 or [Hyperlink, robinsonr@gao.gov]. Major
contributors to this report are included in appendix IX.
Signed by:
Robert A. Robinson:
Managing Director, Natural Resources and Environment:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
To determine what changes have taken place since September 11, 2001, in
federal agencies' roles and responsibilities to protect against
agroterrorism, we reviewed the relevant laws and presidential
directives in force before and after September 11, 2001. Specifically,
our Office of General Counsel reviewed the Robert T. Stafford Disaster
Relief and Emergency Assistance Act of 1974,[Footnote 86] the
Agriculture Risk Protection Act of 2000, [Footnote 87] the Farm
Security and Rural Investment Act of 2002,[Footnote 88] the Public
Health Security and Bioterrorism Preparedness and Response Act of
2002,[Footnote 89] and the Homeland Security Act of 2002. We also
reviewed presidential directives that define agency roles in
emergencies such as acts of agroterrorism, including Homeland Security
Presidential Directives 5, 7, 8, and 9. Finally, we interviewed
numerous agency officials from the U.S. Department of Agriculture
(USDA), the Department of Homeland Security (DHS), the Department of
Health and Human Services (HHS), the Environmental Protection Agency
(EPA), the Department of Defense (DOD), and the Department of Justice.
To determine what steps the federal government has taken to protect
against agroterrorism, we examined (1) steps taken at the federal
level, (2) federal action to prepare the states, and (3) coordination
with industry. To determine what steps have been taken at the federal
level, we reviewed classified and unclassified agency documents,
including vulnerability assessments conducted by USDA and HHS for
agricultural and food products; the draft of the interim National
Infrastructure Protection Plan and the final version of the National
Response Plan; and lists of interagency working groups and coordinating
committees. We also interviewed agency officials involved in creating
and enforcing U.S. policy concerning agroterrorism, including officials
from USDA's Office of Homeland Security, Animal and Plant Health
Inspection Service (APHIS), Agricultural Research Service, and the
Cooperative State Research Education and Extension Service; DHS'
Information Analysis and Infrastructure Protection directorate,
Emergency Planning and Response directorate, Border and Transportation
Security directorate, Science and Technology directorate, and Office
for Domestic Preparedness; HHS' Food and Drug Administration and
Centers for Disease Control and Prevention; and EPA. In addition, we
contacted USDA's Inspector General and state governments to determine
what prior work had been done in this area. To identify federal actions
to strengthen surveillance at the borders we visited or spoke with
officials at three maritime ports, three airports, one border-crossing,
and one international mail facility, where we interviewed inspectors in
DHS' Customs and Border Protection, USDA's Plant Protection and
Quarantine, and USDA's Veterinary Services. We also reviewed documents
obtained from officials and inspectors, including samples of inspection
records, training schedules, as well as interagency agreements that
clarify agency roles and responsibilities, such as the Memorandum of
Agreement between DHS and USDA.[Footnote 90] Finally, we spoke with
officials at DHS' Customs and Border Protection headquarters in
Washington, D.C. To assess the federal government's coordination of its
efforts to protect against agroterrorism, we considered the Office of
Management and Budget Circular A-123, Management Accountability and
Control,[Footnote 91] and the standards in GAO's Internal Control:
Standards for Internal Control in the Federal Government.[Footnote 92]
To determine how the federal government is helping states to protect
against agroterrorism, we used structured interviews of state and
federal officials in three major agriculture states we visited between
July and October 2004. We selected these states in part because of
their status as the top three producers of agricultural commodities
sold before processing, according to data that we obtained from USDA's
Economic Research Service. Additionally, prior to our visit to the
major agricultural states, we visited officials in another state to
test our structured interview methodology. In these four states, we
interviewed officials from state agencies overseeing agriculture,
homeland security, and emergency services; personnel from federal and
state diagnostic laboratory networks and research centers; and
officials from the regional or state offices of USDA and the Food and
Drug Administration. In addition to the three top producing agriculture
states, we had selected a fourth state to visit to get a wider
geographic distribution, but due to severe weather during the fall of
2004, we were only able to interview officials from the state
department of agriculture by phone. We also reviewed documentation from
state and federal officials, including state agricultural emergency
response plans, after-action reports from disease outbreaks and test
exercises, and federal guidance to the states.
To determine how the federal government is coordinating with industry
to protect against agroterrorism, we reviewed federal guidance to
industry. We also interviewed officials from organizations representing
agriculture interests in Washington D.C., and officials from DHS, USDA,
and HHS who are involved in coordinating with industry. Finally, we
attended coordinating meetings in Washington, D.C., involving
representatives from the food and agriculture sector and federal
agencies.
To determine what challenges remain to protect against agroterrorism,
we used knowledge gained in addressing our other objectives. Using
structured interviews, we consulted with nongovernment experts in the
fields of agricultural security and counterterrorism. We selected our
experts based on their professional and research qualifications and
experience in the field of agroterrorism. We then analyzed the content
of the experts' responses to identify common themes. Finally, we
analyzed the content of relevant peer-reviewed journal articles to
identify common themes.
We conducted our work from February 2004 through January 2005 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: List of Experts GAO Consulted and Summary of Observations:
This appendix provides the names and affiliations of nongovernment
experts from academia and other research organizations that we
interviewed during our work and summarizes key observations they made.
The information presented in this appendix does not reflect absolute
consensus of opinion among the experts on each topic; however, it
summarizes their observations on issues where many of the experts held
similar views. The information contained in this appendix should not be
considered to be the views of GAO.
List of Experts Interviewed:
* Roger Breeze, B.V.M.S., Ph.D., M.R.C.V.S., CEO, Centaur Science
Group, Former Director, Plum Island Animal Disease Center;[Footnote 93]
* Corrie Brown, D.V.M., Ph.D., Professor and Coordinator of
International Activities, Department of Veterinary Medicine, University
of Georgia;[Footnote 94]
* Rocco Casagrande, Ph.D. in Biology, Director, The Center for Homeland
Security, Abt Associates;
* Peter Chalk, Ph.D. in Political Science, Security and Political
Analyst, the Rand Corporation, Santa Monica, California;
* R. James Cook, Ph.D., Interim Dean, College of Agricultural, Human,
and Natural Resource Sciences, Washington State University, Pullman,
Washington;
* Radford Davis, D.V.M., M.P.H., Assistant Professor of Public Health,
College of Veterinary Medicine, Department of Veterinary Microbiology
and Preventive Medicine, Iowa State University;[Footnote 95]
* Jacqueline Fletcher, Ph.D., Past President of the America
Phytopathological Society, Currently Sarkeys Distinguished Professor,
Department of Entomology and Plant Pathology, Oklahoma State University;
* David R. Franz, D.V.M., Ph.D., Director, National Agricultural
Biosecurity Center, Kansas State University;
* Brian Jenkins, Senior Advisor to the President of the Rand
Corporation, Member of the Comptroller General of the United States'
Advisory Board;
* Harley Moon, D.V.M., Ph.D., Chair, National Research Council
Committee on Biological Threats to Agricultural Plants and Animals,
Veterinary Medical Research Institute, Iowa State University;
* James A. Roth, D.V.M., Ph.D., Distinguished Professor of Immunology,
Assistant Dean, International Programs and Public Policy; Director,
Center for Food Security and Public Health, College of Veterinary
Medicine, Iowa State University;
* John L. Sherwood, Ph.D., Chair, American Phytopathological Society
Public Policy Board, Professor and Department Head, Department of Plant
Pathology, University of Georgia;
* Mark C. Thurmond, D.V.M., Ph.D., Professor, Department of Medicine
and Epidemiology, University of California, Davis;
* Alfonso Torres, D.V.M., MS, Ph.D, Executive Director, New York State
Animal Health Diagnostic Laboratory, and Associate Dean for Veterinary
Public Policy, College of Veterinary Medicine, Cornell
University;[Footnote 96] and:
* Mark Wheelis, Senior Lecturer in Microbiology, University of
California.
Summary of Experts' Observations:
We conducted structured interviews with nongovernment experts in the
fields of animal and plant diseases, terrorism, bioterrorism, and
agroterrorism. Before conducting our interviews, we reviewed the
experts' relevant studies and publications and provided them with a
list of questions. We sought their views on a range of topics,
including the vulnerability of U.S. agriculture, government agencies'
roles and responsibilities, and agencies' efforts to protect against
agroterrorism.
Vulnerability of U.S. Agriculture:
* In general, experts agree that U.S. agriculture is vulnerable to
agroterrorism because of the relative ease with which highly contagious
diseases can be introduced in livestock and crops. An agroterrorism
event could not only cause severe economic losses to farmers and rural
communities, it could also halt or slow down international trade, and
negatively impact consumer confidence in the government's ability to
ensure the safety of our food supply. For these reasons, many experts
believe that agriculture is an attractive target for terrorists. Some
experts note that the methods for containing the spread of highly
infectious animal diseases--the highly visible and costly slaughter,
incineration, and/or burial of large numbers of animals--creates the
incentive for terrorists to attack.
* Most experts note that livestock presents a more attractive target
for terrorists than crops, although both are vulnerable. The biggest
threat at the farm level would be the deliberate introduction of FMD, a
highly contagious animal disease that has been eradicated in the United
States. Highly contagious animal diseases can spread more quickly than
plant diseases, and the concentration of animals in feedlots and
livestock markets would contribute to the rapid spread of infection.
Experts remarked that an attack of this sort would be cheap, requires
no technical expertise, and would not harm the perpetrator. Some
experts remark that transportation of live cattle, hogs, and poultry,
across the country further enables diseases to spread quickly and
easily over large areas. On the other hand, some of the experts state
that plant diseases often need particular weather and environmental
conditions for them to take hold and flourish, making them a less
attractive target.
* Most experts identify the same group of animal diseases as the most
likely to be used against agriculture--those include FMD, avian
influenza, classical and African swine fevers, and exotic Newcastle
disease. However, there is wide consensus among experts that FMD poses
the highest risk because it is highly contagious, it results in the
need to destroy large numbers of animals which, in turn, generates a
great deal of media attention, and can inflict severe economic losses.
Some of the experts also raise concerns about zoonotic diseases such as
Rift Valley fever, Nipah Virus, and highly pathogenic avian influenza,
but not all experts agree that zoonotic diseases pose a significant
threat. On the plant side, some experts identify soybean rust as the
disease of most concern because it is easy to introduce and can spread
by wind-borne spores. Another expert raises concerns about the threat
of contamination with genetically engineered seeds and observes that it
would only take one or two seeds to contaminate an entire cargo of
product.
Government Agencies' Roles and Responsibilities:
* Some experts we interviewed agree that the federal government is
undertaking significant initiatives to protect against agroterrorism.
They have generally favorable comments regarding the role that DHS
plays in protecting against agroterrorism. Some see the emergence of
DHS as a coordinator for agroterrorism activities within the federal
government as a major change that signals the importance of the
agriculture sector. Some experts also indicate that there was initial
confusion about DHS' role and that, because the agency is still very
new, their role is still evolving.
* Many experts identify the lack of communication at the federal level
as their biggest concern and observe that within the federal government
there is no clear understanding of the initiatives that are in place to
protect against an attack and that there appears to be a duplication of
efforts. Some experts believe that there is little coordination between
federal and state agencies, or between states, and that federal
agencies are not sufficiently sharing information with state and local
officials. Also, there is insufficient coordination and communication
with industry groups.
Agencies' Efforts to Protect against Agroterrorism:
* In terms of planning efforts, several experts indicated that the
development of a National Response Plan and associated Emergency
Support Functions is exactly what was needed. They believe that it is
important to include the states' input in the preparation of those
documents since the states will be the first responders. Several
experts state that preparing a response plan for dealing with an
unintentional outbreak would also be useful in preparing for an
agroterrorism event. Many experts note that test exercises can help
identify potential problems in response plans that may arise in
application.
* Many experts agree that focusing the majority of efforts on
preventing agroterrorism is not the answer because it is impossible to
prevent all disease introductions, whether accidental or intentional.
Instead, several experts note that agencies need to focus more on rapid
detection and identification of diseases and in establishing quick
response mechanisms.
* Most experts agree that USDA's creation of the National Animal Health
Laboratory Network and the National Plant Diagnostic Network is a
positive development. However, some experts disagree as to whether the
networks can provide sufficient surge capacity or if they need to be
expanded.
* Some experts recommend additional research and development to create
FMD vaccines that contain markers to differentiate animals that are
merely vaccinated from those that are infected.
* While some experts agree that training of veterinarians in foreign
animal diseases is inadequate, others note that actual training and
awareness of the importance of such training has improved. Some experts
explain that foreign animal disease training is not required in all
veterinary schools. This training is also not a prerequisite to become
a USDA-accredited veterinarian. On the plant side, some experts note
that the United States does not have an adequate number of people
trained in plant pathology. Many experts agree that more federal
funding should be dedicated to plant pathology research and job
creation.
* Some experts recommend using rapid diagnostic tools at the site of an
outbreak, rather than shipping samples to USDA reference laboratories.
They state that this would save valuable time in containing diseases,
whether naturally occurring or resulting from agroterrorism. The use of
these rapid tools on site would also help prevent laboratories from
becoming overwhelmed with samples, particularly if a terrorist attack
involved the multi-focal introduction of a disease or if diseases were
repeatedly introduced over long periods of time.
[End of section]
Appendix III: Animal and Plant Diseases that Pose a Severe Threat to
Agriculture:
Table 1: List of Select Animal Diseases Identified by USDA Pursuant to
the Bioterrorism Act of 2002 as a Severe Threat to the Livestock
Industry and Human Health:
Diseases and agents: Avian Influenza (highly pathogenic);
Animals affected: Chicken, turkey, wild birds, water fowl;
Route of transmission: Body fluids; aerosols; fomites;
Availability of vaccine: Yes;
Can affect humans: Yes.
Diseases and agents: Exotic Newcastle Disease;
Animals affected: Poultry, other avian species;
Route of transmission: Direct contact with body fluids; aerosols; feces
or respiratory droplets;
Availability of vaccine: Yes;
Can affect humans: Yes.
Diseases and agents: Nipah;
Animals affected: Pigs, horses, cats, dogs;
Route of transmission: Close direct contact with contaminated tissue or
body fluids;
Availability of vaccine: No;
Can affect humans: Yes.
Diseases and agents: Hendra;
Animals affected: Horses, cats, guinea pigs;
Route of transmission: Direct contact; oranasal; ingestion of
contaminated material; fruit bats;
Availability of vaccine: No;
Can affect humans: Yes.
Diseases and agents: Eastern Equine Encephalitis;
Animals affected: Horses;
Route of transmission: Vectors infected with virus;
Availability of vaccine: Yes;
Can affect humans: Yes.
Diseases and agents: Venezuelan Equine Encephalomyelitis;
Animals affected: All equine, bats, birds, rodents;
Route of transmission: Mosquito (vectors) infected with virus;
Availability of vaccine: Yes;
Can affect humans: Yes.
Diseases and agents: Foot and Mouth Disease;
Animals affected: All cloven hoofed animals including cattle, sheep,
goats, pigs;
Route of transmission: Aerosol; direct contact; ingestion; fomites;
Availability of vaccine: Yes;
Can affect humans: Yes, but rarely infects humans.
Diseases and agents: Rift Valley Fever;
Animals affected: Cattle, sheep, goats, dogs, cats, camels, monkeys;
Route of transmission: Insect vectors (mosquitoes); direct contact with
blood or tissue;
Availability of vaccine: Yes;
Can affect humans: Yes.
Diseases and agents: Rinderpest;
Animals affected: Cattle, sheep, goats;
Route of transmission: Direct or close contact with body fluids;
Availability of vaccine: Yes;
Can affect humans: No.
Diseases and agents: African Swine Fever;
Animals affected: Domestic and wild pigs; wart hogs;
Route of transmission: Direct contact with body fluids, especially
blood; fomites; tick vectors;
Availability of vaccine: No;
Can affect humans: No.
Diseases and agents: Classical Swine Fever;
Animals affected: Domestic pigs;
Route of transmission: Ingestion (uncooked garbage); fomites; aerosol;
direct contact;
Availability of vaccine: Yes;
Can affect humans: No.
Sources: GAO analysis and 9 CFR §121.3.
Note: Other animal diseases identified by the Bioterrorism Act of 2002
that have the potential to pose a severe threat to livestock and human
health include bacillus anthracis, brucella abortusm, brucella
melitensis, brucella suis, burkholderia mallei, burkholderia
pseudomallei, clostridium botulinum, coccidioides immitis, francisella
tularensis, botulinum neurotoxins, clostridium perfringens epsilon
toxin, shigatoxin, staphylococcal enterotoxins, T-2 toxin, African
horsesickness, contagious bovine pleuropneumonia, peste des petits
ruminants, vesicular stomatitis virus, swine vesicular disease virus,
lumpyskin disease virus, bluetongue virus, and sheep pox and goat pox.
[End of table]
Table 2: List of All Plant Diseases Identified by USDA as Severe
Threats to Plants Pursuant to the Bioterrorism Act of 2002:
Diseases and agents: Soybean Rust;
Plants affected: Soybeans;
Route of transmission: Wind-borne spores.
Diseases and agents: Southern Bacteria Wilt;
Plants affected: Potatoes, geraniums, tomatoes, peppers, eggplants,
beans, bittergourds, beets, and tobacco;
Route of transmission: Soil, contaminated water, equipment.
Diseases and agents: Plum Pox;
Plants affected: Peaches, plums, apricots, almonds;
Route of transmission: Grafting from infected trees or aphid vectors.
Diseases and agents: Downy Mildew of Corn;
Plants affected: Sugarcane, corn;
Route of transmission: Wind-borne, seedborne, infected soil.
Diseases and agents: Brown Stripe Downy Mildew of Maize;
Plants affected: Corn;
Route of transmission: Wind, rain, water, and physical contact between
plants.
Diseases and agents: Synchytrium Endobioticum (potato wart);
Plants affected: Potatoes;
Route of transmission: Soil, on tubers grown in infected soil,
machinery and implements used in potato cultivation, on footwear and
manure from animals that have fed on infected tuber.
Diseases and agents: Bacterial Leaf Streak of Rice;
Plants affected: Rice;
Route of transmission: Wind-borne, seeds, infected soil and water,
irrigation, rain.
Diseases and agents: Citrus Greening;
Plants affected: Citrus fruit trees;
Route of transmission: Insect vector, grafting from infected trees.
Diseases and agents: Pierce's Disease;
Plants affected: Grapes, almonds, peaches, pears, citrus, alfalfa,
coffee, oleander, oak, sycamore, maple, elm, mulberry, ornamental
grasses;
Route of transmission: Insect vector.
Sources: GAO analysis and 7 CFR §331.3.
[End of table]
[End of section]
Appendix IV: U.S. Concentration of Cattle, Chicken, and Corn Production
in 2002:
Figure 6: Top Cattle-Producing States in 2002:
[See PDF for image]
Note: Cattle production consists of milk and beef cattle.
[End of figure]
Figure 7: Top Chicken-Producing States in 2002:
[See PDF for image]
Note: Chicken production consists of broilers and layers. Two states
did not disclose their information.
[End of figure]
Figure 8: Top Corn-Producing States in 2002:
[See PDF for image]
Note: One state did not produce corn.
[End of figure]
[End of section]
Appendix V: Additional Information on National and Agency-Specific
Steps Taken to Protect against Agroterrorism:
National Infrastructure Protection Plan:
DHS worked jointly with other federal agencies to develop the interim
National Infrastructure Protection Plan, a standardized plan to
safeguard the nation's critical infrastructure, including agriculture,
before a terrorist attack occurs. USDA and HHS, in consultation with
DHS, developed sector-specific plans for agriculture and food, which
were incorporated into the interim National Infrastructure Protection
Plan. These sector-specific plans outline activities including:
* Identifying the sector's assets;
* Identifying and assessing the vulnerabilities and interdependencies
among assets, and analyzing potential risks based on threats and
consequences;
* Prioritizing assets based on an analysis and normalization of
vulnerability data;
* Developing sustainable programs to protect assets and implementing
these programs when necessary; and:
* Using metrics to measure and communicate the effectiveness of the
sector-specific plans.
The National Infrastructure Protection Plan outlines roles and
responsibilities for federal, state, and local governments to safeguard
agriculture. The plan includes a description of coordination activities
to reduce the vulnerability of critical infrastructures. According to
DHS officials, the department--along with other federal departments and
agencies--will work with state and local governments and the private
sector to further refine stakeholder roles and responsibilities in
order to implement the National Infrastructure Protection Plan. In
addition, these entities will work together to implement sector-
specific plans that will support the National Infrastructure Protection
Plan. The results of these implementation efforts will be reflected in
the next version of the National Infrastructure Protection Plan, which
according to DHS officials, will be issued within 270 days of issuance
of the current interim plan.
National Response Plan:
In addition to the National Infrastructure Protection Plan, DHS
coordinated the integration of various interagency and agency-specific
incident management plans into a single all-hazard National Response
Plan that would be used in the event of a terrorist attack. The
National Response Plan includes appendixes, known as Emergency Support
Functions, that detail the responsibilities of federal agencies for
coordinating resources during national emergencies. One of the these
appendixes, Emergency Support Function-11, outlines the roles and
responsibilities of local, state, and federal responders in addressing
the national response to outbreaks or other emergencies in the food and
agriculture sector. For example, Emergency Support Function-11:
* Assigns USDA, through APHIS, as the lead agency for responding to a
disease outbreak, and outlines USDA's role in supporting such
activities as detection, control, and eradication;
* Assigns state agencies, along with USDA's Area Veterinarian-in-
Charge, the task of establishing a Joint Operations Center, which will
serve as the focal point for coordinating the disease management and
decision-making process; and:
* Assigns local or county governments with the task of activating an
Emergency Operations Center to provide a local base of operations.
National Incident Management System:
As directed by HSPD-5, DHS is overseeing the adoption of a National
Incident Management System by federal and state agencies that will be
used in an agroterrorism event. According to HSPD-5, the National
Incident Management System, released in March 2004, is intended to
provide a consistent nationwide approach for federal, state, and local
governments to work effectively and efficiently together to prepare
for, respond to, and recover from domestic incidents, regardless of
cause, size, and complexity. The National Incident Management System is
a management framework rather than a plan. It is intended to ensure
coordinated responses to disasters and terrorist attacks by outlining
common standards for preparedness training, exercises, and
certification. A key component of the National Incident Management
System is the Incident Command System, which is designed to coordinate
the communications, personnel, and procedures of different agencies and
levels of government within a common organizational structure during an
emergency. The Incident Command System, which was initially developed
by the USDA Forest Service and the state of California to help fight
forest fires, has already been adopted by a number of agencies and
state governments. According to USDA and state officials, the Incident
Command System has already been used in two natural animal disease
outbreaks--an outbreak of low-pathogenic avian influenza among turkeys
in Virginia and an exotic Newcastle disease outbreak among chickens in
California.
Test Exercises:
Since 2001, exercises have simulated animal and plant disease outbreaks
and have tested aspects of the new National Incident Management System
protocols and the latest federal and state emergency response plans.
These exercises are in line with HSPD-9's goal of ensuring that the
combined federal, state, and local response capabilities are adequate
to respond quickly and effectively to a terrorist attack. For example,
in July 2004, Kansas State University sponsored "Exercise High Plains
Guardian," a 2-day exercise to test the ability of federal and state
military and civilian first responders to cooperate in responding to an
outbreak of FMD. The scenario addressed quarantines, highway closings,
elapsed time waiting for federal lab results to confirm the suspicions
of state veterinarians, and, after positive confirmation, massive
euthanizing and carcass disposal efforts. As a result of these
exercises, federal, state, and industry officials told us that in
general, the exercises have been useful in allowing players to better
understand their roles and responsibilities in a real-life event,
uncover shortfalls they had not necessarily foreseen in planning, and
test solutions. For example, the 2002 FMD exercise "Crimson Sky" made
it clear that USDA would be the lead federal department in providing
policy and direction for detecting, controlling, and eradicating an
animal disease outbreak. At the same time, the exercise indicated the
importance of interdependence between federal, state, and industry
stakeholders in carrying out emergency management and logistical
response functions. Furthermore, the exercise raised key issues
concerning information-sharing between these players and the public,
stopping and resuming movement of animals, mobilizing federal
resources, indemnity, vaccination of herds, and decontamination policy.
Vulnerability Assessments:
FDA's initial vulnerability assessment utilized an analytical framework
called Operational Risk Management that considered both the severity of
the public health impact and the likelihood of such an event taking
place. FDA incorporated threat information received from the
intelligence community. To validate the findings, FDA contracted with
the Institute of Food Technologists to conduct a review of the initial
assessment and provide a critique of its application to food security.
This review validated FDA's vulnerability assessment and provided
additional information on the public health consequences of a range of
scenarios involving various products, agents, and processes. FDA also
contracted with Battelle Memorial Institute to conduct a "Food and
Cosmetics, Chemical, Biological, and Radiological Threat Assessment."
This assessment provided another decision-making tool and validated
previous findings.
FDA updated and refined these assessments using a process developed by
DOD for use in assessing the vulnerabilities of military targets. This
assessment tool is known as "CARVER + Shock" and takes into
consideration information such as accessibility, vulnerability, and
shock (the shock value of an attack on a target due to the heinous
nature of terrorist events).[Footnote 97] FDA plans to use the results
of these updated assessments to develop technology interventions and
countermeasures, identify research needs, and provide guidance to the
private sector. Similarly, USDA is using the CARVER + Shock tool for
assessing vulnerabilities in USDA-regulated products, based on subject
matter experts and intelligence information. USDA was still developing
the assessment at the time of our review.
Interagency Working Groups:
In addition to the Government Coordinating Council and the Food and
Agriculture Sector Council, federal agencies have established a number
of interagency working groups. One such interagency working group
composed of DHS, USDA, and CDC, is overseeing the development of a
national disease surveillance system. This system, when established,
will allow DHS to incorporate information on disease outbreaks from
other agencies to determine whether an outbreak is natural or
intentional. USDA, with support from DHS and EPA, is leading another
working group that is preparing a plant disease recovery system that is
intended to allow U.S. crop production to quickly recover from an
attack. A final example of one of the interagency working groups is one
led by EPA and supported by USDA, HHS, DHS, and DOD that has laid out
interagency roles in supporting state and local governments in
decontamination and disposal of infected plants and diseased animals
following a major disease outbreak.
Research Efforts:
DHS, USDA, and other agencies are funding research to protect
agriculture. Of note, DHS has established two Centers of Excellence
that, along with partner institutions, will oversee research to protect
agriculture and the food supply. DHS is providing $15 million in
funding to the University of Minnesota to oversee research into post-
harvest food protection and $18 million to Texas A&M University to
oversee research into diseases that affect food animals. This funding
is for a 3-year period of time. For example, the Center of Excellence
at Texas A&M will support efforts to model the outbreak of FMD, which
will allow responders to develop accurate plans to counter an outbreak.
The center will also support research into the development of real-time
diagnostic equipment and vaccines against foreign animal and zoonotic
diseases. Furthermore, the center will develop training curricula for
first responders, industry officials, and production workers to
increase response capability and awareness of possible threats. USDA is
also funding efforts to increase agricultural security through the ARS,
the research arm of USDA, and the Cooperative State Research Education
and Extension Service, which supports research at universities and
other institutions. USDA funding supported research at facilities such
as the National Agricultural Biosecurity Center at Kansas State
University, which will conduct projects including the evaluation of
contaminated carcass disposal efforts, assessments of animal and plant
disease test exercises, and the analysis of pathways by which foreign
animal and plant disease can enter the United States. Finally, other
agencies are supporting research into agricultural security. For
example, CDC provided $1 million per year to Iowa State University to
fund a center for food security and public health. This center will
support efforts such as "train the trainer" programs to educate
veterinarians in foreign animal diseases.
National Animal Health Emergency Management System:
USDA's National Animal Health Emergency Management System incorporates
a nationwide network of state and federal personnel in each state, a
National Animal Health Laboratory Network, and Area Emergency
Coordinators operating within the National Response Plan and the
National Incident Management System. The system also includes a
steering committee consisting of representatives of the animal health
community and other stakeholders that provides a means of communication
and coordination on issues of emergency management and response. The
central principles of the National Animal Health Emergency Management
System are provided in a single set of written guidelines that
consolidate strategy, operations, facility management, and
administrative procedures.
[End of section]
Appendix VI: Comments from the U.S. Department of Agriculture:
USDA:
United States Department of Agriculture:
Animal and Plant Health Inspection Service:
Marketing and Regulatory Programs:
Mr. Robert A. Robinson, Managing Director:
Natural Resources and Environment:
United States Government Accountability Office:
Washington, DC 20548:
Dear Mr. Robinson:
Washington, DC 20250:
The U.S. Department of Agriculture (USDA) has reviewed the Government
Accountability Office's Draft Report, "Homeland Security: Much is Being
Done to Protect Agriculture from a Terrorist Attack, but Important
Challenges Remain" (GAO 05-214). We found that the report provided a
number of insightful and appropriate recommendations. We appreciate
this opportunity to comment on your findings.
Rapid Diagnostic Testing:
The current process and procedures for investigating a suspected animal
health event include several layers of precautionary actions. These
actions are embedded in Animal and Plant Health Inspection Service
(APHIS), Veterinary Services (VS) policies and requirements to protect
the industry and minimize losses due to international and interstate
trade restrictions.
The first precaution concerns VS "front lines" defense. When a
veterinary foreign animal disease diagnostician (FADD) is sent to a
premises to investigate a situation, that person has authority from the
State to act immediately upon his/her findings. If the FADD suspects
that a foreign animal disease (FAD) is present in the livestock on the
premises, a State hold order or quarantine is placed on all movement of
livestock and the producer is required to provide additional
information on his/her overall operation production system. These
actions are necessary to prevent movement of the disease agent through
movement off the premises of livestock, feed, or other materials and
support immediate biosecurity and containment of the disease agent.
In addition, VS works with its Federal and State counterparts to
minimize the time from when an FAD is suspected to the point of disease
confirmation through laboratory testing. Within this system, the
disease is immediately contained and thus, the response at the local
level is progressing while the samples are in route to the laboratory
for confirmatory testing. Employing methods of rapid assay detection
may be useful for confirming suspicions but would be inadequate for
release of hold orders or quarantines and would not affect control
strategies already being employed.
The National Veterinary Services Laboratories (NVSL), which includes
the Foreign Animal Disease Diagnostic Laboratory (FADDL), is officially
responsible for testing and confirming foreign animal disease. Those
labs have the expertise and resources to make informed diagnoses.
Furthermore, USDA performs such confirmatory testing to eliminate the
possibility of a false positive, which could have serious repercussions
on producers and the economy. During a large-scale animal health event
covering multiple locations across several States, VS does deploy rapid
disease diagnostic tools directly to the affected site to efficiently
identify infected livestock.
For example, in two recent outbreaks, exotic Newcastle disease (END)
samples were rapidly tested by real time PCR in California's San
Bernardino Laboratory, and avian influenza (AI) samples were tested in
Harrisonburg, Virginia. APHIS relied on its network of local
laboratories in these cases; because these laboratories were located
closer to the outbreak, shipping samples there saved valuable
diagnostic time. NVSL continued to test samples during both outbreaks,
but the bulk of the rapid tests (PCR for AI and END, and DirectigenR
for Al) were performed locally. Even if rapid pen-side tests were
developed, validated, and used by FADDs to test for FAD suspicious
animals on routine investigations (before an outbreak was confirmed),
confirmatory testing would still be necessary as these tests are
designed to be sensitive and not specific. This would occur for several
reasons including economics, virus isolation and typing, and trade
relations. USDA believes that caution should be used in spending public
funds and that the particular virus and strain or type of virus must be
known before expending resources. Trading partners including other
States will impose restrictions on the infected areas depending on the
type of virus or organism present.
The report states that "USDA developed state-of-the-art, rapid
diagnostic tools to detect FMD, classical swine fever, African swine
fever, Rinderpest, avian influenza, and Newcastle disease... designed
to yield results in less than an hour and ... intended to be used
outside of specialized laboratories at the site of an outbreak." While
proof-of-concept tools have been developed, it is important to note
that these tools have not been validated to the extent necessary to be
used to identify and confirm an FAD. Before a definitive diagnosis is
made, care must be taken to rule out diseases with similar clinical
signs or those with conserved genomic or protein sequences that might
result in a false-positive result. Therefore, initial diagnosis must be
confirmed using well-validated test procedures and must be interpreted
by trained and experienced diagnosticians, especially when there are
enormous economic and trade consequences to the results.
Then, once the initial diagnosis of an infectious FAD is confirmed,
there may be opportunities to use validated rapid diagnostic tools to
evaluate herd health either at the facility (farm) or at a near-by
laboratory. For any highly-infectious FAD, it may be unrealistic to
assume that any tool would be used to determine that some animals in a
herd could be diagnosed as infected and others spared if the results
were negative.
No tool is sensitive enough to detect all exposed animals prior to the
replication of an infectious agent in an animal; therefore, in an
outbreak, once the infectious agent is detected in a herd, the entire
herd is known to be exposed. Continuous repeat testing of individual
animals is a poor use of resources for controlling outbreaks. In
addition, the report suggests that use of the rapid diagnostic tools
would help identify the index case "definitively in less than an hour."
It is unlikely that the rapid diagnostic tools would be used to test
animals with no known risk factors, no clinical signs, and no known
exposure to FAD agents. Furthermore, current rapid diagnostic tools
primarily utilize nucleic- acid amplification and detection methods. VS
continues to explore newer technologies (such as chip technologies)
that could have even greater potential for improving rapid diagnostic
capabilities.
Additionally, the report's assumption that an outbreak can be
effectively countered by vaccine use is misleading. There are a limited
number of diseases that can be "treated" by using vaccines during an
outbreak. Vaccines may have some use in limiting disease spread when
they are used in areas adjacent to the outbreak or in populations
likely to become exposed or when used to decrease shedding of an agent
from infected animals. But even then, most vaccines will not prevent
infection (since vaccines are based on an immune response, it can take
approximately 10 days for maximum efficacy) and can hinder surveillance
during an outbreak. While APHIS will continue its efforts to develop
the National Veterinary Stockpile (NVS), the report incorrectly implies
that having a stockpile of ready-to-use vaccines translates to the
quick control of any outbreak. Also, since vaccines are specific to
variations of strains and have a shelf-life of approximately 18 months,
it would not be cost-effective to have a continuous resupply of every
possible permutation of each disease of concern. See below for more
information on the Stockpile strategy.
In the case of foot-and-mouth disease (FMD), having vaccine stocks
available in 24 hours is likely prudent; however, as the report also
points out, the vaccine use decision tree is complex. While APHIS can
explore the possibility of designing a more rapid decision making
process, the report does not mention the amount of time it would take
to select, deploy, equip, and direct vaccination crews to administer
vaccine in a manner that would be advantageous to disease eradication.
In fact, hastily applied vaccination programs could prove detrimental.
For example, the "Eradication of Exotic Newcastle Disease in Southern
California 1971-74" report concludes "in the massive vaccination
program, it also appeared that increased activity and traffic of
vaccinators among the poultry ranches contributed to the disease's
rapid spread." An ill-conceived or mismanaged FMD vaccination program
could presumably be equally damaging in that by encouraging
vaccination, FMD virus could spread more easily from farm to farm.
Before a full scale vaccination program could be effected, it is likely
that several days or more might pass.
One area not addressed in the above section of the report is the need
to develop marker vaccines. Since the ability to differentiate
vaccinates from animals infected with live agents has a large impact on
trade, a discussion of the value of marker vaccines to be used for at-
risk animals is needed. Marker vaccines would provide the ability to
differentiate vaccinated animals from infected ones. Such vaccines may
be used more strategically in control and eradication efforts and to
facilitate movement of animals.
National Veterinary Stockpile:
USDA will use the NVS to consider options to cut some of the time delay
for obtaining finished final "ready-to-use" vaccine product. USDA's
goal is for the NVS to be one component of an overall response planning
and recovery effort to provide the best possible protection against an
attack on our agriculture and food system. This goal will be
accomplished through the NVS Steering Committee which serves as the
recommending body that determines what is contained in the NVS (and
what constitutes sufficient amounts of which products and appropriate
time for their deployment) as stipulated in the Response Planning and
Recovery Section of HSPD-9: "...animal vaccine, antiviral, or
therapeutic products to appropriately respond to the most damaging
animal diseases affecting human health and the economy and that will be
capable of deployment within 24 hours of an outbreak. The NVS will
leverage where appropriate the mechanisms and infrastructure that have
been developed for the management, storage, and distribution of the
Strategic National Stockpile."
The mission of the NVS Steering Committee is to ensure that decisions
regarding the composition, inventory, storage, deployment, use, and
staffing of the NVS are based on the most current threat assessments,
the most rigorous science available, the best predictive modeling
possible, and the best expert advice available.
The NVS Steering Committee is chaired by VS' Associate Deputy
Administrator for Emergency Management and Diagnostics. The Steering
Committee is composed of voting members from these Departments and
Agencies (USDA, Department of Homeland Security, the Environmental
Protection Agency, and the Department of Health and Human Services,
Centers for Disease Control). The Steering Committee also has voting
representation from the U.S. Food and Drug Administration (FDA) which
has jurisdiction over products which may be contained in the NVS, and
from the Department of Defense (DOD), which has numerous experts on
logistical issues of managing and deploying the NVS to mitigate damage
from biological, chemical, nuclear, and explosive weapons.
Additional non-voting ex-officio representatives from CDC, FDA, DOD or
other agencies may attend meetings of the Committee to offer
information, observations, and comments. Non-voting ex-officio
representatives from the Armed Forces Medical Intelligence Center, the
Central Intelligence Agency, and the Federal Bureau of Investigation
may be invited to provide current assessments of terrorist risks that
may affect the composition of the NVS. There will also be a non-voting
liaison representative from the National Institutes of Health for the
Bioshield initiative and Lawrence Livermore Biodefense Knowledge
Center. Membership on the Committee may be expanded, as deemed
necessary for the Committee to effectively carry out its functions, by
VS' Deputy Administrator. All members of the Committee will need to
maintain a security clearance at the Secret Level or greater. This
Steering Committee was formed in late 2004.
Veterinary Accreditation and FAD Training:
The information in the section on veterinary training should be
clarified. The document incorrectly assumes that veterinary students
who do not receive a specific course on FADs receive no training on the
subject at all. Moreover, the quotation from the Wenzel study is
misleading. All relevant disease information is covered in the
veterinary curriculum; however, this information is not presented in
one FAD course. All students must take instruction in infectious
diseases and in pathology (during which instruction, FADs are covered).
Additionally, each year since 1990, APHIS has run the Smith-Kilborne
Program on foreign animal diseases offered to one student in each U.S.
veterinary school. Each participant is expected to present information
from the course:
to his or her classmates. Furthermore, APHIS has worked to develop web-
and CD-ROM-based training, and worked with veterinary schools on
curriculum development.
The requirement that an accredited veterinarian is licensed ensures
that personnel have received this basic training. USDA is working to
update the Veterinary Accreditation system to emphasize continuing
education. APHIS is developing an information system to streamline the
accreditation of veterinarians, which will allow them to apply and
maintain accreditation as well as receive credit for FAD and emergency
response training.
In fact, USDA already has a cadre of certified private veterinary
practitioners who partner with APHIS to report any suspected FAD cases
to Federal officials. These surveillance efforts are further augmented
by the work of 450 specially trained animal disease diagnosticians from
State, Federal, and military ranks who actively search for FMD and
other FADs across the country. USDA continues to train an additional
100 FADDs annually. These FADDs respond to calls from the general
public, private practitioners, and animal disease diagnostics
laboratories to evaluate any disease recognized as outside the norm for
any reason. However, USDA realizes that additional training is needed.
Specifically, APHIS is seeking to strengthen its presence in veterinary
colleges to provide information on various aspects of regulatory
medicine. APHIS is also working to increase the visibility of public
practice careers making veterinary students and veterinarians aware of
public service career potential. These efforts will increase the number
of veterinarians entering public service.
National Animal Health Laboratory Network:
USDA will integrate information from the laboratory networks by mid-
2005 (though the laboratories themselves will not be integrated by that
time). USDA leads the development of a Memorandum of Agreement (MOA)
for an Integrated Consortium of Laboratory Networks (ICLN) which was
drafted in late 2004. USDA, Departments of Homeland Security, State,
Defense, Justice, Interior, Energy and Human Health Services, and the
Environmental Protection Agency are parties to the agreement.
The MOA provides a framework for the Federal government to work
collaboratively to provide timely, high quality, and interpretable
results for early detection and effective consequence management of
acts of terrorism and other events requiring an integrated laboratory
response. The ICLN will provide surge capacity capabilities for all
hazard incidents that overwhelm existing laboratory systems within
individual Departments.
Once again, I appreciate the opportunity to offer comments on the
report. The report was informative and thorough. I hope that our
observations prove helpful.
Sincerely,
Signed by:
W. Ron DeHaven:
Administrator:
Animal and Plant Health Inspection Service:
The following are GAO's comments on the U.S. Department of
Agriculture's letter dated February 23, 2005.
GAO Comments:
1. Regarding USDA's comments about the use of rapid diagnostic tools at
the site of an outbreak, our report acknowledges that USDA has already
utilized these tools for the control of exotic Newcastle disease and
avian influenza, but notes that USDA has only done so in a laboratory
setting. The report also acknowledged USDA's concern for using this
technology at the site of an outbreak. For example, we noted that rapid
diagnostic tools still need to be validated for many diseases,
including FMD. Furthermore, the report acknowledges USDA's concern that
samples need to be sent to USDA's reference laboratories for final
confirmation to determine the disease subtype, which must be known to
deploy the correct type of vaccine. However, we continue to believe
that use of these tools at the site of an outbreak would help reduce
the impact of a terrorist attack because the tools would allow for a
more rapid diagnosis so that informed control measures could be
implemented as quickly as possible, and they would also permit the
monitoring of nearby herds before symptoms appeared so that only
infected herds would have to be killed. We understand that it would not
be appropriate or cost-effective to test all animals within a herd for
any highly infectious foreign animal disease because in all likelihood,
if one tests positive, the other animals in that herd would already be
infected. Also, as noted by state officials, the use of these tools
would help prevent laboratories from becoming overwhelmed with test
samples in the event of a terrorist attack involving the introduction
of diseases at multiple locations.
2. Regarding USDA's comments about the use of vaccines to control an
outbreak, we acknowledge that using vaccines to control an outbreak has
some limitations; however, as our report states, a recent USDA test
exercise of an intentional introduction of FMD in multiple locations
suggests that the current "stamping out approach" would have
catastrophic results. Also, in February 2005, the National Audit Office
in the United Kingdom reported that based on experience from the 2001
FMD outbreak in the United Kingdom, the ability to vaccinate, in
conjunction with culling, may be necessary to contain an FMD outbreak.
The report further states that the government in the United Kingdom has
substantially increased stocks of vaccines for FMD in order to better
contain the spread of FMD should another outbreak occur. Furthermore,
USDA's draft response plan for an outbreak of foot and mouth disease or
other highly contagious animal disease notes that vaccines may be used
strategically to create barriers between infected zones and disease-
free zones. We have added this information to the report.
Furthermore, our report does not imply that it is cost effective to
maintain a supply of vaccines for every possible permutation of each
disease of concern. In fact, the report clearly states that it is
unlikely that vaccines will ever be developed for all strains of
diseases and the report also notes that vaccines should be developed
for those of primary concern to USDA. We do not state that vaccines are
necessary for all foreign animal diseases. We acknowledge, however,
that our report did not address the need to develop marker vaccines,
and we have modified the report to reflect this need. Finally, in
response to USDA's comment about simplifying the decision-making
process on vaccine use, we have added language to the report to clarify
USDA's position.
3. We modified our report to state that while all U.S. veterinary
schools offer information about foreign animal diseases, only about 26
percent of the nation's veterinary graduates have taken a course
specifically dedicated to foreign animal diseases. We also revised the
report to note that, according to USDA officials, all veterinary
students must take instruction in infectious diseases and pathology
which, according to these officials, includes foreign animal diseases.
In addition, we modified the report to state that USDA officials
believe that requiring accredited veterinarians to be licensed ensures
that they receive basic training in foreign animal diseases.
Furthermore, we note that there are a small number of personnel trained
specifically in the diagnosis of foreign animal diseases.
Finally, we modified the report to state that USDA officials told us
that new efforts are being made to strengthen APHIS' role in colleges
of veterinary medicine to provide information on various aspects of
regulatory medicine and that USDA intends to increase the number of
veterinarians entering public service by working to increase the
veterinary student awareness of potential careers in public service.
4. We modified our report to include a statement about USDA's
Memorandum of Agreement.
[End of section]
Appendix VII: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
February 14, 2005:
Mr. Robert A. Robinson:
Managing Director, Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, DC 20548:
Re: Draft Report GAO-05-214, Homeland Security: Much is Being Done to
Protect Agriculture from Terrorist Attack, but Important Challenges
Remain:
Dear Mr. Robinson:
Thank you for the opportunity to review and comment on the subject
draft report. We are providing general comments for your use in
preparing the final report and have submitted technical comments under
separate cover.
The draft report indicates that there has been a decline in agriculture
inspections at ports of entry. In fiscal year 2002, there were 40.9
million agricultural inspections at ports of entry. In fiscal year
2003, as the agriculture inspection mission was transitioning to the
Department of Homeland Security (DHS), 35.0 million inspections were
performed. In fiscal year 2004, there were 37.5 million agricultural
inspections. In June of 2003, the U.S. Department of Agriculture (USDA)
transferred 1,507 agriculture inspectors to DHS; however, by October
2004, the number of inspectors had decreased to 1,452. Despite an
initial drop in the volume of inspections during this year of
transition, total inspections increased in 2004 even as the number of
inspectors was decreasing.
There are developments currently being undertaken by DHS that will
impact agriculture inspections. Among these is the development of the
first agroterrorism rule set for the Automated Targeting System (ATS).
This rule set will be used by agriculture specialists stationed at
Advanced Targeting Units (ATU). The agriculture specialists are
receiving training in ATS and risk management skills to focus on high-
risk agricultural cargo. This includes the development of specific
selectivity criteria for the prevention of foreign animal disease in
commercial cargo.
There are also efforts underway to hire approximately 500 agriculture
specialists. The combination of additional personnel with specialized
knowledge in the biological sciences together with advanced targeting
systems and risk management will produce a more efficient inspection
process.
The draft report also references a lack of coordination of research
efforts among DHS and other agencies. However, since the summer of
2003, DHS's Science and Technology Directorate has worked with USDA's
Agricultural Research Service (ARS) and Animal Plant Health Inspection
Service (APHIS) to develop and coordinate "A Joint Strategy for Foreign
Animal Disease Research and Diagnostic Programs" (including assays and
diagnostics, and vaccines and therapeutics), with an initial focus on
foot-and-mouth disease. A report summarizing this strategy was
submitted in January 2005 in response to a request by the U.S. House of
Representatives Appropriations Subcommittee for Homeland Security.
In addition, a Board of Directors has been chartered to provide an
inter-agency forum for coordination of use of the Plum Island Animal
Disease Center (PIADC) by representatives from DHS, USDA, and other
agencies as appropriate. This will allow both DHS and USDA to
efficiently utilize the unique capabilities at PIADC for the
accomplishment of their respective mission directed requirements. Also,
a charter is being drafted for a Joint Federal Working Group on
Research and Diagnostic Development for Foreign Animal and Zoonotic
Diseases that will continue the coordination of research efforts
against agroterrorism. Further, the DHS National Center for Foreign
Animal and Zoonotic Diseases, led by Texas A&M University, is working
closely with PIADC to coordinate their respective efforts on research
and development on foot and mouth disease, and is in dialogue with
researchers in the other respective fields of their efforts, e.g.,
avian influenza, to prevent any overlap.
GAO also indicates that "...there is no overall departmental
coordination of policy and budget issues concerning agricultural and
food security within DHS and with other departments and agencies" (page
40). However, since HSPD-9 was issued in February 2004, there have been
extensive interactions between program staff across DHS, and with other
federal departments and agencies. Successful realization of the
implementation of HSPD-9 now requires engaging senior policy and
decision makers across DHS organizational elements, along with other
federal departments and agencies, to resolve necessary policy, mission,
and budget related issues.
GAO states that DHS may not be providing sufficient guidance to the
states on using the Homeland Security Grant Program (HSGP) to obtain
federal emergency preparedness assistance to support the agriculture
sector. However, it is important to note that the agricultural
component was an optional part of the FY 2003 Assessment and Strategy
process. As such, the Department did not give explicit guidance on how
to use federal financial assistance towards agroterrorism when it may
not be applicable in all cases. However, Fiscal Year 2004 and Fiscal
Year 2005 program guidance clearly notes that states may expend funds
towards the prevention, response and mitigation of agroterrorism
incidents through the purchase of equipment, training, exercises or
planning. However, any funds expended must be in accordance with the
goals and objectives outlined in the State or Urban Area Homeland
Security Strategy. As noted, DHS gives the states maximum flexibility
to determine the needs of their state and local entities; agricultural
issues may not necessarily be a concern for them. In the FY 2005
program guidance, equipment, training or exercises related to
agroterrorism is only noted as an allowable item in the State Homeland
Security Program (SHSP) and the Urban Areas Security Initiative (UASI).
These two programs are the most broad-based and well-funded sections of
the overall HSGP. The other four programs do not allow for
agroterrorism because they are much more focused program areas. For
example, the Metropolitan Medical Response System (MMRS) grant may only
be spent for ongoing activities related to MMRS, and the Emergency
Management Performance Grant (EMPG) funds are only to be used for all-
hazards, emergency management costs.
Finally, with respect to the report's recommendations, the Department
generally concurs with the recommendations. Various corrective actions
have already taken place to implement at least two of these
recommendations and they are articulated below:
Recommendation: The Secretaries of Agriculture and Homeland Security
work together to identify the reasons for declining agricultural
inspections and to identify potential areas for improvement.
USDA and DHS have entered into a Joint Agency Quality Assurance Plan
(JAQAP) and have agreed to conduct joint quality assurance reviews of
ports of entry (POE). This joint program is intended to study the
performance of the agricultural mission under DHS and identify the best
business practices of individual ports. If the JAQAP does a port review
and finds a decline in inspections, the reasons for a port's declining
inspections will be explored and actions to improve the port's
performance will be recommended. This program is part of the overall
agreement between the two agencies. The vision statement of the Joint
Quality Assurance Plan reads as follows:
JAQAP will provide suggestions for preventing terrorists and terrorist
weapons in the form of agroterrorism from entering the United States.
JAQAP will assist Customs and Border Protection to safeguard
agricultural and natural resources from the intentional (agroterrorism)
or unintentional introductions of animal and plant pests and disease
into the United States.
The joint teams' first review was in December 2004. At least four port
reviews are expected to take place during the next calendar year. These
cooperative efforts will identify weaknesses in the port's agricultural
operations and suggest areas and ways to address those areas of concern.
The Department also plans to increase hiring of agriculture specialist
and agriculture supervisors. In November 2004, DHS advertised 129
government-wide agricultural specialist positions. These positions are
presently being processed. In addition, DHS approved 14 training
classes for new officers which began in the summer of 2004 and will
continue through January 2006. It is estimated that these training
classes will result in 720 new officers. As of February, 2005, 109 new
agricultural specialists have passed New Officer Training (NOT) and are
working at Ports of Entry.
In addition to new officers, DHS has identified the need to replace and
increase the number of agricultural supervisors. The Department began
issuing vacancy announcements for new agricultural supervisors during
the week of February 7, 2005.
The added supervisors will enhance the DHS agricultural inspection
infrastructure as the number of specialists and their workloads
increase.
The Department also plans to improve agricultural targeting to make
more interceptions of pests and diseases. The assignment of
Agricultural Specialists to the Advance Targeting Units (ATU) will
greatly enhance the ability of DHS to more effectively target
passengers and commodities at all the POEs. "Smarter" targeting will
increase the number of interceptions by focusing on the people and
commodities of greater risk. A number of agricultural specialists have
already received the ATS targeting training necessary to be part of an
ATU team.
DHS has developed and delivered ATS training aimed solely at
agricultural specialists. Eighteen agricultural specialists from
various seaports successfully completed the agriculture specific
training on February 10, 2005. An additional class of ATS for the
agricultural specialists will be held in June 2005 for seaport based
specialists. It is planned to have ATS training for agricultural
specialists in air cargo and land border POEs completed by the end of
FY 2005.
Recommendation: The Secretaries of Agriculture and Homeland Security
streamline the flow of information between USDA and DHS agricultural
inspectors, and expedite the integration of the two agencies' databases
and information technology systems at the port level.
DHS is working with USDA to complete Appendix 8 of Article 8 of the
Memorandum of Agreement (MOA) between USDA APHIS and DHS to .enhance
communication. The relevant databases maintained by USDA APHIS are now
available to all DHS agricultural specialists electronically. Initially
there had been problems achieving connectivity between the two agencies
but to date these problems have been resolved and DHS officers now have
full access to the necessary databases.
As for USDA access, after extensive negotiations with USDA APHIS, DHS
is now reviewing the final version of Article 8 of the MOA. This is the
crucial article that solidifies the ability of USDA to gain access to
relevant databases held by DHS. As agreed to in the draft Appendix 8,
USDA has already identified those positions for which they are
requesting access to DHS databases. This request is currently being
processed. Additionally, USDA will soon be placing two employees at the
National Targeting Center (NTC) to work with the DHS targeters.
The Department is also working to improve information sharing with
USDA's Food Safety and Inspection Service (FSIS). DHS has gained access
to the relevant database in FSIS. In turn, FSIS has now stationed two
individuals at the NTC to assist with targeting meat and poultry
commodities. DHS is continuing to work with FSIS to gain more access
for FSIS personnel. In addition to these efforts, FSIS has developed,
in conjunction with the NTC and the Office of Strategic Trade, rule
sets for meat. The rule set is presently undergoing final adjustments
and will be piloted shortly.
In conjunction with USDA, DHS is developing rule sets for agroterrorism
targeting. The agencies have identified a plan of action for this
targeting effort and established ownership of responsibilities for
subsequent actions. USDA has agreed to form a working group to
coordinate the risk assessment and rules refinement work. DHS is in the
process of forming a corresponding work group.
In summary, DHS is in the process of implementing six corrective
actions in response to the GAO's review addressing agroterrorism. These
actions include: jointly identifying problem areas and solutions;
increased hiring of personnel; improved automated targeting; and,
increased information sharing between agencies. These actions are
expected to be completed by January 2006.
We thank you again for the opportunity to provide comments on this
draft report and look forward to working with you on future homeland
security issues:
Sincerely,
Signed by:
Steven J. Pecinovsky:
Acting Director, Departmental GAO/OIG Liaison:
Office of the Chief Financial Officer:
The following are GAO's comments on the Department of Homeland
Security's letter dated February 14, 2005.
GAO Comments:
1. DHS provided minor modifications to the total number of agricultural
inspectors transferred from USDA as well as the number of inspectors
remaining as of October 2004. We have added a footnote to our report to
address this change. DHS commented that following the transition of
inspectors from USDA to DHS in mid-2003, the number of agricultural
inspections increased. We agree, and our report clearly identifies this
increase, but also states that between 2002 and 2004, the overall
number of inspections declined.
2. At the time of our draft report, USDA noted that they were unaware
of the full scope of research efforts supported by DHS, and DHS
officials told us that there was no overall departmental coordination
of policy and budget issues concerning agriculture security research.
DHS now states that since the summer of 2003, the agency has been
working with USDA's Agricultural Research Service and with the Animal
and Plant Health Inspection Service to develop a joint strategy for
foreign animal disease research and diagnostic programs, and that a
report summarizing this strategy was submitted to the House of
Representatives Appropriations Subcommittee for Homeland Security in
January 2005. We have modified our report to reflect this comment.
Regarding DHS's other comments about research at the Plum Island Animal
Disease Center and at the National Center for Foreign Animal and
Zoonotic Diseases at Texas A&M University, our report acknowledges
these efforts so we made no further modifications.
3. We agree that, as DHS states, the fiscal year 2004 and 2005 grant
program guidance notes that states may expend funds towards the
prevention, response, and mitigation of agroterrorism incidents through
the purchase of equipment, training, exercises or planning. However, as
our report states, we believe that the guidance continues to provide
limited emphasis on agriculture relative to other funding priorities.
As a result, state governments, which have been accustomed to seek
funding for traditional emergency disciplines such as law enforcement,
may not be sufficiently informed about the availability of DHS grant
funds to protect their agriculture industries.
[End of section]
Appendix VIII: Comments from the Department of Health and Human
Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
FEB 17 2005:
Mr. Robert A. Robinson:
Managing Director, Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Robinson:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO's) draft report entitled, "Homeland
Security-Much Is Being Done to Protect Agriculture from a Terrorist
Attack, but Important Challenges Remain" (GAO-05-214). The comments
represent the tentative position of the Department and are subject to
reevaluation when the final version of this report is received.
The Department provided several technical comments directly to your
staff.
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Daniel R. Levinson:
Acting Inspector General:
Enclosure:
The Office of Inspector General (OIG) is transmitting the Department's
response to this draft report in our capacity as the Department's
designated focal point and coordinator for U.S. Government
Accountability Office reports. OIG has not conducted an independent
assessment of these comments and therefore expresses no opinion on
them.
COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES FOR THE U.S.
GOVERNMENT ACCOUNTABILITY OFFICE'S (GAO's) DRAFT REPORT ENTITLED
"HOMELAND SECURITY-MUCH IS BEING DONE TO PROTECT AGRICULTURE FROM A
TERRORIST ATTACK, BUT IMPORTANT CHALLENGES REMAIN" (GAO-05-214):
The Department of Health and Human Services (HHS) appreciates the
opportunity to review and comment on GAO's draft report entitled
"Homeland Security-Much is Being Done to Protect Agriculture from a
Terrorist Attack, but Important Challenges Remain" (GAO-05-214).
Overall, HHS agrees with the recommendations in the draft report and
welcomes the attention given to the implications of animal diseases.
The draft report frequently asserts that the costs and benefits of
developing stockpiles of ready-to-use vaccines should be evaluated. The
Centers for Disease Control and Prevention (CDC) suggests including
information on the process required for U.S. Department of Agriculture
licensure, such as the BL-3, B1-3 agriculture laboratory space that
would be sufficient to conduct Good Laboratory Practice vaccine
efficacy trials among statistically appropriate numbers of livestock-
type animals. The shortage of sufficient space to conduct efficacy
trials is a formidable barrier to vaccine development.
In response to GAO's recommendation that HHS and other agencies compile
after-action reports and submit them to the Department of Homeland
Security network under development, it should be noted that CDC has
standardized after-action reporting procedures currently in place that
are refined following events.
[End of section]
Appendix IX: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Robert A. Robinson (202) 512-3841;
Maria Cristina Gobin (202) 512-8418;
Mary Denigan-Macauley (202) 512-8552:
Acknowledgments:
In addition to the persons named above, Josey Ballenger, Jill Ann Roth
Edelson, and Steve Rossman made key contributions to this report. Other
contributors included Kevin Bray, Karen Keegan, Amanda Kutz, Lynn
Musser, Omari Norman, Cynthia Norris, and Claire van der Lee.
[End of section]
Related GAO Products:
Drinking Water: Experts' Views on How Federal Funding Can Best Be Spent
to Improve Security.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1098T]
Washington, D.C.: September 30, 2004.
Emerging Infectious Diseases: Review of State and Federal Disease
Surveillance Efforts.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-877]
Washington, D.C.: September 30, 2004.
Homeland Security: Observations on the National Strategies Related to
Terrorism.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1075T]
Washington, D.C.: September 22, 2004.
9/11 Commission Report: Reorganization, Transformation, and Information
Sharing.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1033T]
Washington, D.C: August 3, 2004.
Status of Key Recommendations GAO Has Made to DHS and Its Legacy
Agencies.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-865R]
Washington, D.C.: July 2, 2004.
Coast Guard: Key Management and Budget Challenges for Fiscal Year 2005
and Beyond.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-636T]
Washington, D.C.: April 7, 2004.
Homeland Security: Summary of Challenges Faced in Targeting Oceangoing
Cargo Containers for Inspection.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-557T]
Washington, D.C.: March 31, 2004.
Homeland Security: Risk Communication Principles May Assist in
Refinement of the Homeland Security Advisory System.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-538T]
Washington, D.C.: March 16, 2004.
Homeland Security: Preliminary Observations on Efforts to Target
Security Inspections of Cargo Containers.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-325T]
Washington, D.C.: December 16, 2003.
Bioterrorism: A Threat to Agriculture and the Food Supply.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-259T]
Washington, D.C.: November 19, 2003.
Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-847]
Washington, D.C.: September 19, 2003.
Food-Processing Security: Voluntary Efforts Are Under Way, but Federal
Agencies Cannot Fully Assess Their Implementation.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-342] Washington,
D.C.: February 14, 2003.
Homeland Security: CDC's Oversight of the Select Agent Program.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-315R]
Washington, D.C.: November 22, 2002.
(360436):
FOOTNOTES
[1] These agricultural activities include such items as farming, food-
processing, and transportation.
[2] See appendix II for a summary of experts' observations; many
experts held similar views.
[3] U.S. Government Accountability Office, U.S. Agriculture:
Vulnerability of Crops and Livestock to a Biological Attack, GAO/C-
RCED-98-1 (Washington, D.C.: May 8, 1998).
[4] Farmers may be the first to recognize the presence of an animal
disease through normal routine care and would then request a
veterinarian--usually USDA-accredited--to diagnose the disease.
Accredited veterinarians are supposed to recognize clinical signs and
lesions of exotic animal diseases.
[5] FDA is responsible for ensuring the safety and security of certain
farm products including fruits, vegetables, and milk.
[6] We also reviewed classified documents, but none of that information
is included in this report.
[7] U.S. Government Accountability Office, Homeland Security: A Risk
Management Approach Can Guide Preparedness Efforts, GAO-02-208T
(Washington, D.C.: Oct. 31, 2001).
[8] See appendix IV illustrating the concentrated nature of production
for other select animals and plants.
[9] The North American Foot and Mouth Disease Vaccine Bank located at
Plum Island Animal Disease Center was developed in 1982 and is jointly
owned by the United States, Canada, and Mexico.
[10] APHIS also has a Wildlife Services Program, which conducts
surveillance and monitoring of wild animal populations that may
potentially impact livestock by spreading disease. Wildlife Services
employees have been especially trained to assist Veterinary Services
personnel during animal health emergencies.
[11] The OIE is also known as the World Animal Health Organization.
[12] According to USDA officials, OIE now recognizes that countries may
regionalize. This means that, in the past, when OIE evaluated the
animal disease situation in a country intending to export animals
and/or animal products, it judged the country as a whole. If an
infectious disease existed somewhere within a country's borders, or if
its presence was suspected, the whole country was considered infected.
Today, a country may be able to trade if that country can demonstrate
that the disease is regionalized. In light of this, USDA officials told
us that they would remain flexible about how to handle the "stamping
out process"; however, according to USDA's draft procedure manual for
contagious animal diseases, all susceptible animals on infected farms
and those within certain proximity would still be depopulated as
quickly as possible to stop the spread of the disease.
[13] Homeland Security Act of 2002, Pub. L. No. 107-296, 116 Stat. 2135.
[14] In addition to receiving authority from the Homeland Security Act,
DHS derives its authority to oversee planning, response, and recovery
functions, through FEMA, from the Robert T. Stafford Disaster Relief
and Emergency Assistance Act of 1974, Pub. L. No. 93-288, as amended.
[15] Through an interagency agreement, FEMA, working under the
authority of the Secretary of Agriculture, can support federal, state,
and local governments in agricultural emergencies.
[16] Although most of the inspectors from USDA's Plant Protection and
Quarantine unit transferred to DHS, all of USDA's inspectors in its
Veterinary Services unit remained in USDA.
[17] DHS Agreement Number BTS-03-0001.
[18] Though neither the Homeland Security Act of 2002 nor the
Memorandum of Agreement between USDA and DHS define "conveyance," the
term typically means ships, aircraft, vehicles, buses, and rail cars.
[19] The emergency preparedness grant programs administered by HHS,
including those of CDC and FDA, were not transferred to DHS.
[20] The FY 2005 Homeland Security Grant Program combines six separate
grant programs into one application. These programs are the State
Homeland Security Program, the Law Enforcement Terrorism Prevention
Program, the Citizen Corps Program, Emergency Management Performance
Grants, the Metropolitan Medical Response System Program, and the Urban
Areas Security Initiative.
[21] Any expenditure by state or local entities must be made in
accordance with the state or urban area's homeland security strategy,
which each state has submitted to DHS.
[22] Agencies from which functions were transferred include the
Departments of Justice, Defense, and Energy.
[23] HSPD-9 calls for nationwide laboratory networks for food,
veterinary, and plant health that integrate existing federal and state
laboratory resources and are interconnected.
[24] Pub. L. No. 107-188, 116 Stat. 594.
[25] DHS released the interim National Infrastructure Protection Plan
on February 9, 2005.
[26] The appendixes in the National Response Plan are referred to as
Emergency Support Functions.
[27] Minnesota and Iowa are two of the nation's biggest soybean-
producing states.
[28] In addition to FDA and the Food Safety and Inspection Service,
other federal agencies playing a role in the development of the network
are CDC, EPA, and the Department of Energy.
[29] Sudden oak death is a disease affecting oak and tan oak trees,
which appeared in California nurseries in March 2004.
[30] Other official participants in the Government Coordinating Council
include EPA, DOD, the Association of State and Territorial Health
Officials, the National Association of State Departments of
Agriculture, the National Association of County and City Health
Officials, and the National Assembly of State Chief Livestock Health
Officials. In addition, the council includes ex-officio non-voting
participants that possess relevant expertise. Ex-officio members
include the Associations of Food and Drug Officials, the Departments of
Commerce, Interior, and Justice.
[31] USDA homeland security research is supported by ARS and the
Cooperative State Research, Education and Extension Service, which
awards grants to universities and other institutions to conduct
research in agriculture.
[32] APHIS also created one National Wildlife Disease Coordinator
position to coordinate state and federal surveillance of wildlife
diseases.
[33] These coordinators also assist in administrating emergency
management grants to states; develop communication and training to
state and local entities; and serve as technical resources for states,
industry, and other stakeholders.
[34] Wenzel, James G.W. "Assessment of Training for Veterinary
Accreditation and Foreign Animal Disease Recognition at US Colleges and
Schools of Veterinary Medicine," Auburn University. Contracted Research
for USDA-APHIS-VS (2004).
[35] APHIS's Veterinary Services administers the National Veterinary
Accreditation Program. This voluntary program certifies private
veterinary practitioners to work cooperatively with federal
veterinarians and state animal health officials. Producers that export
animals rely on the expertise of accredited veterinarians to help
ensure that exported animals will not introduce diseases into another
state or country. Private practitioners were first used to perform
regulatory work in 1907, when a large number of horses were exported to
Canada. As there were inadequate numbers of federal veterinarians to
meet these demands, the Canadian government agreed to accept health
inspections and certifications performed by private practitioners
qualified by the Bureau of Animal Industry (now APHIS). The services of
practicing veterinarians were used again in 1917, when the Tuberculosis
Eradication program was established.
[36] USDA officials told us that it has a cadre of certified private
veterinary practitioners who partner with APHIS to report any suspected
foreign animal disease cases to federal officials. These surveillance
efforts are further augmented by the work of 450 specially trained
foreign animal disease diagnosticians who actively search for FMD and
other foreign animal diseases across the country. USDA continues to
train 100 foreign animal disease diagnosticians annually.
[37] A USDA official told us that continuing education is a requirement
of every state licensing process. All accredited veterinarians must be
licensed by a state and therefore are required to have continuing
education to maintain their licenses.
[38] To maintain accreditation status under the new standards,
veterinarians will have to periodically complete supplemental education
requirements. These supplemental training modules will be available on-
line to the entire accredited veterinarian population. Through a
cooperative agreement with Iowa State University, APHIS has already
initiated development of 6 supplemental training modules for the new
accreditation process. These modules focus heavily on the recognition
of the clinical signs of many of the most prominent foreign animal
diseases and on how to respond to a potential foreign animal disease
outbreak. The new program will institute a 3-year renewal period for
veterinary accreditation for all veterinarians. If documented
supplemental training is not completed before the 3-year renewal period
expires, the accreditation status of the veterinarian will be
inactivated.
[39] The American Veterinary Medical Association reports that there are
approximately 61,000 practicing veterinarians.
[40] The Association of American Veterinary Medical Colleges (AAVMC)
defines public practice as federal, state (including state, public
health, and extension veterinarians, as well as those who inspect
meat), and industry. According to AAVMC, there are approximately 4,000
additional veterinarians in academia, most of whom are engaged in
research.
[41] During the early phase of foreign animal disease surveillance,
samples will most likely be sent to NVSL in Ames, Iowa, or the Foreign
Animal Disease Diagnostic Laboratory located on Plum Island, New York,
depending on the disease agent. Once the disease agent in the outbreak
has been confirmed and an emergency response effort has started,
samples may be sent to local laboratories, including one of USDA's
National Animal Health Laboratory Network laboratories.
[42] According to USDA officials, confirmatory testing is done for
several reasons, including economics and trade relations. USDA
officials told us they believe that caution should be used in spending
public funds and that the particular virus and strain or type of virus
must be known before expending resources. If FMD were officially
confirmed in the United States, the international community would be
notified and all exports of susceptible animals and animal products
would temporarily cease until the scope of the outbreak could be
determined. Trading partners would also impose restrictions.
[43] USDA officials told us that a tool is being developed for Rift
Valley fever as well.
[44] While rapid diagnostic tools can diagnose the presence of FMD,
they cannot determine the disease subtype, which must be known to
deploy the correct type of FMD vaccine. Therefore, a sample of the
suspect virus would still have to be flown to Plum Island Animal
Disease Center, where its complete genetic sequence would be determined
in order to identify the subtype.
[45] CDC and FDA officials told us they have not used rapid diagnostic
tools outside of a laboratory setting. According to CDC officials, they
are concerned about possible cross-contamination as well as the lack of
an integrated plan among local, state, and federal officials for
responding to reported results. However, resources are being devoted to
support the ongoing evaluation of field detection products. FDA
officials told us they are also concerned about cross-contamination as
well as the sensitivity of reagents to temperature changes. In
commenting on a draft of this report, FDA officials told us that a
number of different types of rapid diagnostic tools are in use by FDA
laboratories and others for the detection of pathogenic microorganisms,
biologically derived toxins, and toxic chemicals. Real-time polymerase
chain reactions and immunoassays are two examples of such tests; other
technologies exist. FDA officials noted that while these can be useful
outside a laboratory setting, these techniques generally have several
requirements that have limited their field application. FDA officials
also commented that in most instances, it is actually more time
efficient to rapidly transport samples to one of a series of
strategically located regional laboratories where all aspects of the
analytical process can be completed. However, FDA officials also told
us that resources are being devoted to support the ongoing evaluation
of field detection products and the agency plans to use diagnostic
tools in its mobile laboratories.
[46] According to USDA, the rapid diagnostic tools for these diseases
have been scientifically validated. Tools for the detection of FMD,
classical swine fever, and vesicular stomatitis virus are still
undergoing validation at the time of our report. Once validated, the
rapid diagnostic tools are to be deployed to select laboratories within
the National Animal Health Laboratory Network in 2005.
[47] The mobile unit would be located just off the farm to eliminate
contaminating the unit. Procedures would be the same as those for any
official taking a sample from a farm suspected of having a highly
contagious disease.
[48] Depending on the situation, the rapid diagnostic tools are set up
in a tent near the sampling site or, if sampling is required at
multiple sites, the tools are set up in a mobile unit and driven to
each location.
[49] If an animal tests positive for a foreign animal disease such as
FMD, current USDA procedures to contain the outbreak are to slaughter
all susceptible animals within a 10-kilometer radius.
[50] Results could be reviewed over the Internet by experts in the
laboratories, or the tests could be conducted by technical experts at
the site of an outbreak.
[51] In addition, technicians who are sampling are typically supervised
by individuals with clinical laboratory credentials and/or advanced
degrees, according to DOD.
[52] Samples that test positive at the site are shipped back to DOD's
reference laboratory for further analysis, but personnel in the field
will make medical decisions based on these rapid diagnostic tools. For
example, if anthrax is detected, then medicine would be distributed.
[53] See appendix III for a list of these diseases.
[54] We reported in 2002 that an outbreak of FMD could range up to $24
billion in current dollars, depending, among other things, on the
extent of the outbreak.
[55] The Department for Environment, Food and Rural Affairs. Foot and
Mouth Disease: Applying the Lessons. Report by the Comptroller and
Auditor General (HC 184 session 2004-2005). February 2, 2005.
[56] This participation includes senior representatives from CDC's
Strategic National Stockpile. Their participation also supports HSPD-9.
[57] CDC officials also noted that if testing indicates a vaccine is
still efficacious, USDA could potentially extend the shelf life of the
vaccine.
[58] For those diseases where there is no market for a vaccine, the
vaccine would simply have to be disposed and restocked.
[59] According to USDA officials, the extent to which the vaccine could
be applied would be limited to the number of available trained
personnel, and these personnel are limited.
[60] USDA officials noted that there is a need to develop "marker"
vaccines to differentiate vaccinated animals from those infected with
live agents, as this would have a large impact on trade.
[61] DHS and USDA-APHIS-PPQ inspect imports of plants, (dead) animal
products, seeds, farm instruments, and other items of agricultural
interest, including packing materials that could contain pests. USDA-
APHIS' Veterinary Services retains sole authority over inspections of
live animals.
[62] See the Congressional Research Service's Border Security:
Inspections Practices, Policies, and Issues, May 26, 2004, and
Agroterrorism: Threats and Preparedness, August 13, 2004, both of which
are available at http://www.crs.gov; and America at Risk: Closing the
Security Gap by the Democratic Members of the House Select Committee on
Homeland Security, February 2004, available at
http://www.house.gov/hsc/democrats.
[63] USDA has retained responsibility for maintaining agricultural
inspections data, including data on interceptions. The agency provided
us with the total number of agricultural inspections and interceptions
for fiscal years 2002 through 2004 as of December 22, 2004. These
numbers came from USDA-APHIS-PPQ's Work Accomplishment Data System
(WADS), the primary database both USDA and DHS agricultural inspectors
use to record inspections of plant and animal products and
interceptions of prohibited agricultural items, and the Port
Information Network (PIN) 309 database, which USDA uses to track
interceptions of reportable insects and pests. These databases do not
include inspections data from USDA-APHIS-Veterinary Services, which
still maintains authority over inspections of live animals, nor does it
include inspections of food items performed by USDA's Food Safety and
Inspection Service or FDA. For a comprehensive review of the entire
food and agricultural sector, those agencies' inspections would have to
be included. We did not independently assess the reliability of the
WADS data provided to us by USDA.
[64] USDA and DHS refer to the different types of ports of entry--land
border crossings, airports, and maritime (sea) ports--as "pathways."
Within those pathways, agricultural items can enter the United States
through different means: ships, aircraft, vehicles, buses, rail cars,
passenger and crew baggage, regulated cargo, miscellaneous cargo,
pedestrians, and international mail.
[65] An inspection team that reviews the paperwork accompanying foreign
cargo can decide to "hold" an item for further review, which may result
in an inspection, fumigation, or other appropriate action.
[66] USDA's Economic Research Service reports that the total value of
agricultural imports was $41.0 billion in fiscal year 2002, $45.7
billion in fiscal year 2003, and $51.5 billion in fiscal year 2004.
Meanwhile, USDA's inspections data show that international air
passenger and crew arrivals at U.S. airports increased from 64.9
million to 67.1 million to 72.6 million over the same time frame.
[67] Under the memorandum of agreement between the two agencies, USDA
is responsible for providing risk analysis guidance to DHS, and DHS is
responsible for targeting high-risk agricultural passenger and cargo
shipments for inspections, using USDA data.
[68] During our audit, DHS officials told us USDA transferred 1,872
full-time agricultural inspector positions, of which 355 were vacant in
March 2003, including supervisors. However, in commenting on a draft of
this report, DHS officials stated that USDA transferred 1,507
agricultural inspectors to DHS in June 2003 and that by October 2004
the number of inspectors had decreased to 1,452, including supervisors.
[69] According to DHS officials, the personnel vacancies also include
agricultural specialists assigned to K-9 units, resulting in fewer
inspections of this nature. DHS officials told us that they are in the
process of assessing K-9 needs and filling vacancies.
[70] At the time of our report, DHS and USDA officials told us they
were drafting another memorandum of agreement between the two agencies
on data and information-sharing. However, we have not seen this
document and some officials told us it may not address the information-
sharing issues we have raised concerning agriculture inspections.
[71] DHS refers to inspectors who transferred from the U.S. Customs
Service and the Immigration and Naturalization Service as "legacy"
customs and immigration officers. All DHS inspectors are cross-trained
on immigration, customs, and agriculture laws, policies, and procedures
in order to assist each other and make appropriate referrals to each
other regarding specialized inspections.
[72] USDA is responsible for the supervision and development of
educational support and systems to ensure that DHS employees receive
the training necessary to carry out the USDA functions transferred to
DHS, as specified in Article 4 of the memorandum of agreement between
USDA and DHS.
[73] DHS officials told us that some ports of entry provide agriculture-
related information to customs and immigration inspectors. Although
this training is not officially certified by DHS or USDA, the training
does provide an overview to the inspectors of agriculture- related
items and pests such as wood borers, "hitchhiker" pests such as snails,
and prohibited packing material and contaminants. According to DHS,
this unofficial training has led to some referrals by these legacy
inspectors to DHS agricultural specialists and has resulted in some
interceptions.
[74] Some recent, naturally occurring disease outbreaks since the
transfer to DHS include sudden oak death, Sapote and Mexican fruit
flies, exotic Newcastle disease, and karnal bunt.
[75] As a result of the outbreak of soybean rust in late 2004 in
multiple southern states, USDA expects the 2005 crop to be infected and
anticipates the need for emergency response personnel to control the
disease.
[76] According to USDA's 2002 agriculture census, California has
342,053 acres of citrus fruit, compared with #1 Florida's 871,733
acres. Florida's industry has an approximate $9 billion economic impact
on the state.
[77] The FY 2005 Homeland Security Grant Program combines six separate
grant programs into one application. These programs are the State
Homeland Security Program, the Law Enforcement Terrorism Prevention
Program, the Citizen Corps Program, Emergency Management Performance
Grants, the Metropolitan Medical Response System Program, and the Urban
Areas Security Initiative.
[78] The $20 million is the allocation available through one component
of the Homeland Security Grant Program, the State Homeland Security
Program. All of the funding for the state's agroterrorism projects for
FY 2004 came through the State Homeland Security Program.
[79] This was required for USDA's Standards for Plant Health Emergency
System. In addition, the District of Columbia and the American Virgin
Islands did not complete their plant health emergency planning
documents by the September 30, 2004, deadline.
[80] The USDA job announcement for these positions warns the job is
trying, involving long hours at a computer or on the phone, and up to
10 days of travel per month regionally, nationally, or internationally-
-not including emergencies.
[81] DHS officials did not provide us with a copy of the Government
Coordinating Council Charter during the course of our engagement.
[82] In commenting on a draft of this report, DHS officials noted that
since the summer of 2003, the agency has been working with USDA's
Agricultural Research Service and with APHIS to develop a joint
strategy for foreign animal disease research and diagnostic programs,
and that a report summarizing this strategy was submitted to the House
of Representatives Appropriations Subcommittee for Homeland Security in
January 2005.
[83] Those diseases, as identified by the National Animal Health
Laboratory Network's steering committee, are bovine spongiform
encephalopathy, FMD, classical swine fever, exotic Newcastle disease,
avian influenza, scrapie, chronic wasting disease, and vesicular
stomatitis virus.
[84] USDA officials told us that a memorandum of agreement was drafted
in late 2004 between USDA, HHS, DHS, and other agencies to work
collaboratively to provide timely, high-quality, and interpretable
results for early detection and effective consequence management of
acts of terrorism and other events requiring an integrated laboratory
response.
[85] HSPD-9 calls for nationwide laboratory networks for food,
veterinary, and plant health that integrate existing federal and state
laboratory resources and are interconnected. Specifically, HSPD-9
requires USDA and HHS to develop robust, comprehensive, and fully
coordinated surveillance and monitoring systems that provide early
detection and awareness of disease, pest, or poisonous agents.
[86] Pub. L. No. 93-288, 88 Stat. 143.
[87] Pub. L. No. 106-224, 114 Stat. 358.
[88] Pub. L. No. 107-171, 116 Stat. 134; portions of this law are
referred to as the Animal Health Protection Act.
[89] Pub. L. No. 107-188, 116 Stat. 594.
[90] DHS Agreement Number BTS-03-0001.
[91] Office of Management and Budget, OMB Circular A-123 Management
Accountability and Control (Washington, D.C.: 1995). This document
provides the specific requirements for assessing and reporting on
controls within the executive branch.
[92] U.S. Government Accountability Office, Internal Control: Standards
for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
(Washington, D.C., November 1999). The Federal Managers' Financial
Integrity Act of 1982 (FMFIA) requires us to issue standards for
internal controls in government. Among other things, the standards
provide the overall framework for establishing and maintaining internal
controls.
[93] B.V.M.S., is a Bachelor of Veterinary Medicine degree. M.R.C.V.S.,
is a Member of the Royal College of Veterinary Surgeons. Ph.D. is a
Doctorate of Philosophy degree.
[94] D.V.M., is a Doctorate of Veterinary Medicine degree.
[95] M.P.H., is a Master in Public Health degree.
[96] MS is a Master of Science degree.
[97] CARVER is an acronym for Criticality, Accessibility,
Recuperability, Vulnerability, Effect, and Recognizability.
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