Live Animal Imports
Agencies Need Better Collaboration to Reduce the Risk of Animal-Related Diseases Gao ID: GAO-11-9 November 8, 2010The United States legally imported more than 1 billion live animals from 2005 through 2008. With increased trade and travel, zoonotic diseases (transmitted between animals and humans) and animal diseases can emerge anywhere and spread rapidly. The importation of live animals is governed by five principal statutes and implemented by four agencies. GAO was asked to examine, among other things, (1) potential gaps in the statutory and regulatory framework governing live animal imports, if any, that may allow the introduction and spread of zoonotic and animal diseases and (2) the extent to which the agencies collaborate to meet their responsibilities, and face barriers, if any, to collaboration. GAO reviewed statutes, met with agency officials, visited ports of entry, and surveyed experts on animal imports.
The statutory and regulatory framework for live animal imports has gaps that could allow the introduction of diseases into the United States, according to the experts GAO surveyed, discussions with agency officials, and scientific studies. Specifically, (1) The Department of Health and Human Services' Centers for Disease Control and Prevention (CDC) has regulations to prevent the importation of live animals that may pose a previously identified disease risk to humans for some diseases, but gaps in its regulations may allow animals presenting other zoonotic disease risks to enter the United States. CDC has solicited comments in advance of a rulemaking to better prevent the importation of animals that pose zoonotic disease risks. (2) The Department of the Interior's Fish and Wildlife Service (FWS) has regulations to prevent imports of nonnative live animals that could become invasive. However, it has not generally emphasized preventing the introduction of disease through importation. FWS is taking some initial steps to address disease risks. For example, in January 2010, the department directed FWS to review statutory authorities and regulations to address existing problems concerning nonnative live animals and recommend tools to better prevent the introduction of new threats. In contrast, the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) has regulations to prevent importing live animals it finds may pose a disease risk to agricultural animals. In 2008, APHIS issued a long-term strategy that would broaden its oversight of live animal imports. APHIS, the Department of Homeland Security's Customs and Border Protection (CBP), CDC, and FWS have collaborated to meet their responsibilities related to live animal imports by taking actions in five areas--strategic planning, joint strategies, written procedures, leveraging resources, and sharing data. However, experts GAO surveyed and agency officials GAO interviewed identified barriers to further collaboration on live animal imports, such as different program priorities and unclear roles and responsibilities, which are inherent when multiple agencies have related responsibilities. For example, experts noted that because each of the agencies is focused on a different aspect of live animal imports, no single entity has comprehensive responsibility for the zoonotic and animal disease risks posed by live animal imports. Experts also reported the need for an entity to help the agencies overcome these barriers to collaboration. Furthermore, the agencies have largely incompatible data systems, and a completion date for CBP's planned data system, which would provide the agencies with full operational access to information on incoming shipments of live animals, has not been established. In addition, APHIS, CBP, CDC, and FWS have yet to jointly determine which data elements on live animal imports are needed in this system for them to effectively oversee these imports, according to CBP officials. As a result, it is unclear whether the data elements in the completed system will meet interagency needs. GAO recommends that the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior develop a strategy to address barriers to agency collaboration that may allow potentially risky imported animals into the United States and jointly determine data needs to effectively oversee imported animals. In commenting on a draft of this report, the Departments of Agriculture, Interior and Homeland Security generally agreed with GAO's findings and recommendations. The Department of Health and Human Services provided technical comments only.
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: Lisa R. Shames Team: Government Accountability Office: Natural Resources and Environment Phone: (202) 512-2649GAO-11-9, Live Animal Imports: Agencies Need Better Collaboration to Reduce the Risk of Animal-Related Diseases
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Report to the Committee on Homeland Security and Governmental Affairs,
U.S. Senate:
United States Government Accountability Office:
GAO:
November 2010:
Live Animal Imports:
Agencies Need Better Collaboration to Reduce the Risk of Animal-
Related Diseases:
GAO-11-9:
GAO Highlights:
Highlights of GAO-11-9, a report to the Committee on Homeland Security
and Governmental Affairs, U.S. Senate.
Why GAO Did This Study:
The United States legally imported more than 1 billion live animals
from 2005 through 2008. With increased trade and travel, zoonotic
diseases (transmitted between animals and humans) and animal diseases
can emerge anywhere and spread rapidly. The importation of live
animals is governed by five principal statutes and implemented by four
agencies.
GAO was asked to examine, among other things, (1) potential gaps in
the statutory and regulatory framework governing live animal imports,
if any, that may allow the introduction and spread of zoonotic and
animal diseases and (2) the extent to which the agencies collaborate
to meet their responsibilities, and face barriers, if any, to
collaboration. GAO reviewed statutes, met with agency officials,
visited ports of entry, and surveyed experts on animal imports.
What GAO Found:
The statutory and regulatory framework for live animal imports has
gaps that could allow the introduction of diseases into the United
States, according to the experts GAO surveyed, discussions with agency
officials, and scientific studies. Specifically,
* The Department of Health and Human Services‘ Centers for Disease
Control and Prevention (CDC) has regulations to prevent the
importation of live animals that may pose a previously identified
disease risk to humans for some diseases, but gaps in its regulations
may allow animals presenting other zoonotic disease risks to enter the
United States. CDC has solicited comments in advance of a rulemaking
to better prevent the importation of animals that pose zoonotic
disease risks.
* The Department of the Interior‘s Fish and Wildlife Service (FWS) has
regulations to prevent imports of nonnative live animals that could
become invasive. However, it has not generally emphasized preventing
the introduction of disease through importation. FWS is taking some
initial steps to address disease risks. For example, in January 2010,
the department directed FWS to review statutory authorities and
regulations to address existing problems concerning nonnative live
animals and recommend tools to better prevent the introduction of new
threats.
In contrast, the U.S. Department of Agriculture‘s Animal and Plant
Health Inspection Service (APHIS) has regulations to prevent importing
live animals it finds may pose a disease risk to agricultural animals.
In 2008, APHIS issued a long-term strategy that would broaden its
oversight of live animal imports.
APHIS, the Department of Homeland Security‘s Customs and Border
Protection (CBP), CDC, and FWS have collaborated to meet their
responsibilities related to live animal imports by taking actions in
five areas”strategic planning, joint strategies, written procedures,
leveraging resources, and sharing data. However, experts GAO surveyed
and agency officials GAO interviewed identified barriers to further
collaboration on live animal imports, such as different program
priorities and unclear roles and responsibilities, which are inherent
when multiple agencies have related responsibilities. For example,
experts noted that because each of the agencies is focused on a
different aspect of live animal imports, no single entity has
comprehensive responsibility for the zoonotic and animal disease risks
posed by live animal imports. Experts also reported the need for an
entity to help the agencies overcome these barriers to collaboration.
Furthermore, the agencies have largely incompatible data systems, and
a completion date for CBP‘s planned data system, which would provide
the agencies with full operational access to information on incoming
shipments of live animals, has not been established. In addition,
APHIS, CBP, CDC, and FWS have yet to jointly determine which data
elements on live animal imports are needed in this system for them to
effectively oversee these imports, according to CBP officials. As a
result, it is unclear whether the data elements in the completed
system will meet interagency needs.
What GAO Recommends:
GAO recommends that the Secretaries of Agriculture, Health and Human
Services, Homeland Security, and the Interior develop a strategy to
address barriers to agency collaboration that may allow potentially
risky imported animals into the United States and jointly determine
data needs to effectively oversee imported animals. In commenting on a
draft of this report, the Departments of Agriculture, Interior and
Homeland Security generally agreed with GAO‘s findings and
recommendations. The Department of Health and Human Services provided
technical comments only.
View [hyperlink, http://www.gao.gov/products/GAO-11-9] or key
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov.
[End of section]
Contents:
Letter:
Background:
Gaps in the Statutory and Regulatory Framework for Some Live Animal
Imports May Contribute to Disease Risks, according to Experts and
Agency Officials:
Agencies Have Collaborated to Meet Their Responsibilities, but Experts
and Agency Officials Identified Barriers to Further Collaboration:
APHIS, CDC, and FWS Have Reported Some Information on Their
Performance on Live Animal Imports:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Agencies' Processes for Overseeing Live Animal Imports:
Appendix III: Data on the Number of Live Animals Imported in Recent
Years:
Appendix IV: Examples of Recent U.S. Animal Disease Outbreaks Causing
Animal, Human, and Environmental or Economic Harm:
Appendix V: Overview of Federal Agencies' Disease Risk Screening for
Selected Types of Imported Animals:
Appendix VI: Experts Responding to Our Survey on Live Animal Imports:
Appendix VII: GAO Survey Questions and Responses:
Appendix VIII: Comments from the U.S. Department of Agriculture:
Appendix IX: Comments from the Department of Homeland Security:
Appendix X: Comments from the Department of the Interior:
Appendix XI: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Overview of Federal Agencies' Disease Risk Screening for
Selected Types of Imported Animals:
Table 2: Number of Live Animal Imports Regulated by APHIS, Fiscal
Years 2005 through 2008:
Table 3: Number of Live Animal Imports Regulated by FWS, Fiscal Years
2005 through 2009:
Abbreviations:
ACE: Automated Commercial Environment:
APHIS: Animal and Plant Health Inspection Service:
Bd: Batrachochytrium dendrobatidis:
CBP: Customs and Border Protection:
CDC: Centers for Disease Control and Prevention:
DHS: Department of Homeland Security:
FWS: Fish and Wildlife Service:
ITDS: International Trade Data System:
MOU: memorandum of understanding:
SARS: severe acute respiratory syndrome:
USDA: U.S. Department of Agriculture:
[End of section]
November 8, 2010:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The United States is the world's leading import market for live
animals: From 2005 through 2008 more than 1 billion live animals were
legally imported into the United States for agriculture, clinical
research, education and exhibition, the aquarium and pet industries,
and other uses. However, these imports have the potential to transmit
zoonotic diseases--infectious diseases that can be transmitted between
animals and humans and can cause a substantial number of deaths.
Furthermore, zoonotic diseases have represented about 75 percent of
newly emerging infectious diseases in recent years. Because of growing
international trade and travel, these zoonotic diseases can emerge
anywhere and spread rapidly around the globe, as demonstrated by the
2003 outbreak of severe acute respiratory syndrome (SARS), a viral
respiratory illness that caused pneumonia in most patients and was
responsible for over 700 deaths in East Asia and 43 deaths in Canada.
Over the past few years, another zoonotic disease, a highly pathogenic
strain of avian influenza, killed millions of wild and domestic birds
worldwide and infected over 400 people, more than half of whom died.
The spread of zoonotic diseases, as well as other diseases affecting
only animals, can take a major economic toll on many industries. For
example, the highly pathogenic avian influenza in East Asia cost the
affected economies an estimated $10 billion. In the United States, an
outbreak of exotic Newcastle disease--a contagious and fatal viral
disease affecting birds--resulted in the destruction of over 4.5
million birds in 2002 and 2003 at a cost of more than $395 million in
lost trade.
The laws governing the importation of live animals include five
statutes that are implemented by four agencies. Specifically,
* Animal Health Protection Act. The U.S. Department of Agriculture's
(USDA) Animal and Plant Health Inspection Service (APHIS) may prohibit
imports of particular animals to prevent the introduction of any pest
or disease affecting agricultural animals, such as cattle, horses,
poultry, and swine.
* Lacey Act. The Department of the Interior's Fish and Wildlife
Service (FWS) administers the prohibition against the import of
animals that have been individually listed in the statute or
prescribed in FWS regulation to be "injurious to human beings, to the
interests of agriculture, horticulture, forestry, or to wildlife or
the wildlife resources of the United States."
* The Endangered Species Act of 1973. FWS administers the prohibition
against the import of animals that have been listed as threatened or
endangered species and implements other international agreements
related to these species.
* Public Health Service Act. The Department of Health and Human
Services' Centers for Disease Control and Prevention (CDC) issues
regulations to prevent the introduction, transmission, and spread of
communicable diseases, including zoonotic diseases.
* Tariff Act of 1930. The Department of Homeland Security's (DHS)
Customs and Border Protection (CBP) is responsible for inspecting
imports for compliance with United States law and assisting all
federal agencies in enforcing their regulations--including regulations
for live animal imports--at ports of entry.
As we have previously reported, when responsibilities cut across more
than one federal agency--as they do for the regulation of live animal
imports to prevent the introduction and spread of diseases--it is
important for agencies to work collaboratively.[Footnote 1] Taking
into account the nation's long-range fiscal challenges, we noted that
the federal government must identify ways to deliver results more
efficiently and in a way that is consistent with its multiple demands
and limited resources. We also identified key practices that can help
enhance and sustain federal agencies' collaboration. In addition, we
have previously reported on the need to collaborate on animal disease
issues. For example, we reported in 2007 on the steps that USDA took
to prepare for highly pathogenic avian influenza in poultry and
recommended that USDA and DHS clarify their roles during emergency
responses to a disease outbreak.[Footnote 2] Both USDA and DHS
officials told us that they have taken preliminary steps to clarify
and better define their coordination roles. For example, the two
agencies meet on a regular basis to discuss such coordination.
In this context, you asked us to examine (1) potential gaps in the
statutory and regulatory framework governing live animal imports, if
any, that may allow the introduction and spread of zoonotic and animal
diseases; (2) the extent to which APHIS, CBP, CDC, and FWS collaborate
to meet their responsibilities and face barriers, if any, to
collaboration; and (3) the performance information that the
responsible agencies have reported on live animal imports.
To identify potential gaps in the statutory and regulatory framework,
we reviewed relevant statutes, the agencies' implementing regulations,
and other agency documents. We also reviewed APHIS and FWS data on the
number, type, and exporting country of all imported animals regulated
by these two agencies for fiscal years 2005 through 2009. For the
APHIS and FWS data, we analyzed documentation related to the data, and
worked with agency officials to identify data problems, and determined
the data were sufficiently reliable for the purposes of providing
background to this report. To obtain information on potential gaps in
the statutory and regulatory framework as well as agencies' processes
for overseeing live animal imports, we interviewed officials at agency
headquarters and ports of entry--airports in Atlanta, Baltimore, Los
Angeles, New York, and Washington, D.C., and the land border crossings
with Mexico at Otay Mesa and San Ysidro, California. At these ports,
we focused our review on the legal importation of live animals and not
on agencies' actions to prevent animal smuggling. We also reviewed
scientific studies on zoonotic and animal diseases, including studies
by the National Academies of Sciences.
To examine the extent to which the four agencies collaborate to meet
their responsibilities and face barriers, if any, to collaboration, we
reviewed each agency's strategic plans, policies, and protocols;
reviewed documentation on the allocation of staff resources; and
interviewed headquarters officials. We also examined the degree to
which the agencies' collaborative efforts reflected the key practices
we had identified that can help enhance and sustain collaboration
among federal agencies.
To address the first two objectives, we also conducted a two-round
survey to identify potential gaps in the current statutory and
regulatory framework, how well responsible agencies collaborate to
meet their responsibilities, and potential barriers to collaboration.
The first round of the survey was conducted from January through
February 2010, and the second round was conducted from April through
May 2010. We identified knowledgeable experts who had primary
employment responsibilities related to or dependent on live animal
imports, authored peer-reviewed papers, presented at professional
conferences, provided testimony on the subject matter to Congress, or
were recognized by their peers as experts on live animal imports. To
ensure a cross section of different sectors, we selected experts from
federal and state government, academia, nongovernmental organizations,
and industry to obtain a broad spectrum of opinions. For the first
round, we sent surveys that consisted of open-ended questions
(questions that solicit additional information) to our initial list of
39 experts, and we received responses from 33, resulting in a response
rate of about 85 percent. On the basis of recommendations provided by
those responding in our first round and other experts, we expanded our
list of experts to 64 for the survey's second round, which consisted
of closed-ended questions (questions with a set of answers to choose
from). Of these 64 experts, we received responses from 56, resulting
in a response rate of about 88 percent for the second round.
To examine the performance information the responsible agencies have
reported on live animal imports in their planning and reporting
documents, we reviewed strategic plans, operational plans, mission
statements, and annual performance plans and reports from APHIS, CBP,
CDC, and FWS. A more detailed discussion of our scope and methodology
is presented in appendix I.
We conducted this performance audit from August 2009 through October
2010, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
APHIS, CBP, CDC, and FWS share responsibility for preventing the
importation of live animals that may introduce and spread zoonotic and
animal diseases.[Footnote 3] APHIS, CDC, and FWS have developed
regulations that provide specific requirements and restrictions on the
importation of animals. In some cases, more than one agency may
regulate a given animal. For example, CDC regulates dogs for their
risk of spreading rabies to humans, and APHIS regulates dogs from
countries with screwworm, a parasite that can cause great damage to
domestic livestock and other warm-blooded animals, for their risk of
spreading this parasite to agricultural animals. Information on each
agency's responsibilities and oversight activities follows and is
presented in greater detail in appendix II.
Agencies That Are Responsible for Live Animal Imports:
While CBP is responsible for overseeing all imports and assists other
agencies in enforcing their import regulations, APHIS, CDC, and FWS
have specific statutory and regulatory responsibilities for protecting
human, domesticated animal, and wildlife health from risks posed by
live animal imports.
APHIS. APHIS restricts the importation of live animals that it has
determined may pose a disease risk to agricultural animals, such as
cattle, horses, poultry, sheep, and swine. APHIS requires that many of
the animals it regulates be visually inspected at the port of entry
and generally requires the animals be accompanied by health
certificates signed by a licensed veterinarian in the country of
export and import permits. APHIS determines the level of inspection
for animals on the basis of their associated disease risk, for both
the type of animal and country of export. As a result of this
determination, APHIS may restrict imports of certain animals from
certain countries or require that animals undergo quarantine and
disease testing. APHIS veterinarians inspect live animal imports at 15
land ports along the border with Mexico, 20 land ports along the
border with Canada, and 30 airports across the continental United
States, and in Alaska, Hawaii, and Puerto Rico. In addition, APHIS
maintains animal quarantine facilities in southern California,
southern Florida, and New York state and oversees private quarantine
facilities for birds and horses in southern California. At these
quarantine facilities, imported animals are held until test results
for various diseases are received.
CBP. CBP assists other federal agencies in enforcing their import
regulations, has the primary authority to inspect imports, and seeks
to interdict shipments of contraband and the illegal importation of
live animals and other products while facilitating the flow of legal
travel and trade. According to CBP officials, when a live animal
shipment arrives at a port of entry, CBP holds and refers the shipment
to the responsible agency or agencies. CBP holds the import until an
agency representative is available to release it. After the
responsible regulating agency has released the import, CBP clears the
import for entry into the United States. CBP staff are present at more
than 300 land, air, and sea ports of entry and are trained in the
procedures to follow when live animals are presented for customs
clearance.
CDC. CDC restricts the importation of live animals that it has
determined pose a risk to public health. CDC's restrictions on these
imports vary by type of animal and can include banning certain
imports, requiring permits, requiring vaccination certificates, and
requiring quarantine. CDC staff are not present at all ports of entry
to routinely inspect live animal imports. According to CDC officials,
CDC relies on APHIS, CBP, and FWS staff to enforce its regulations at
ports of entry. When the agencies' staff have questions about
enforcing CDC's regulations, they are to contact CDC quarantine public
health officers, who are often located at a CDC quarantine station
that is at or near the port of entry. CDC has 20 quarantine stations
in the continental United States, Alaska, Hawaii, and Puerto Rico.
FWS. FWS restricts the importation of certain wildlife. Specifically,
FWS restricts the importation of injurious wildlife and threatened or
endangered species and related species for which international trade
is regulated under international agreements. Injurious wildlife
includes animals that are individually listed in the Lacey Act or
prescribed in FWS regulations to be injurious to human beings; to the
interests of agriculture, horticulture, or forestry; or to wildlife or
the wildlife resources of the United States. FWS seeks to prevent the
introduction of invasive species as injurious wildlife under the Lacey
Act. Invasive species are alien (or nonnative) species whose
introduction does, or is likely to, cause economic or environmental
harm or harm to human health.[Footnote 4] At ports of entry, FWS
wildlife inspectors review the required import documents and, for some
live animal shipments, perform visual inspections. If FWS determines
that the animals are prohibited from importation based on FWS
regulations, for example, are injurious to wildlife or threatened or
endangered species, it rejects the import unless it has an FWS permit,
which may be issued under certain conditions, such as educational
purposes. FWS has about 120 wildlife inspectors who handle shipments
at 49 ports of entry nationwide, including 7 land ports along the
Mexican border, 24 land ports along the Canadian border, and 18
designated ports for air, ocean, rail, and truck across the
continental United States and in Alaska and Hawaii.
Number, Type, and Purpose of Live Animals Imports:
APHIS and FWS data systems provide information on the number of and
purpose for live animal imports, as well as on the country from which
the import has been shipped into the United States in recent years.
[Footnote 5] According to the APHIS data system, about 32 million live
animals--mostly agricultural or aquacultural--were imported under
APHIS regulation in fiscal year 2008, the most recent year for which
verified data were available. They included cattle, fish, poultry, and
swine. According to the FWS data system, about 177 million live
animals--all wildlife--were imported under FWS regulation in fiscal
year 2009. About 157 million of these imports were fish. Other types
of animals imported under FWS regulation included amphibians, birds,
corals, crustaceans, insects, mammals, mollusks, and reptiles. More
information about the number and type of live animal imports is in
appendix III.
Interagency Collaboration:
In 2000, we reported that agencies face a range of barriers when they
attempt to collaborate with other agencies.[Footnote 6] With these
barriers in place, federal agencies carry out programs in a
fragmented, uncoordinated way, resulting in a patchwork of programs
that can waste scarce funds, confuse and frustrate program customers,
and limit the overall effectiveness of the federal effort.
Subsequently, in 2005, we identified key practices that can help
enhance and sustain collaboration among federal agencies.[Footnote 7]
Among the practices we identified were (1) defining and articulating a
common outcome; (2) defining and agreeing on roles and
responsibilities; (3) establishing mutually reinforcing or joint
strategies; (4) identifying and addressing needs by leveraging
resources; and (5) establishing compatible policies, procedures, and
other means to operate across agency boundaries. In our 2005 report,
we stated that while we generally believe that the application of as
many of these practices as possible increases the likelihood of
effective collaboration, we also recognize that there is a wide range
of situations and circumstances in which agencies work together.
The One Health Initiative Discusses Collaboration to Address Zoonotic
and Animal Diseases:
Recognizing that zoonotic and animal diseases are interconnected,
several organizations--including the American Medical Association, the
American Veterinary Medical Association, and CDC--have taken steps to
support the One Health concept, which is a worldwide strategy for
expanding interdisciplinary collaboration and communications in all
aspects of health care for humans and animals. In 2007, the American
Veterinary Medical Association established the One Health Initiative
Task Force to study the feasibility of a campaign to facilitate
collaboration and cooperation among health science professions,
academic institutions, governmental agencies, and industries to help,
among other things, assess, treat, and prevent cross-species disease
transmission. In 2008, the task force framed the issue, stating that
the convergence of people, animals, and the environment has created a
new dynamic in which the health of each group is inextricably
interconnected.[Footnote 8] Examples of recent diseases causing
animal, human, environmental, or economic harm are described in
appendix IV.
The National Invasive Species Council Focuses on Collaboration among
Federal Agencies:
In 1999, an executive order established the National Invasive Species
Council, cochaired by the Secretaries of Agriculture, Commerce, and
the Interior.[Footnote 9] Its members are the Secretaries and
Administrators of 13 federal departments and agencies. The council was
charged with providing national leadership; seeing that the federal
invasive species activities are coordinated, complementary, cost-
efficient, and effective; and encouraging planning and action at
local, tribal, state, and regional levels. The range of invasive
species issues that the council is attempting to address includes live
animal imports that may bring diseases into the United States. The
executive order also required the Secretary of the Interior to
establish the Invasive Species Advisory Committee, a group of 30
nonfederal stakeholders from diverse constituencies (representing
state, tribal, local, and private concerns) around the nation, to
advise the council on invasive species issues. In 2008, the council
issued its most recent management plan for invasive species, the 2008-
2012 National Invasive Species Management Plan. The management plan
lists goals and performance elements that identify the federal agency
with the lead or participant role. It includes tasks pertaining to
pathogens or diseases. For example, one of the tasks is to develop a
process for identifying high-priority invasive plants, animals, and
plant or animal pathogens for agencies' actions. The council is
currently preparing a progress report on the implementation of the
2008-through-2012 plan, with an expected completion date of October
2010.
Recent Studies Have Discussed the Regulation of Live Animal Imports:
Studies by the National Academies of Sciences and others have found
significant deficiencies in the regulation of live animal imports that
may allow the introduction and spread of emerging zoonotic and animal
diseases. For example,
* A 2005 National Academies of Sciences report referred to a
"patchwork of federal policies and agencies with limited or ill-
defined jurisdiction" for the importation of wildlife, "a significant
gap in preventing and rapidly detecting emergent diseases," and "a
lack of coordinated federal oversight" over disease issues associated
with these animals.[Footnote 10] It found that wildlife are imported
daily with little or no health monitoring, increasing the likelihood
that zoonotic or animal diseases will enter the United States. The
report also noted that the animal health infrastructure "does not have
formal and comprehensive-based science and risk analysis systems for
anticipating potential challenges to animal health; ranking their
likelihood of occurring and likely severity; evaluating alternative
prevention, detection, and diagnostic systems; and using this
information to make appropriate policy decisions."
* A 2007 study by the Defenders of Wildlife, a nonprofit organization
that supports wildlife conservation, concluded that no law mandates a
comprehensive assessment of the potential risk from the importation of
a given nonnative species to human and animal health.[Footnote 11]
* In the November 2009 issue of CDC's journal, Emerging Infectious
Diseases, scientists reported on their study of mammal imports and
concluded that these imports provide numerous opportunities for
zoonotic pathogens to enter the United States. The study recommended
increased surveillance of imported animals that pose an increased risk
of harboring zoonotic pathogens.[Footnote 12]
Gaps in the Statutory and Regulatory Framework for Some Live Animal
Imports May Contribute to Disease Risks, according to Experts and
Agency Officials:
The statutory and regulatory framework governing live animal imports
has gaps that could allow the introduction and spread of zoonotic
diseases and diseases affecting wildlife, according to the experts we
surveyed, our discussions with agency officials, and scientific
studies on zoonotic and animal diseases. In particular, while APHIS
has regulations in place to protect agricultural animals from the risk
of diseases in live animal imports, CDC does not fully use its
statutory authority to prevent the importation of live animals that
may pose a risk of zoonotic diseases, and FWS generally does not
restrict the entry of imported wildlife that may pose disease risks.
APHIS Has Regulations to Protect U.S. Agriculture from Live Animal
Imports That Could Carry Disease:
APHIS has regulations to prevent the importation of live animals that
it has determined could pose a disease risk to agricultural animals.
For example, APHIS requires that commercial birds, such as those
imported for resale, breeding, or public display from countries other
than Canada be quarantined until found free of evidence of
communicable diseases of poultry. In addition, APHIS restricts the
importation of certain animals from certain countries, such as cattle
from countries where foot-and-mouth disease--a highly contagious viral
disease of cloven-hoofed animals such as cattle, swine, and sheep--has
been detected.
USDA's Office of Inspector General has performed several audits of
APHIS's live animal import processes in recent years. For example, an
August 2010 audit report identified weaknesses in the procedures APHIS
used to handle animals destined for a quarantine facility, beginning
with the precautions it took when receiving the animals into the
country and continuing to the conditions at the quarantine facilities.
[Footnote 13] According to the report, APHIS officials did not
identify these weaknesses because they did not exercise sufficient
oversight to ensure import and quarantine requirements were met.
Instead, they relied on the experience and expertise of port staff and
import center officials. In addition, a 2008 audit report on APHIS's
controls over live animal imports indicated that APHIS relies on
health certificates from the exporting country to certify the animal's
health condition, age, and other import requirements.[Footnote 14]
However, the report stated, APHIS does not have adequate processes to
determine whether individual problems detected represent a larger
systemic noncompliance that needs to be addressed by agency inspection
personnel or the exporting country. The Inspector General recommended
that APHIS establish an automated system of records to document and
track problems with live imported animals and report these problems to
key stakeholders. According to the Inspector General, APHIS planned to
implement this recommendation and to have officials analyze data from
the system each month and communicate with stakeholders regarding
corrective actions. According to agency officials, APHIS began using
this system--the Veterinary Services Process Streamlining System--in
June 2010.
We found that the agency has screening processes in place for the
imported animals it regulates that generally do not exist for other
imported animals regulated by other agencies. For example, as table 1
shows, for cattle from Canada or Mexico, APHIS is to assess whether
key diseases are present in the prospective exporting country, require
a health certificate from a veterinarian in the exporting country, and
visually inspect the cattle. In addition, for cattle not from Canada,
Mexico, Central America, or the West Indies, APHIS requires that the
cattle be quarantined to determine that they are free from disease. As
the table shows, CDC and FWS do not generally have similar processes
for the animals they regulate. (See app. V for additional types of
imported animals and federal agency disease risk screening
requirements.)
Table 1: Overview of Federal Agencies' Disease Risk Screening for
Selected Types of Imported Animals:
Type of imported animal: Cattle from Canada or Mexico[B];
Regulating agency[A]: APHIS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. ports of entry for disease: APHIS.
Type of imported animal: Commercial birds not from Canada;
Regulating agency[A]: APHIS; FWS;
Disease testing at quarantine facility: APHIS;
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. ports of entry for disease: APHIS.
Type of imported animal: Rodents from Africa;
Regulating agency[A]: CDC; FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
CDC[D];
Health certificate from exporting country: [C];
Visual inspection at U.S. ports of entry for disease: FWS[E].
Type of imported animal: Rodents not from Africa;
Regulating agency[A]: FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. ports of entry for disease: [C]c.
Type of imported animal: Amphibians;
Regulating agency[A]: FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. ports of entry for disease: [C].
Source: APHIS, CDC, and FWS regulations and guidance and discussions
with agency officials.
Note: FWS does not screen shipments of live animals for disease risk,
with the exception of imported salmon. FWS requires that all carriers
transporting wild mammals and birds to the United States have a
certificate of veterinary medical inspection signed by a veterinarian.
[A] CBP does not develop regulations for how to import an animal, so
it is not included in the list of regulating agencies.
[B] Cattle from Mexico are tested for tuberculosis and brucellosis and
checked for ticks prior to entry into the United States.
[C] APHIS, FWS, and CDC do not perform this screening process for this
imported animal.
[D] In 2003, CDC restricted the importation of rodents from Africa
based on concerns about monkeypox.
[E] FWS inspects shipments of rodents from Africa to assess if the
rodents are in compliance with CDC regulations.
[End of table]
Although APHIS does not regulate the importation of all live animals,
most of the experts responding to our survey supported a broader role
for APHIS. (See appendices VI and VII for more details on these
experts and their responses to the survey.) Specifically,
* Fifty-three of the 55 experts responding to our survey question
about APHIS's statutory and regulatory framework indicated that
changes are needed to prevent the importation of zoonotic and animal
diseases.
* Forty-eight of the 54 experts responding to a question in our survey
strongly or somewhat supported giving APHIS the authority to consider
the disease risk from wildlife as part of its existing risk assessment
process.
In 2008, APHIS took a step toward broadening its oversight of live
animal imports and becoming more responsive to emerging disease
threats. It issued a long-term strategy--known as VS2015--that
identifies key changes APHIS states are essential for the organization
in 2015, including (1) an expanded veterinary health mission and (2)
an increased focus on disease prevention, preparedness, detection, and
early response activities.[Footnote 15] Specifically,
Expanded veterinary health mission. Consistent with the One Health
concept, APHIS would expand its mission to address not only disease
issues that affect agricultural animals but also those associated with
zoonotic and wildlife diseases. According to the long-term strategy,
APHIS plans to:
* provide national leadership on the animal health component
associated with public health,
* work with wildlife entities to address health issues that affect
production agriculture and wildlife health, and:
* lend its veterinary assets (e.g., laboratory networks, stockpiles,
and response corps) and provide leadership in areas within its
expertise (e.g., epidemiology, surveillance, planning, risk analysis,
and modeling) when public health issues arise involving nonnative and
wildlife species.
Increased focus on disease prevention, preparedness, detection, and
early response activities. APHIS's goal is to reduce the frequency of
disease outbreaks that affect animals by emphasizing prevention and
preparedness. According to the long-term strategy, APHIS plans to:
* design and direct comprehensive national animal health surveillance
systems capable of finding foreign, emerging, and known diseases, and
of supporting international reporting and trade verification
requirements;
* investigate potential emerging animal health threats and apply
decision criteria to determine appropriate early responses;
* when needed, extend its prevention and early response efforts to
address animal health issues occurring outside of the United States,
including identifying, prioritizing, planning, and directing APHIS-
funded animal health surveillance and disease control or eradication
programs carried out overseas; and:
* assist other countries as they develop their animal health
capacities and provide leadership in the development of global animal
health standards and methods.
In support of VS2015, APHIS formed an internal work team that,
according to agency officials, is working on more comprehensive
training of APHIS staff; better use of technology for collaboration,
communication, and data tracking; and the engagement of industry as a
more active partner.
CDC Has Regulations for Some Live Animal Imports but Does Not Prevent
the Importation of Many Animals That May Pose a Risk of Zoonotic
Diseases:
CDC has regulations to prevent the importation of certain live animals
that may pose a previously identified disease risk to humans for some
diseases, such as rabies, but, according to agency officials, CDC's
regulations are limited to specific species and regions and do not
comprehensively prevent the importation of animals that are known to
present a high risk of zoonotic diseases. That is, CDC restricts
imports of some animals to prevent the introduction of specific
diseases: nonhuman primates, to prevent the spread of tuberculosis,
among other things; bats, to prevent the introduction of a variety of
infectious pathogens, including Ebola virus; rodents from Africa, to
prevent monkeypox; dogs and cats, to prevent zoonotic diseases in
general and rabies in dogs; and certain turtles, to prevent
Salmonella. In 2004, CDC banned the importation of birds from
specified countries based on the threat that imports from such
countries increased the risk that highly pathogenic avian influenza
may be introduced into the United States. In 2009, CDC rescinded this
ban. According to CDC's notice rescinding the ban, APHIS's import
restrictions on birds and poultry adequately address risks to human
health, and CDC will work closely with APHIS to monitor the
international situation regarding highly pathogenic avian influenza.
Even though CDC has these restrictions, imported animals that present
a zoonotic risk could enter into the United States. For example,
* While CDC generally requires proof of current rabies vaccination and
the confinement of most dogs for up to 30 days after vaccination, it
has received reports of large-volume shipments of puppies intended for
immediate resale. According to agency officials, these animals often
appear younger than the age on their accompanying documents, that is,
they are too young to receive an effective rabies vaccination, and
their vaccination status is questionable. In addition, according to
agency officials, if CDC finds at ports of entry that a dog was not
vaccinated for rabies, the agency allows it to enter, if the owner
agrees to keep the dog confined until it can be properly vaccinated
and then confined for an additional 30 days following vaccination to
prevent the potential spread of rabies. However, state and local
agencies that are to monitor confinement frequently lack resources to
do so, according to CDC officials.
* CDC's regulations do not require rabies vaccinations for cats, which
are highly susceptible to certain strains of rabies virus and can also
transmit the infection to humans.
In addition, experts responding to our survey told us that CDC
generally reacts only when a zoonotic disease problem arises. For
example, since the 1970s it has been well known that monkeypox, a
zoonotic disease, was endemic to Africa. However, according CDC
officials, CDC did not have a process to conduct a risk assessment on
the potential movement of monkeypox to the United States. Furthermore,
they said, if such a risk assessment process had been in place, CDC
might have restricted the importation of certain animals from Africa.
After a 2003 outbreak of monkeypox in the United States, which
sickened over 70 people, CDC restricted the importation of African
rodents and other animals that may carry the monkeypox virus. However,
CDC still allows the importation of rodents from countries outside of
Africa, and these imported rodents are not subject to examination to
determine whether they may be carrying zoonotic disease. Furthermore,
according to experts responding to our survey and CDC officials, the
importation of many other wildlife species is allowed with little or
no screening for zoonotic disease risks. For example, mice, rats, and
gerbils are not screened for zoonotic diseases, but the animal family
that includes these animals has been found to harbor 21 zoonotic
diseases.
CDC's regulation of live animal imports does not sufficiently protect
against zoonotic disease risks, according to the experts responding to
our survey and scientific studies. According to 50 of the 55 experts
responding to our survey question about CDC's statutory and regulatory
framework, changes are needed. For example, 40 of the 51 experts
responding to a question in our survey strongly or somewhat supported
giving CDC the authority to use pre-import screening, such as a
process that assesses disease risk by species and country and
determines allowable imports on the basis of that assessment. CDC is
considering other regulatory mechanisms that would allow CDC to
suspend the entry of animal imports into the United States from
designated foreign countries for public health reasons. Decisions to
suspend animal imports from designated foreign countries would be
based on the existence of a communicable disease in that country and
the likelihood that allowing such imports would increase the
likelihood of introducing disease into the United States. While these
regulatory mechanisms are not specifically "pre-import screening,"
these mechanisms may serve the same purpose.
The CDC officials we interviewed acknowledged gaps in the agency's
regulation of live animal imports for zoonotic diseases. To address
this problem, in 2007, CDC issued an advance notice of proposed
rulemaking on live animal imports to take steps to better prevent the
introduction of zoonotic disease into the United States. The questions
raised in the advance notice of proposed rulemaking include whether
CDC should (1) establish a regulation that maintains a list of species
or categories of high-risk animals for which importation is restricted
(e.g., either prohibited from entry or subject to certain
requirements), (2) apply these potential restrictions to broad
taxonomic groupings (e.g., all rodents) or individual species, (3)
issue these potential restrictions on a limited geographical basis
(i.e., certain countries or regions) or more broadly, and (4) make
rabies vaccination a requirement for entry into the United States for
all dogs and cats. CDC is currently analyzing the comments that it
received, revising the proposed language, and conducting economic
analyses. CDC expects to publish a notice of proposed rulemaking in
2011.
Although FWS Has Regulations for Injurious Wildlife, It Does Not
Restrict the Entry of Imported Wildlife That May Pose Disease Risks:
Under the authority of the Lacey Act, FWS has implemented regulations
to restrict imports of various types of nonnative live animals that
have been identified as injurious wildlife because, for example, they
could become invasive.[Footnote 16] However, FWS's regulations allow
other types of wildlife to enter the United States with little
assessment of the disease risk or health status of the animal, despite
the possible presence of diseases in animals that are not endemic to
the United States. For example, FWS does not restrict the importation
of live amphibians or assess their risk for the presence of disease,
creating a risk that the Bd fungus (Batrachochytrium dendrobatidis)--
which causes a highly contagious disease that is potentially fatal to
amphibians--will continue to enter and spread. The Department of the
Interior has been petitioned by the Defenders of Wildlife to ban
imports of live amphibians unless they are free of the Bd pathogen. As
of September 2010, the department planned to gather information from
the public before deciding whether to develop a regulation in response
to this petition. Furthermore, the Lacey Act's process to ban the
importation of injurious wildlife often requires too much time for the
process to be effective, according to FWS officials and experts
responding to our survey. On average, it takes about 4 years for FWS
to identify a species or group of species as injurious wildlife.
During this time, the animals in question continue to be imported into
the United States.
In addition, according to FWS officials, FWS inspectors visually
inspect some live wildlife imports, which may include observation for
signs of disease, but they are not veterinarians, and they do not have
expertise in detecting diseased animals. Furthermore, experts
responding to our survey said that visual inspections have limited
effectiveness in detecting diseased animals. They noted that it is
often difficult to distinguish between a healthy, uninfected animal
and an apparently healthy but infected animal, and even healthy
animals can carry pathogens that could harm other species or humans
but not harm the host.
In written comments to our survey, some experts reported that the
Lacey Act should be amended to better prevent the importation of live
animals that pose disease risks, while other experts said FWS should
use its current authority to improve its regulations in this area.
According to 52 of the 55 experts responding to our survey question
about FWS's statutory and regulatory framework, changes are needed. Of
the 53 experts who responded to our survey questions about specific
potential changes, 44 strongly or somewhat supported giving FWS the
authority to use pre-import screening, and 43 strongly or somewhat
supported having FWS expedite the process for classifying species as
injurious wildlife.
The Department of the Interior has taken preliminary steps that may
address gaps in FWS's regulation of live animal imports. In addition
to reviewing the petition to restrict amphibian imports, in January
2010, the Secretary of the Interior directed FWS to comprehensively
review statutory authorities and regulations to address existing
invasive species problems and to recommend potential tools to more
effectively prevent the introduction of new invasive threats.
According to Department of the Interior testimony provided at a March
2010 hearing on invasive species, FWS is reviewing several proposals
to create a more proactive and comprehensive approach to preventing
the spread of invasive species, including streamlining the evaluation
process, examining gaps that the Lacey Act's injurious wildlife
provisions leave in the listing process, revising its risk assessment
process, and supporting improved regulatory and educational
approaches.[Footnote 17]
Agencies Have Collaborated to Meet Their Responsibilities, but Experts
and Agency Officials Identified Barriers to Further Collaboration:
APHIS, CBP, CDC, and FWS have collaborated to meet their
responsibilities by taking actions in five areas--strategic planning,
joint strategies, written procedures, leveraging resources, and
sharing data--but experts responding to our survey and agency
officials we interviewed identified barriers to further collaboration
on live animal imports. As we have previously reported, agencies
encounter a range of barriers when they attempt to collaborate with
other agencies.[Footnote 18] Experts also identified the need for an
entity to help the agencies overcome these barriers.
Although Agencies Have Collaborated to Meet Common Goals, They Face
Barriers to Additional Collaboration:
Strategic planning. APHIS, CBP, CDC, and FWS have engaged in strategic
planning that recognizes the need for joint efforts to reduce the
risks of zoonotic and animal diseases from live animal imports.
Specifically, according to APHIS's 2007-through-2012 strategic plan,
it is working with CBP to reduce pest and disease threats at the
borders. The strategic plan also states that the agency's risk
assessment protocols must recognize the growing importance of zoonotic
diseases and the need to work with public health agencies to reduce
the risk of these diseases. Within APHIS, the program office of
Veterinary Services' strategic plan--VS2015--states that Veterinary
Services intends to meet future animal health challenges, such as
emerging zoonotic and animal diseases, by 2015. According to this
plan, Veterinary Services will expand its mission to include public
health concerns connected to any type of animal. In addition, the plan
states that Veterinary Services will work with wildlife entities to
address health issues that affect the health of both agricultural
animals and wildlife. Such collaboration would involve working with
CDC and FWS. According to CBP's strategic plan for 2009 through 2014,
CBP is actively pursuing new relationships with CDC to enhance CBP's
response to public health threats. CDC officials told us that it has
identified a strategic goal to enhance CDC's ability to prevent,
detect, and respond to zoonotic diseases associated with the
importation of live animals.[Footnote 19] Furthermore, according to
FWS's law enforcement strategic plan for 2006 through 2010, increased
coordination will be required with agencies (such as CDC and APHIS)
that are responsible for addressing linkages between wildlife trade
and the cross-border spread of zoonotic and animal diseases.
As we have previously reported, federal agencies can use their
strategic and annual performance plans as tools to drive collaboration
with other agencies and partners and establish complementary goals and
strategies for achieving results.[Footnote 20] While the agencies'
strategic planning addresses some concerns about the disease risk from
live imported animals, it does not specify how they will collaborate
to address the risk of disease from live animal imports. Such
specificity is difficult, according to several experts responding to
our survey, in part because the agencies' program priorities are based
on different missions, constituencies, and priorities. In particular,
experts responding to our survey noted that because each of the
agencies is focused on a different aspect of live animal imports, no
single entity has comprehensive responsibility for the zoonotic and
animal diseases risks posed by live animal imports. As one expert
noted, the principal barrier to collaboration is agencies' "failure to
take a broader view of the entire importation process," focusing
instead on only those components of the process each agency controls
under its statutory authority. As we have previously reported, when
agencies do not have a compelling rationale, such as legislation,
directives, or their perceptions of the benefits from collaboration,
it is difficult to overcome differences in missions and priorities and
to define and articulate a common outcome that is consistent with
their respective agency missions.[Footnote 21] However, as the One
Health concept recognizes, human and animal diseases are
interconnected. In this regard, the federal agencies that are
responsible for live animal imports appear to have a common goal--
preventing the introduction and spread of zoonotic and animal diseases
from live animal imports.
Joint strategies to reduce disease risk from imported live animals.
Several of the agencies we reviewed participated in joint strategies
to directly or indirectly address risks posed by imported live
animals. For example,
* APHIS, FWS, and the Department of Commerce's National Oceanic and
Atmospheric Administration jointly developed the National Aquatic
Animal Health Plan in 2008.[Footnote 22] Under this plan, the agencies
are to prepare coordinated research and development strategies and
budget recommendations to provide a framework for how the three
agencies should develop programs for diseases that affect the health
of aquatic animals, including finfish, crustaceans, and mollusks.
[Footnote 23] Activities addressed in the plan include (1) defining
pathogens of national concern; (2) preventing, controlling, and
managing pathogens or the diseases caused by those pathogens; (3)
describing and implementing surveillance programs; and (4) describing
strategies for continued outreach and awareness regarding national
aquatic animal health strategies and the plan. As of July 2010, an
advisory committee was being formed and a surveillance network had
been established for viral hemorrhagic septicemia, a deadly infectious
fish disease that affects 28 susceptible species of fresh and
saltwater fish and is a growing threat in the Great Lakes region.
While this plan is not fully launched, experts responding to our
survey commented that the effort has strengthened collaboration among
international, federal, and state partners. According to the
Department of the Interior, this plan is a model for federal
cooperation with regard to movement of aquatic animal diseases, and it
will be broadened to include amphibians and reptiles in the future.
* The National Invasive Species Council's 2008-2012 National Invasive
Species Management Plan, which is the council's primary coordination
tool for the prevention and control of invasive species, includes an
objective to expand the coordination of invasive species programs and
expenditures to leverage resources. It also directs the relevant
agencies to update the budget for federal agencies' expenditures
concerning invasive species. The council expects to report on the
plan's progress in October 2010. APHIS, CBP, and FWS have participated
in the council since its inception, while CDC has recently rejoined
the group.
* The Aquatic Nuisance Species Task Force--an intergovernmental
organization composed of 13 federal agencies, including FWS, APHIS,
and the Department of Commerce's National Oceanic and Atmospheric
Administration--is working to prevent and control aquatic nuisance
species.[Footnote 24] The task force was established by the
Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990.
[Footnote 25] In 2007, the task force developed a strategic plan for
2007 through 2012 that includes an objective for analyzing and
evaluating rapid response plans, including plans for foreign animal
disease events, to see how they could apply to reported introductions
of invasive species. In addition, the task force and the National
Invasive Species Council have identified various pathways by which
pathogens can be introduced into the country. These pathways include
container water in which aquatic animals are transported. According to
FWS officials, this container water can contain pathogens and, in some
instances, importers may not disinfect the water before disposing of
it.
* In 2009, APHIS, CBP, CDC, and several southern California animal
agencies formed a task force to address issues with the importation of
puppies, such as reducing and eliminating the illegal smuggling and
selling of dogs that are underage, in poor health, or do not have the
required health certifications.
These strategies are positive steps toward furthering the common goal
of preventing disease risk from live animal imports. As we have
previously reported, collaborating agencies need to establish
strategies that work in concert with those of their partners or are
joint in nature.[Footnote 26] Such strategies help in aligning the
partner agencies' activities, core processes, and resources to
accomplish the common outcome. In addition, all 56 experts responding
to our survey indicated that it is very or moderately important for
the federal agencies to collaborate to develop a coordinated national
strategy to better align activities, processes, and resources.
According to the experts responding to our survey, the agencies
develop joint strategies to respond quickly to emergencies as they
arise, but the agencies tend to develop joint strategies in reaction
to an identified problem, rather than in anticipation of it. For
example, one expert noted that the outbreak of monkeypox in 2003
spread to prairie dogs and subsequently to humans. The expert, as well
as CDC officials, commented that although this outbreak was addressed
promptly, it might have been avoided if officials had considered the
risk of this disease and taken appropriate actions before an outbreak
occurred.
Several studies and CDC officials also cited the need for a formal
joint strategy to prevent the introduction of zoonotic and animal
diseases, such as a comprehensive risk assessment system, and for
responding to health risks, such as having plans and resources for
early detection and response. Experts also commented that the
development of such a system should focus on how live animal imports
affect the health of humans, agricultural animals, and wildlife.
Moreover, the 2005 National Academies of Sciences report noted that
the animal health infrastructure does not have formal and
comprehensive science-based risk analysis systems for anticipating
potential challenges to animal health. In addition, experts responding
to our survey commented that a comprehensive risk assessment system
should be established on the basis of an analysis of imported animals
to assess the threat that these animals pose. The experts stated that
the components of this risk assessment system might include an
analysis of the species' exporting country, diseases of concern,
typical packaging and delivery times, and methods of shipment of
concern, among other things. Suggested uses of the risk assessment
include targeting passengers and cargo most likely to be carrying
prohibited animals, and making decisions based on this information.
According to experts responding to our survey, agencies could use this
information to determine whether the importation of particular species
from certain countries should be banned and which animals require pre-
import screening, including the increased use of disease testing and
quarantine at the ports of entry. For example, such risk assessment
could be similar to APHIS's process, which assesses the disease risk
within defined regions on a consistent and scientific basis and
evaluates the animal health status of countries or regions requesting
approval to import live animals into the United States.
Written procedures for ports of entry. The four agencies have written
procedures to follow when working with other federal agencies at ports
of entry. In particular, three of the agencies--APHIS, CBP, and FWS--
signed a memorandum of understanding (MOU) on forfeiture that lays out
the specific roles and responsibilities each has for seizing,
quarantining, and disposing of birds that are brought into the United
States in violation of laws or regulations. In addition, APHIS and CBP
signed an MOU that outlines the agencies' roles for entry and
inspection of the imported animals that APHIS regulates. Two of the
four agencies--APHIS and CBP--also have other types of written
procedures, while CDC is developing guidance, according to CDC
officials. Specifically,
* APHIS has guidance that outlines the procedures and responsibilities
that its division of Veterinary Services is to follow with CBP in
handling legally and illegally imported pet and performing birds
arriving as passenger baggage, from when the birds arrive at the port
of entry until they are released to enter into the United States or
refused entry. For example, the guidance specifies which birds are
eligible for entry and which agency is responsible for (1)
transferring birds to a quarantine station and (2) obtaining supplies
for handling the birds.
* CBP has a standard operating procedure that informs its staff at
ports of entry of procedures to follow in handling shipments of APHIS-
regulated live fish. Specifically, if the species has been approved by
APHIS for import, CBP staff are to allow it to proceed; if the species
has not already been approved, then the staff are to hold the shipment
for Veterinary Services; if the species is not regulated by APHIS, CBP
is to hold the shipment for USDA's Agricultural Marketing Service,
which administers programs that facilitate the marketing of U.S.
agricultural products.
* CBP and APHIS have written guidance for coordinating their
processing of live animals arriving at Canadian land border ports of
entry.
* CBP and APHIS have written procedures for the importation of
livestock at four Mexican land border ports of entry and certain
cattle at all Mexican land border ports of entry.
* CBP has written procedures to help its port staff make appropriate
referrals to other agencies.
* According to CDC officials, the agency is developing internal
standard operating procedures to distribute to its staff at ports of
entry on CDC-regulated animals. The officials said the first such
guidance will be on how to handle imported turtles, although the
officials did not know when this guidance would be issued.
While the agencies have developed some written procedures, officials
told us that they do not have written procedures for all animal
imports. In the absence of written procedures, agencies collaborate
informally at ports of entry on how to handle incoming shipments.
Specifically, according to FWS headquarters officials we spoke with,
FWS and CDC port officials regularly coordinate on physical
inspections of live animals they both regulate, such as nonhuman
primates, turtles and tortoises, and bats. For example, according to
CBP officials, when turtles are imported into the United States, CBP
usually contacts FWS inspectors. According to FWS officials, if the
type of turtle being imported is not banned, FWS may contact CDC or
APHIS for inspection or further action if it believes there is
potential for another type of violation, such as undersized turtles
that pose a risk for Salmonella (CDC) or turtles with ticks that may
have Heartwater infection (APHIS), a potentially fatal disease to
cattle. In addition, officials at ports of entry from CBP and APHIS
told us that they usually have access to an official from another
agency to speak with if questions arise about a shipment. For example,
CBP officials at several ports told us they contact APHIS, CDC, and
FWS officials informally through e-mails, telephone calls, and in
person in order to verify that procedures are being followed for live
animal imports they regulate. Finally, some experts responding to our
survey noted that officials at some ports have cultivated effective
collaborative relationships.
However, we have previously reported that by using informal
coordination mechanisms, agencies may rely on relationships with
individual officials to ensure effective collaboration and that these
informal relationships could end once personnel move to their next
assignments.[Footnote 27] Without written procedures, agencies' roles
and responsibilities are not clearly defined. We reported that
agencies can strengthen their commitment to work collaboratively by
articulating their roles and responsibilities in formal documents to
facilitate decision making. Such formal documents can include MOUs,
interagency guidance, or interagency planning documents, signed by
senior officials in the respective agencies. These documents can
clarify which agencies will be responsible for particular activities,
and how they will organize their joint and individual efforts.
Experts responding to our survey generally agreed that uncertainty
about agencies' roles and responsibilities for imported animals is a
barrier, particularly for species that are (1) not regulated for
disease risk by any agency or (2) regulated by more than one agency.
For example, several of the experts noted that federal regulations do
not address the risk to human and animal health posed by the
importation of most nonnative wild animals, such as non-African
rodents, and that where regulations do allow for the import of
nonnative wild animals, no disease assessment is made. In addition,
the agencies do not have written procedures for all species that are
regulated by more than one agency, such as reptiles. For example,
APHIS and FWS do not have a written procedure to coordinate their
shared responsibilities for regulating reptiles--which are a source of
Salmonella infection in humans and also carry disease-causing
parasites.
Leveraging resources. APHIS, CBP, CDC, and FWS have taken steps to
leverage resources--staff and funding--to enhance their ability to
address disease risks associated with live animal imports. For example,
* APHIS has provided CDC headquarters with a liaison to represent
USDA's interests on a broad range of topics, including live animal
imports, and shares information with CDC on zoonotic diseases. CDC
officials stated that they are currently exploring the possibility of
establishing a DHS liaison.
* APHIS, FWS, the U.S. Coast Guard, and the Department of Commerce's
National Oceanic and Atmospheric Administration worked together to
launch two national campaigns designed to help the public understand
its role in preventing the introduction and spread of zoonotic and
animal diseases. The first campaign, called "Stop Aquatic
Hitchhikers," is directed toward the public who engage in aquatic
activities to, among other things, prevent the spread of invasive
species, zoonotic diseases, and animal pathogens. The second campaign,
"Habitattitude," is directed toward, among others, pet owners to
promote environmentally friendly behaviors, such as not releasing
nonnative pets into the environment.
While the agencies have worked together to leverage their resources,
they do not separate the amount of funding and level of staff for live
animal imports from other agency activities.[Footnote 28] As a result,
they may not be able to determine whether their funding and staff are
sufficient, and the extent to which they could be leveraged in a
collaborative effort. Furthermore, the four agencies vary
significantly in the extent to which they have resources for
regulating live animal imports, according to agency officials and
experts responding to our survey. For example, APHIS has staff who
perform services--such as review of information provided by foreign
governments--to support assessments of the risk of live animal imports
into the United States. In addition, APHIS has quarantine facilities
that inspect and test imports for diseases prior to an animal being
released into the United States. In contrast, FWS does not have
similar resources for assessing risk and has no quarantine facilities.
The experts responding to our survey also noted that resource
constraints, such as limited facilities and staff, make it difficult
for the four agencies to devote enough time to collaboration when they
face time constraints in completing daily tasks. The experts
responding to our survey noted that under these conditions it is
challenging for the agencies to collaborate.
As we have previously reported, collaborating agencies should identify
the human, information technology, physical, and financial resources
needed to initiate or sustain their collaborative effort.[Footnote 29]
By assessing their relative strengths and limitations, collaborating
agencies can look for opportunities to obtain additional benefits that
would not be available if they were working separately. Forty-nine of
the 54 experts who responded to a survey question about leveraging
resources strongly or somewhat supported leveraging APHIS resources to
assist FWS in preventing the importation of animal diseases, and 48
indicated that APHIS resources should be leveraged to assist CDC in
preventing the importation of zoonotic diseases. In addition,
according to APHIS officials we spoke with, APHIS has expertise that
could assist FWS and CDC in assessing disease risks in other
countries. Furthermore, 50 of 56 experts responding to our survey
reported that it is very or moderately important for federal agencies
to collaborate to develop a plan to maximize existing resources.
Data sharing. As we have reported, agencies can facilitate
collaboration by coordinating data information systems for carrying
out shared objectives.[Footnote 30] According to CBP officials, the
agency is developing the International Trade Data System (ITDS) within
the Automated Commercial Environment (ACE) system. ACE will serve as a
Web-based portal for exchanging trade information among federal
agencies that share the responsibility for facilitating international
trade.[Footnote 31] Currently, APHIS and FWS can access data, such as
importer data and other related information, but cannot enter
information into the system. In its 2009 Report to Congress on the
International Trade Data System, CBP stated that agencies
participating in ITDS, including APHIS, CDC, and FWS, have formed
working groups to ensure, among other things, that data elements are
identified and specified to the detail necessary in shipment
information. For example, according to agency officials, a working
group of agencies that use data on or oversee imported eggs was
formed. While agencies do not yet have access to an integrated data
system, agency officials and experts responding to our survey
identified efforts to share data. For example, FWS has shared its data
with CDC to identify possible health risks from imports of nonnative
wildlife. In addition, according to APHIS officials, the agency is
beginning to implement terminology in its trade database that is
consistent with CBP's so that the agencies can share information about
incoming shipments.
According to CBP officials, APHIS, CDC, FWS and other agencies will
ultimately be able to enter and retrieve information using the ACE
system. However, CBP officials do not have a target date for when
APHIS, CBP, CDC, and FWS would have full operational access to ACE,
and they stated that a unified data system has been a goal since 1995;
ITDS has been ongoing since 2006. In addition, while the agencies
participating in ITDS have formed workgroups for some types of trade
data, APHIS, CBP, CDC, and FWS have yet to jointly determine which
data elements are needed for them to effectively oversee live animal
imports, according to CBP officials. As a result, it is unclear
whether the data in the completed system will meet interagency needs.
Until ITDS is completed, the agencies responsible for live animal
imports continue to collect and rely on data that are not easily
shared. Experts responding to our survey pointed out that the agencies
have not linked their data systems so that they can share information
on live animal shipments, as well as track violations. In particular,
APHIS and FWS maintain separate databases that contain information on
shipments of animals that they regulate, and CBP maintains a database
on all imports, including live animals. However, the three databases
do not interface, so that agencies regulating the same shipment of
live animals can have access to the same information at the same time.
Experts Responding to Our Survey Identified the Need for an Entity to
Help the Agencies Overcome Barriers to Collaboration:
The experts responding to our survey, including federal and state
agency officials, also generally pointed to the need for some formal
entity to help overcome barriers to achieving their common interest in
preventing the importation of animals that may be carrying zoonotic or
animal diseases. For example, one expert observed that such an entity
could help the agencies identify gaps and inconsistencies in the
overall regulation of live animal imports for zoonotic and animal
diseases and enable the agencies to collaborate regularly, and 53 of
56 experts responding to our survey reported that it was very or
moderately important for the agencies to collaborate to identify gaps
in regulations related to live animal imports. We asked the experts
about the extent to which they would support the creation of a
workgroup to help the federal agencies collaborate in preventing the
importation of animals that may be carrying zoonotic and animal
diseases. Most of the experts responding to this question--52 of 55--
strongly or somewhat supported the creation of such a workgroup. (See
app. VII for the experts' detailed responses.)
APHIS, CDC, and FWS Have Reported Some Information on Their
Performance on Live Animal Imports:
APHIS and FWS routinely report information on their performance to
oversee the importation of live animals, and CDC has reported
performance information for one species. CBP does not report any
performance information on live animal imports. As we have previously
reported, agencies can use performance information to make decisions
oriented toward improving results.[Footnote 32] In that same report,
we stated that federal managers can use performance information to
identify performance problems and look for solutions, develop
approaches that improve results, and make other important management
decisions, including those that affect future strategies, planning and
budgeting, identifying priorities, and allocating resources.
APHIS. APHIS has reported performance information on live animal
imports that aligns with the goals it established in its strategic
plan for its Veterinary Services program office.[Footnote 33]
Specifically, APHIS measured progress on its performance goal of
protecting the United States from the occurrence of adverse animal
health events. For example, APHIS reported that in fiscal year 2009 it
conducted risk assessments on the animal health status of at least 14
foreign countries that have been denied access to U.S. import markets.
In fiscal year 2009, APHIS conducted risk analyses in the European
Union for the presence of exotic Newcastle disease, highly pathogenic
avian influenza, and classical swine fever--a highly contagious virus
that can cause high mortality rates in swine populations.
Additionally, APHIS reported that in fiscal year 2009 it did not have
any disease outbreaks associated with imports of animals from foreign
regions that APHIS has reviewed for animal health status.
CBP. CBP has not reported any performance information on live animal
imports. As we previously noted, however, it has agencywide and field
operations strategic plans that recognize the agency's role in
preventing the importation of zoonotic and animal diseases.[Footnote
34]
CDC. In general, CDC has not developed comprehensive performance
information on live animal imports. However, CDC has reported on
mortality rates for one live animal import--nonhuman primates. In its
2008 annual performance report, CDC reported that this mortality rate
was less than 1 percent for fiscal years 2005, 2006, 2007, and 2008,
down from about 20 percent before 1989. CDC attributed this
improvement to its instituting facility inspections and new infection
control requirements. In that same report, CDC reported on its
performance goal of maintaining low mortality in nonhuman primates
imported to the United States for science, exhibition, and educational
purposes to, for example, reduce the potential exposure of humans to
zoonotic diseases, such as Ebola and tuberculosis.[Footnote 35]
FWS. FWS reported performance information dealing with live wildlife
imports in its 2008 operational plan. In this plan, FWS reported on
the number of injurious wildlife interdicted at international ports of
entry and land borders (270), number of shipments that contained
injurious wildlife (54), the number of wildlife shipments physically
inspected (31,000), and the number of interdicted wildlife shipments
(4,000). This information supports FWS's performance goal of
preventing the unlawful import, export, and interstate commerce of
foreign fish, wildlife, and plants in its law enforcement strategic
plan for 2006 through 2010.[Footnote 36]
Conclusions:
With the growth in emerging zoonotic diseases, as well as the risk of
other animal diseases in an increasing global marketplace, federal
agencies play an increasingly important role in preventing the
introduction of these diseases into the United States. However, as we
found, gaps in the statutory and regulatory framework across federal
agencies increase the risk that some live animal imports will carry
diseases into the United States, as was the case for African rodents
carrying monkeypox in 2003. Of the three agencies responsible for
regulating live animal imports for disease risks--APHIS, CDC, and FWS--
only APHIS comprehensively assesses an animal's disease risk or health
status, and APHIS has issued a strategy for expanding its role in
overseeing nonagricultural animals. In contrast, CDC and FWS have gaps
in their oversight of disease risks from live animal imports. CDC's
regulations direct its focus to particular species or diseases, and
the agency does not have a process for identifying risks from some
emerging diseases that could be imported in live animals. FWS
generally does not restrict the entry of imported wildlife that may
pose disease risks and does not generally assess the disease risk or
health status of these animals. Experts responding to our survey
indicated that changes are needed in FWS's statutory authority, its
regulations, or both. Recognizing such issues, APHIS, CDC, and FWS
have separately proposed additional actions to better protect against
disease risks from live imported animals, including actions that may
involve pre-import screening.
The four agencies we reviewed have collaborated to meet their
responsibilities to some extent. They have recognized the need to work
together in their strategic planning, formulated some joint
strategies, developed some written procedures for collaboration,
leveraged resources in some situations, and shared some data on live
animal imports. However, experts responding to our survey and agency
officials identified barriers to further collaboration in each of
these areas. These barriers--such as different program priorities and
unclear roles and responsibilities--are inherent when multiple
agencies have related responsibilities. Furthermore, the agencies have
largely incompatible data systems, and it appears that some time will
pass before these issues are resolved or ACE is able to offer a
conduit for data sharing among APHIS, CBP, CDC, and FWS. Because the
agencies have not determined which data they will need, it is also
unclear whether the data elements in the latest version of ACE will
meet interagency needs. While these barriers pose a challenge, the
agencies still have a common interest in preventing the introduction
of diseases from live animal imports. Recognizing this common
interest, the experts responding to our survey, including federal and
state officials, reported that increased collaboration through some
type of formal entity, such as a workgroup, is needed to help overcome
these barriers. Furthermore, the experts and the National Academies of
Sciences noted that the absence of a risk assessment system for
comprehensively addressing disease risks from live animal imports
could result in zoonotic and animal diseases entering the United
States.
Recommendations for Executive Action:
To better prevent the importation of live animals carrying zoonotic
and animal diseases and improve the responsible agencies'
collaboration, we recommend that the Secretaries of Agriculture,
Health and Human Services, Homeland Security, and the Interior take
the following two actions:
* Develop and implement, in coordination with the relevant federal
agencies, a strategy for their collaboration in preventing the
importation of animals that may be carrying zoonotic and animal
diseases into the United States. This strategy should help the
agencies:
- Identify and resolve differing program priorities so that the
agencies can work collaboratively to ensure that live animal imports
posing a risk of zoonotic and animal diseases do not enter the United
States. Such efforts could include collaborative methods for
prevention, such as a comprehensive risk assessment system for live
animal imports.
- Lay out individual agency roles and responsibilities for all live
animal imports, including how a collaborative effort will be led.
- Identify resources dedicated to live animal imports and leverage
these resources to the extent possible to support the agencies'
efforts.
- Examine ways to systematically share data on shipments of live
animal imports that are regulated by more than one agency until ACE is
able to offer data-sharing capabilities to each agency.
- Explore the need for any additional legislative or executive
authority to develop and implement this strategy such as the authority
to establish a coordinating entity (e.g., an interagency workgroup).
* Jointly determine, in collaboration with CBP, the data elements that
APHIS, CDC, and FWS will need ACE to contain, so that the agencies can
effectively oversee all live animal imports.
Agency Comments and Our Evaluation:
We provided a draft of this report to USDA, the Department of Health
and Human Services, DHS, and the Department of the Interior for their
review and comment. In their written comments, USDA, DHS, and the
Department of the Interior generally agreed with our findings and
recommendations. The Department of Health and Human Services only
provided technical comments, which we included as appropriate.
USDA agreed with our recommendations and commented that it appreciates
our emphasis on increasing the level of collaboration among federal
agencies. USDA also commented that it believes a key component to
successfully leveraging the agencies' strengths lies in finding new
ways to approach these opportunities and that it therefore supports
the formation of an interdepartmental steering committee for the
oversight of animal imports as soon as possible. USDA also stated that
in collaboration with the committee and other departments, it would
seek to determine the need for creating additional authority, clarify
the scope of existing authority, and implement current authority more
efficiently through expanded memorandums of agreements or other
interdepartmental cooperative measures. Furthermore, USDA stated that
it would report to us on the components of a successful strategy for
addressing our recommendations. USDA's written comments are presented
in appendix VIII.
DHS also agreed with our recommendations and stated that it would work
with the other departments to gauge interest in development of a joint
strategic implementation plan. In addition, DHS described its existing
collaborative efforts with APHIS, CDC, and FWS, with respect to live
animal import processes and agencies' data needs. DHS's written
comments are presented in appendix IX, and we incorporated DHS's
technical comments as appropriate.
The Department of the Interior agreed with our findings and
recommendations. In addition, the department provided the following
comments:
* While GAO asked experts whether a workgroup should be created to
help federal agencies collaborate, GAO did not consider whether an
existing body could perform this function. The use of an existing
interagency body to serve as a coordinating entity to help federal
agencies prevent the importation of animals that may be carrying
zoonotic and animal diseases was not mentioned in experts' responses
to the first round of our survey, which was the basis for asking this
question. Placing a coordinating entity for live animal imports within
an existing interagency body may help avoid duplication of effort. If
the agencies determine that it is appropriate to place the
coordinating entity for live animal imports within an existing
interagency body, this response would be consistent with our
recommendation.
* The report does not refer to possible confusion that may be caused
by multiple agencies having related authorities, and the report could
have provided more information on agency outreach to the public.
However, as the department noted, the issue of public outreach was not
a central question of our review.
* The report should emphasize the National Aquatic Animal Health Plan
as a model for federal cooperation with regard to movement of aquatic
animal diseases. We believe the report recognizes this plan, stating
that it is an example of federal agencies' joint strategies to reduce
disease risks from live animal imports, and provided more information
on the plan's relevant efforts.
The Department of the Interior's written comments and our responses
are presented in appendix X.
We are sending copies of this report to the appropriate congressional
committees; the Secretaries of Agriculture, Health and Human Services,
Homeland Security, and the Interior; the Director, Office of
Management and Budget; and other interested parties. The report is
also available at no charge on GAO's Web site at [hyperlink,
http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. Key contributors to this report are
listed in appendix XI.
Signed by:
Lisa Shames:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
This report examines the (1) potential gaps in the statutory and
regulatory framework governing live animal imports, if any, that may
allow the introduction and spread of zoonotic and animal diseases; (2)
extent to which the U.S. Department of Agriculture's Animal and Plant
Health Inspection Service (APHIS), Department of Homeland Security's
Customs and Border Protection (CBP), Department of Health and Human
Services' Centers for Disease Control and Prevention, (CDC), and
Department of the Interior's Fish and Wildlife Service (FWS)
collaborate to meet their responsibilities and face barriers, if any,
to collaboration; and (3) the performance information that the
responsible agencies have reported on live animal imports.
To identify potential gaps in the statutory and regulatory framework,
we reviewed relevant statutes, including the Animal Health Protection
Act, the Public Health Service Act, the Lacey Act, and the Endangered
Species Act of 1973; the agencies' implementing regulations; and
agency documents on the procedures employed to regulate the
importation of live animals from APHIS, CBP, CDC, and FWS. We
interviewed officials from these agencies at agency headquarters and
ports of entry. Using information from interviews of agency officials
and agency documents, we compared the level of inspection and review
used by each of the agencies to regulate the importation of various
types of animals, including mammals, birds, fish, and reptiles. In
addition, we reviewed scientific studies on zoonotic and animal
diseases, including studies by the National Academies of Sciences.
We also reviewed APHIS and FWS data on the number, type, and exporting
country of all imported animals regulated by these two agencies that
entered the United States for fiscal years 2005 through 2009. For the
APHIS and FWS data, we analyzed documentation related to the data and
worked with agency officials to identify any potential data problems
and determined that the data were sufficiently reliable for the
purposes of providing background information in this report. We
analyzed the APHIS and FWS data to determine the number of animals
imported each fiscal year, the countries from which animals are most
frequently imported, and the purposes for which animals are most
frequently imported.
To examine the extent to which the agencies collaborate to meet their
responsibilities and face barriers, if any, to collaboration, we
reviewed strategic plans, memorandums of understanding, standard
operating practices, and other policies and protocols from each of the
four agencies. We also reviewed joint strategies developed by
interagency working groups, such as the National Invasive Species
Council's management plan and the National Aquatic Animal Health Plan.
We interviewed agency headquarters officials and agency officials at
ports of entry, including airports in Atlanta, Georgia; Baltimore,
Maryland; Los Angeles, California; New York, New York; and Washington,
D.C.; and the Otay Mesa, California, and San Ysidro, California, land
border crossings between California and Mexico, on ongoing and planned
efforts for coordination. We obtained documentation on the allocation
of staff resources. Finally, we assessed the agencies' collaboration
efforts according to practices we identified that can help enhance and
sustain collaboration among federal agencies.
To help address the first two objectives, we conducted a two-round
survey to identify (1) potential gaps in the current statutory and
regulatory framework that may allow for the introduction of and spread
of zoonotic and animal diseases, (2) how well the responsible federal
agencies work together to meet their responsibilities, and (3)
potential barriers to collaboration. The process we followed is based
on GAO guidance for identifying experts for panels or other work
requiring expertise in a specific area. We identified potential
experts on disease risk posed by live animal imports who had primary
employment responsibilities related to or dependent on live animal
imports, authored peer-reviewed papers, presented at professional
conferences, provided testimony on the subject matter to Congress, or
were recognized by their peers as experts on live animal imports. We
then selected experts from federal and state government, academia,
nongovernmental organizations, and industry to obtain a broad spectrum
of views. We conducted pretests with several survey recipients prior
to distributing both surveys. The goals of the pretests were to ensure
that (1) the questions were clear and unambiguous and (2) terminology
was used correctly. The first round of the survey consisted of five
open-ended questions (questions that solicit additional information)
in which experts provided their opinions on gaps in the current
statutory and regulatory framework, how well the responsible federal
agencies work together to meet their responsibilities, and potential
barriers to collaboration. In the first round, we received responses
from 33 out of the 39 experts contacted, resulting in a response rate
of about 85 percent.
We performed a content analysis of the responses to the open-ended
questions in order to compile a list of gaps in the statutory and
regulatory framework, corrective actions to address those gaps, the
effectiveness of federal agencies' collaboration, and barriers to
federal agencies' collaboration mentioned by the experts. We used this
list to construct the second round of survey questions. These were
primarily closed-ended (questions with a set of answers to choose
from). We expanded our second round of the survey to include
additional experts recommended by those responding to our first round
and other experts. Of the 64 experts we contacted, 56 provided
responses, resulting in a response rate of about 88 percent in the
second round.
The first round of the survey was conducted from January through
February 2010, and the second round was conducted from April through
May 2010. To the extent possible, we followed up with experts to
clarify their responses. The questions and aggregated responses are
presented in appendix VII. Responses to the survey express only the
views of the experts.
To examine what performance information the responsible agencies
report on live animal imports in their planning and reporting
documents, we reviewed strategic plans, operational plans, mission
statements, and annual performance plans and reports from APHIS, CBP,
CDC, and FWS. Review of these documents allowed us to determine the
extent to which these agencies set out performance goals, established
measures to assess performance toward achieving those goals, and
reported on the effectiveness of their efforts for activities directly
involving live animal imports. We analyzed the extent to which each of
the four agencies used performance objectives and measures and reports
on the effectiveness of these activities for live animal imports.
We conducted this performance audit from August 2009 through October
2010, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Agencies' Processes for Overseeing Live Animal Imports:
This appendix describes the processes that the U.S. Department of
Agriculture's Animal and Plant Health Inspection Service, Department
of Homeland Security's Customs and Border Protection, Department of
Health and Human Services' Centers for Disease Control and Prevention,
and Department of the Interior's Fish and Wildlife Service use for
processing live animal imports for entry into the United States.
APHIS:
APHIS restricts the importation of live animals that it has determined
may pose a disease risk to agricultural animals, such as cattle,
horses, poultry, sheep, and swine. APHIS has developed import
processes that depend on the level of risk associated with either the
type of animal or country of export. APHIS has a memorandum of
agreement with CBP whereby CBP refers live animal shipments to APHIS
port veterinarians for inspection. APHIS port veterinarians visually
inspect all applicable live animal shipments and review the import
documentation, which may include a declaration of importation,
vaccination records, and health certificates from a licensed
veterinarian in the country of export. APHIS requires that most
imported animals that it regulates be accompanied by a health
certificate. A licensed veterinarian in the country of export inspects
the animals and then signs the health certificate certifying the
health status of the animals and whether U.S. requirements are met.
The most common type of certification states that the animals to be
imported were inspected and determined to be free of communicable
disease.
If the animals do not pass inspection, the animals are either
quarantined and then reinspected or are refused entry. For example, if
cattle from Mexico fail a visual inspection for tick-free status, they
are dipped and quarantined for 10 to 14 days and then presented for a
second inspection. If ticks are found during the second inspection,
the cattle will be rejected, branded as rejected, and sent back to
Mexico. For those animals that require quarantine, such as horses,
importers are required to reserve space at either an APHIS-managed
animal import center or an APHIS-approved private quarantine facility.
During the quarantine, the animal undergoes disease testing. Animals
that test positive for a regulated disease are refused entry into the
United States.
APHIS has established processes for specific animals and exporting
countries. For example, for imports from Canada and Mexico, APHIS has
established streamlined processes, such as eliminating requirements
for permits or quarantine for some animals. Additionally, commercial
birds--birds that are imported for resale, breeding, or public
display--entering the United States through a land border from Canada
are not required to have a permit or undergo quarantine, as long as
they are accompanied by a veterinary health certificate from a
Canadian government veterinarian. Commercial birds not imported from
Canada are required to be quarantined and tested for avian influenza.
In some instances, APHIS restricts the importation of animals based on
risk. For example, APHIS restricts the import of commercial birds from
countries with highly pathogenic avian influenza and cattle from
countries with foot-and-mouth disease. An example of species-specific
regulation can be found with imports of fish susceptible to Spring
viremia of carp; such species include the common carp and goldfish.
APHIS checks that these imports have the required documents, visually
checks the shipments to ensure that they are not leaking or emitting
an atypical odor, and assesses the animals' disease status if the
shipment is chosen for inspection.
APHIS relies on a manual process to account for and track the movement
of the live animal imports from CBP to APHIS inspection at the border
and to their final destination. According to agency officials, APHIS
is developing an automated data system, the Veterinary Services
Process Streamlining System, which is expected to replace the existing
manual, paper-oriented process and will track live animal imports,
exports, interstate movement of animals, and veterinary accreditation.
According to APHIS officials, the new system became operational in
June 2010 and will be able to track live animal imports in calendar
year 2011.
CBP:
CBP assists APHIS, CDC, and FWS in enforcing their import regulations,
has the primary authority to inspect imports, and seeks to interdict
shipments of contraband and the illegal importation of live animals
and other products while facilitating the flow of legal trade and
travel. If there is a problem with a particular shipment, CBP will
levy the appropriate fines and penalties.
CBP requires importers to file entry documents that describe the
merchandise, quantity, value, and exporting country, among other
things, and a Harmonized Tariff Schedule classification, which is a
schedule of tariffs associated with individual products. All entry
documents must be filed before the imported goods are allowed to be
released into U.S. commerce. For faster release, importers or their
brokers may provide CBP with pre-arrival notification of an incoming
shipment by submitting information on the shipment locally or
electronically submitting information on the shipment to either CBP's
legacy computer system, the Automated Commercial System, or the
Automated Commercial Environment, the agency's replacement system. CBP
screens the incoming information through its information systems to
verify if the shipment meets the criteria or requires further
examination or inspection. According to agency officials, if CBP then
determines that further inspection is needed by APHIS, FWS, or CDC,
CBP will hold the shipment, provide minimal custodial care, and
contact the relevant agency. According to agency officials, CBP holds
the shipment until an agency representative of the other government
agency is available to inspect and release it. According to agency
officials, if an agency representative is unavailable, then CBP denies
entry of the shipment.
CDC:
CDC restricts the importation of live animals that it has determined
pose a risk to public health and bans the importation of certain
animals. All live animal imports on which CDC has placed import
restrictions are to be visually examined by the inspecting personnel
to ensure that the animal has no obvious signs of infectious diseases.
Dogs and cats that show signs of infectious diseases are to be
examined, tested, or treated by a licensed veterinarian at the owner's
expense. According to agency officials, other CDC-regulated animals
that show signs of infectious diseases, such as nonhuman primates, are
inspected at an import facility. For many of the animal imports
restricted by CDC, the agency requires a permit for importation.
Imports that are restricted to these purposes and require a permit
include African rodents, civets, live bats,[Footnote 37] and shipments
of more than six turtles with a shell length of less than 4 inches.
For nonhuman primates only, CDC requires that persons or facilities
importing such animals be registered with CDC. If the shipment has the
required documents, it is released to a registered importer. Nonhuman
primates are quarantined for 31 days after entry on the importer's
premises. No permit is required for the importation of dogs and cats.
Generally dogs greater than 3 months of age from countries where
rabies is present must have a valid certificate of vaccination against
rabies signed by a licensed veterinarian showing that the dog was
vaccinated greater than or equal to 30 days prior to import. If the
dog is more than 3 months old and does not have a vaccination
certificate, the dog may be admitted if the owner agrees to confine
the dog until vaccination, vaccinate the dog within 4 days upon
arrival at the ports of entry, and then confine the dog for an
additional 30 days following vaccination. If the dog is more than 3
months old and has a certificate showing a vaccination done less than
30 days prior to arrival, the dog may be admitted if the owner signs
an agreement to confine the dog for the balance of 30 days. If the dog
is less than 3 months old, the dog may be admitted if the owner signs
an agreement to confine the dog until it is 3 months old, and then
have it vaccinated and confined for an additional 30 days. Confinement
is defined as restricting the animal to a building or other enclosure,
in isolation from other animals and people, except for contact
necessary for its care. If the dog is allowed out of the enclosure,
the owner must muzzle the dog and use a leash. After agreeing to these
conditions, the dog is released and the agreement is forwarded to a
CDC quarantine station. The rabies vaccination requirement does not
apply to dogs that have been exclusively in a rabies-free area for at
least 6 months immediately preceding arrival or since birth. Cats are
only required to pass visual inspection.
FWS:
FWS has restrictions on the importation of certain wildlife.
Specifically, FWS restricts the importation of injurious wildlife and
threatened or endangered species and related species for which
international trade is regulated under international agreements.
According to agency officials, FWS inspectors work with public health
officials and other federal inspectors at ports of entry to enforce
wildlife regulations and ensure the safety and legality of wild animal
imports. According to agency officials, FWS inspectors coordinate with
the other agencies to ensure that the requirements for animals that
are jointly regulated by FWS and APHIS and/or CDC have been met, such
as APHIS prohibitions on hedgehogs that can transmit foot-and-mouth
disease or CDC inspection requirements for small turtles. Importers of
wildlife shipments generally must provide FWS with a 48-hour notice of
the shipment's arrival. Commercial importers of wildlife must be
licensed by FWS.
According to agency officials, the following processes occur at the
port of entry. The shipment is declared at the port of entry, and FWS
reviews the accuracy and consistency of the required documents, which
depend on species and can include declaration forms, permits, import/
export licenses, invoices, and packing lists. Following documentation
review, FWS inspectors then decide if a physical inspection is
required. Common reasons for inspecting shipments include the type of
live animal, exporting country, importer history, intelligence on the
shipment, outcome of documentation review, or random selection. If the
shipment fails a physical inspection, FWS either seizes the animals
with the violations and releases the remainder of the shipment or
seizes the entire shipment, based on the type of animal or violation.
If the shipment passes physical inspection and has the required
documentation, then FWS clears the shipment. If the shipment is not
selected for physical inspection and the required documentation is
present, then FWS clears the shipment.
[End of section]
Appendix III: Data on the Number of Live Animals Imported in Recent
Years:
APHIS and FWS provide information on the number of live animal
imports, the purpose of the animal import, and the country from which
the import has been shipped for recent years. APHIS's Import Tracking
System records the number of APHIS-regulated animals imported by
fiscal year. FWS's Law Enforcement Management Information System
records the number of FWS-regulated animals imported by fiscal year.
The APHIS and FWS data systems may overlap because both agencies
regulate some of the same species, such as certain fish and birds. CDC
does not maintain a database on live animal imports.
APHIS:
Table 2 shows the number of APHIS-regulated animals imported for
fiscal years 2005 through 2008.
Table 2: Number of Live Animal Imports Regulated by APHIS, Fiscal
Years 2005 through 2008:
Type of animal: Swine;
Fiscal year: 2005: 8,114,546;
Fiscal year: 2006: 8,638,151;
Fiscal year: 2007: 9,511,180;
Fiscal year: 2008: 10,374,424.
Type of animal: Fish;
Fiscal year: 2005: 0[A];
Fiscal year: 2006: 0[A];
Fiscal year: 2007: 7,754,013;
Fiscal year: 2008: 7,537,149.
Type of animal: Koi carp;
Fiscal year: 2005: 0[A];
Fiscal year: 2006: 0[A];
Fiscal year: 2007: 3,370,220;
Fiscal year: 2008: 4,211,454.
Type of animal: Poultry;
Fiscal year: 2005: 10,412,974;
Fiscal year: 2006: 9,396,557;
Fiscal year: 2007: 6,312,181;
Fiscal year: 2008: 3,769,190.
Type of animal: Goldfish;
Fiscal year: 2005: 0[A];
Fiscal year: 2006: 0[A];
Fiscal year: 2007: 2,086,047;
Fiscal year: 2008: 3,540,739.
Type of animal: Cattle;
Fiscal year: 2005: 1,506,998;
Fiscal year: 2006: 2,374,679;
Fiscal year: 2007: 2,291,255;
Fiscal year: 2008: 2,494,891.
Type of animal: Bison;
Fiscal year: 2005: 906;
Fiscal year: 2006: 12,025;
Fiscal year: 2007: 19,307;
Fiscal year: 2008: 27,586.
Type of animal: Horses;
Fiscal year: 2005: 43,553;
Fiscal year: 2006: 37,426;
Fiscal year: 2007: 30,202;
Fiscal year: 2008: 26,301.
Type of animal: Ornamental fish;
Fiscal year: 2005: 0[A];
Fiscal year: 2006: 0[A];
Fiscal year: 2007: 498,456;
Fiscal year: 2008: 7,254.
Type of animal: Other[B];
Fiscal year: 2005: 3,225;
Fiscal year: 2006: 7,132;
Fiscal year: 2007: 4,215;
Fiscal year: 2008: 1,949.
Type of animal: Unknown[C];
Fiscal year: 2005: 70,496;
Fiscal year: 2006: 20,686;
Fiscal year: 2007: 10,426;
Fiscal year: 2008: 1,852.
Type of animal: Total;
Fiscal year: 2005: 20,152,698;
Fiscal year: 2006: 20,486,656;
Fiscal year: 2007: 31,887,502;
Fiscal year: 2008: 31,992,789.
Source: APHIS Import Tracking System.
Note: At the time of our review, fiscal year 2008 was the last year
for which verified data were available.
[A] As discussed below, the agency began regulating the import of fish
in 2006.
[B] Other animals include sheep, goats, elk, deer, moose, caribou,
reindeer, llamas, alpacas, pet birds, zoological animals, camels,
exotics, and reptiles.
[C] According to APHIS, data in this category could not be identified
or verified at the species level.
[End of table]
Prior to fiscal year 2007--when APHIS began recording large numbers of
fish imports--APHIS recorded that imports of live swine, poultry, and
cattle were about 99 percent of its regulated live animal imports.
About 94 percent of these imports came from Canada, with the remainder
generally coming from Mexico. These animals were primarily imported
for slaughter plants or farms. By fiscal year 2008, imports of fish
represented about half of the total number of APHIS live animal
imports, with the largest suppliers of these animals, including China,
Malaysia, Hong Kong, the United Kingdom, Thailand, and Singapore,
primarily importing these fish for commercial purposes. According to
agency officials, APHIS reported large numbers of fish beginning in
fiscal year 2007 because of a new regulation on the import of fish,
which previously were not required to have APHIS permits and thus were
not counted by APHIS. In August 2006, APHIS issued regulations
requiring importers of species of fish that are susceptible to Spring
viremia of carp, a contagious, fatal viral disease, to obtain an APHIS
permit prior to importation into the United States.
FWS:
Table 3 shows the number of FWS-regulated live wildlife imported from
2005 through 2009. FWS officials attributed the decline of live animal
imports in fiscal year 2009 in part to the recession, as well as the
increase in FWS user fees, which included new handling fees.
Table 3: Number of Live Animal Imports Regulated by FWS, Fiscal Years
2005 through 2009:
Type of animal[A]: Crustaceans;
Fiscal year: 2005: 11,021,121;
Fiscal year: 2006: 12,457,692;
Fiscal year: 2007: 12,649,912;
Fiscal year: 2008: 10,097,441;
Fiscal year: 2009: 9,232,677.
Type of animal[A]: Amphibians;
Fiscal year: 2005: 5,360,493;
Fiscal year: 2006: 5,050,831;
Fiscal year: 2007: 4,594,679;
Fiscal year: 2008: 4,164,832;
Fiscal year: 2009: 3,575,934.
Type of animal[A]: Mollusks;
Fiscal year: 2005: 1,013,423;
Fiscal year: 2006: 1,145,732;
Fiscal year: 2007: 1,438,519;
Fiscal year: 2008: 1,950,384;
Fiscal year: 2009: 1,444,248.
Type of animal[A]: Insects;
Fiscal year: 2005: 1,037,268;
Fiscal year: 2006: 971,078;
Fiscal year: 2007: 1,105,246;
Fiscal year: 2008: 1,714,148;
Fiscal year: 2009: 1,208,392.
Type of animal[A]: Reptiles;
Fiscal year: 2005: 1,591,606;
Fiscal year: 2006: 1,440,749;
Fiscal year: 2007: 1,469,399;
Fiscal year: 2008: 1,187,679;
Fiscal year: 2009: 946,243.
Type of animal[A]: Corals;
Fiscal year: 2005: 711,747;
Fiscal year: 2006: 699,348;
Fiscal year: 2007: 980,559;
Fiscal year: 2008: 840,657;
Fiscal year: 2009: 768,931.
Type of animal[A]: Mammals;
Fiscal year: 2005: 78,488;
Fiscal year: 2006: 115,910;
Fiscal year: 2007: 237,767;
Fiscal year: 2008: 591,322;
Fiscal year: 2009: 289,843.
Type of animal[A]: Spiders;
Fiscal year: 2005: 215,289;
Fiscal year: 2006: 241,627;
Fiscal year: 2007: 224,872;
Fiscal year: 2008: 203,170;
Fiscal year: 2009: 175,505.
Type of animal[A]: Worms;
Fiscal year: 2005: 1,810,855;
Fiscal year: 2006: 839,689;
Fiscal year: 2007: 322,656;
Fiscal year: 2008: 119,268;
Fiscal year: 2009: 162,412.
Type of animal[A]: Birds;
Fiscal year: 2005: 299,983;
Fiscal year: 2006: 225,244;
Fiscal year: 2007: 246,710;
Fiscal year: 2008: 240,250;
Fiscal year: 2009: 159,795.
Type of animal[A]: Echinoderms (e.g., starfish, sea urchin);
Fiscal year: 2005: 29,553;
Fiscal year: 2006: 48,156;
Fiscal year: 2007: 22,626;
Fiscal year: 2008: 40,111;
Fiscal year: 2009: 133,924.
Type of animal[A]: Miscellaneous[B];
Fiscal year: 2005: 2,818,367;
Fiscal year: 2006: 2,695,776;
Fiscal year: 2007: 2,087,462;
Fiscal year: 2008: 2,097,805;
Fiscal year: 2009: 1,649,071.
Type of animal[A]: Unknown[C];
Fiscal year: 2005: 900;
Fiscal year: 2006: 246;
Fiscal year: 2007: 116;
Fiscal year: 2008: 42;
Fiscal year: 2009: 145.
Type of animal[A]: Subtotal;
Fiscal year: 2005: 25,989,093;
Fiscal year: 2006: 25,932,078;
Fiscal year: 2007: 25,380,523;
Fiscal year: 2008: 23,247,109;
Fiscal year: 2009: 19,747,120.
Type of animal[A]: Fish;
Fiscal year: 2005: 205,539,504;
Fiscal year: 2006: 227,125,679;
Fiscal year: 2007: 200,289,950;
Fiscal year: 2008: 181,531,235;
Fiscal year: 2009: 157,377,941.
Type of animal[A]: Total;
Fiscal year: 2005: 231,528,597;
Fiscal year: 2006: 253,057,757;
Fiscal year: 2007: 225,670,473;
Fiscal year: 2008: 204,778,344;
Fiscal year: 2009: 177,125,061.
Source: FWS's Law Enforcement Management Information System.
Note: This table does not include data for imported animals that were
recorded by weight rather than number. FWS recorded some shipments
that were not individually counted in fiscal years 2005 through 2009,
and those shipments that were measured by weight included the
following species: fish, crustaceans, echinoderms, mollusks,
miscellaneous, amphibians, insects, annelids, corals, mammals,
arachnids, and reptiles.
[A] Animals are grouped by animal class. Animal classes are scientific
groupings of animals based on common characteristics.
[B] According to FWS, the agency uses this category for grouping
multiple species together or when all that is known is the class.
[C] This category represents imports of multiple nonprotected species.
[End of table]
In fiscal year 2009, wildlife imports came from a variety of countries
and were primarily imported for commercial purposes. For example,
Singapore and Thailand were the leading exporters for fish, Haiti and
Taiwan for crustaceans, amphibians from Taiwan, mollusks from
Indonesia and the Philippines, insects from Costa Rica, reptiles from
Vietnam, corals from Indonesia, mammals from Canada and the
Netherlands, birds from Senegal, spiders from Ghana, and worms from
Canada and France.
Although mammals represent a small percentage of FWS-recorded imports
of live wildlife excluding imports of fish--ranging from 0.3 percent
in 2005 to 2.5 percent in 2008--they are commonly associated with the
spread of zoonotic diseases. The following describes FWS-regulated
imported mammals and their associated disease risks, according to FWS
data for fiscal year 2009:
* Bovines, including bison and water buffalo, with 201,561 imported
primarily from Canada for commercial purposes. The animal family that
includes bovines has been found to harbor 15 zoonotic diseases,
including Ebola and Rift Valley fever.
* Mice, rats, and gerbils, with 141,060 imported primarily from the
Netherlands for commercial purposes. The animal family that includes
these animals has been found to harbor 21 zoonotic diseases.
* Old world monkeys, with 24,106 imported primarily from China for
biomedical research. The animal family that includes these animals has
been found to harbor 13 zoonotic diseases, including yellow fever and
Marburg disease.
* Chinchillas, with 4,302 imported primarily from Canada and the
Netherlands for commercial purposes. The animal family that includes
chinchillas has been found to harbor 2 zoonotic diseases: rabies and
monkeypox.
[End of section]
Appendix IV: Examples of Recent U.S. Animal Disease Outbreaks Causing
Animal, Human, and Environmental or Economic Harm:
Infectious agent: Bovine spongiform; encephalopathy; (mad cow disease);
United States outbreaks: Three cases of bovine spongiform
encephalopathy in cattle have been identified from 2003 through 2006,
one of which was caused by an imported cow;
Mode of transmission: Transmitted to cattle through contaminated feed
containing, for example, the spinal cord or brain matter of infected
cattle. Transmitted to humans through eating the contaminated meat of
infected cattle;
Animal and human harm: Bovine spongiform encephalopathy is transmitted
to humans causing a variant form of Creutzfeldt-Jakob disease;
From 2003 through 2007, three fatal variant Creutzfeldt-Jakob cases
occurred in two United Kingdom citizens and one Saudi Arabian citizen
who were residing in the United States. They were likely exposed to
bovine spongiform encephalopathy in their native countries;
Environmental or economic harm: An estimated $11 billion in losses in
U.S. exports resulted from bovine spongiform encephalopathy-related
restrictions in the United States.
Infectious agent: Chytridiomycosis;
United States outbreaks: May have been introduced through a shipment
to northern California in the late 1950s or early 1960s; Has been
linked with serious declines almost everywhere that amphibians are
present, including North America;
Mode of transmission: Caused by an aquatic fungal pathogen,
Batrachochytrium dendrobatidis (Bd); Bd appears to be spreading
through the international amphibian trade, the international pet
trade, the bait trade, and inadvertently in produce;
Animal and human harm: Bd is an emerging infectious disease of
amphibians, especially frogs;
Environmental or economic harm: Bd is responsible for a large disease-
caused loss of biodiversity.
Infectious agent: Exotic Newcastle disease;
United States outbreaks: An outbreak of the disease occurred in the
western United States from September 2002 through September 2003;
Mode of transmission: Transmitted by infected birds, contaminated
people, and contaminated equipment to other birds;
Animal and human harm: The 2002-through-2003 outbreak resulted in
nearly 4.5 million birds destroyed; Humans can be infected with
Newcastle virus and infection generally causes conjunctivitis (i.e.,
pink eye). Most often, those affected are workers in the poultry
industry or laboratory technicians who handle the virus;
Environmental or economic harm: As a result of the 2002-through-2003
outbreak, over 50 countries imposed some form of trade restriction
against United States poultry exports. The outbreak caused an
estimated $395 million loss in direct and indirect trade. Federal
dollars allocated to the eradication effort are estimated at $138.9
million.
Infectious agent: Highly pathogenic avian influenza;
United States outbreaks: In February 2004, an outbreak of highly
pathogenic avian influenza was detected and reported in a flock of
7,000 chickens in south-central Texas. This was the first outbreak of
highly pathogenic avian influenza in 20 years; Note: Some strains of
highly pathogenic avian influenza do not have the same implication for
human health. The highly pathogenic avian influenza strain in the
Texas outbreak only affects poultry, not humans;
Mode of transmission: Transmitted by infected birds;
Animal and human harm: By mid-2005 in southeast Asia, more than 140
million birds had died or been destroyed; Despite control measures,
the disease continues to spread, resulting in animal and human
fatalities (more than half of the human cases have been fatal). Many
in the scientific community are concerned about a global pandemic of
human avian influenza;
Environmental or economic harm: By mid-2005 in southeast Asia, losses
to the poultry industry were estimated to be in excess of $10 billion.
Infectious agent: Viral hemorrhagic septicemia;
United States outbreaks: First outbreak occurred in 1988 and affected
marine fish in the Pacific Northwest; Outbreaks of a more virulent
strain of viral hemorrhagic septicemia began occurring in United
States waters of the Great Lakes in 2006;
Mode of transmission: Transmission is by infected fish, tissues from
infected fish, and water that has contained infected fish; Ballast
water is considered the most likely original vector;
Animal and human harm: Viral hemorrhagic septicemia is known to cause
fish mortality, particularly for rainbow trout, turbot, and herring,
in short periods of time; APHIS currently lists 28 susceptible species;
Environmental or economic harm: Although large numbers of fish loss
have been reported, long-term economic loses are unclear; To meet
federal and state regulations, aquaculture facilities incur additional
testing expenses to ensure their fish are healthy.
Infectious agent: West Nile virus;
United States outbreaks: Emerged in 1999 and has been found throughout
the continental United States;
Mode of transmission: Transmitted by mosquitoes and can cause
encephalitis in humans;
Animal and human harm: West Nile virus in the United States has
infected 29,766 people, resulting in 1,166 fatalities from 1999
through August 10, 2010;
Environmental or economic harm: The estimated economic impact of the
disease in the United States from 1999 through 2007 was $400 million.
Source: GAO analysis of literature.
Note: CDC estimates that for every case of zoonotic disease reported
to CDC, there are likely hundreds to thousands more cases that go
unreported. For CDC to become aware of a zoonotic disease, the
following must occur: (1) The infected person has to have contact with
an animal and know that it was imported; (2) the person has to become
ill enough to go to a doctor and remember to tell the doctor that he
was exposed to a certain animal; (3) the doctor has to request a lab
test, and if a cause of disease is found, the doctor has to know if it
is a reportable disease in his state; (4) the state has to report the
findings to CDC in a timely manner so that an investigation can be
done to determine the source of the infection.
[End of table]
[End of section]
Appendix V: Overview of Federal Agencies' Disease Risk Screening for
Selected Types of Imported Animals:
Type of imported animal: Cattle from Canada or Mexico[B];
Regulating agency[A]: APHIS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS.
Type of imported animal: Cattle not from Canada or Mexico;
Regulating agency[A]: APHIS;
Disease testing at quarantine facility: APHIS;
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS[D].
Type of imported animal: Canadian horses;
Regulating agency[A]: APHIS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS.
Type of imported animal: Horses not from Canada;
Regulating agency[A]: APHIS;
Disease testing at quarantine facility: APHIS;
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS.
Type of imported animal: Domesticated dogs;
Regulating agency[A]: APHIS; CDC;
Disease testing at quarantine facility: APHIS[E];
Assessment by U.S. agency of disease presence in exporting country:
APHIS; CDC;
Health certificate from exporting country: APHIS[F]; CDC[G];
Visual inspection at U.S. port of entry for disease: APHIS[E]; CDC.
Type of imported animal: Commercial birds not from Canada;
Regulating agency[A]: APHIS; FWS;
Disease testing at quarantine facility: APHIS;
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS.
Type of imported animal: Commercial birds from Canada;
Regulating agency[A]: APHIS; FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
APHIS;
Health certificate from exporting country: APHIS;
Visual inspection at U.S. port of entry for disease: APHIS.
Type of imported animal: Turtles;
Regulating agency[A]: APHIS[H]; CDC[I]; FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. port of entry for disease: FWS[I].
Type of imported animal: Reptiles, not including turtles;
Regulating agency[A]: FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. port of entry for disease: [C].
Type of imported animal: Rodents from Africa;
Regulating agency[A]: CDC; FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
CDC[K];
Health certificate from exporting country: [C];
Visual inspection at U.S. port of entry for disease: FWS[L].
Type of imported animal: Rodents not from Africa;
Regulating agency[A]: FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. port of entry for disease: [C].
Type of imported animal: Amphibians;
Regulating agency[A]: FWS;
Disease testing at quarantine facility: [C];
Assessment by U.S. agency of disease presence in exporting country:
[C];
Health certificate from exporting country: [C];
Visual inspection at U.S. port of entry for disease: [C].
Source: APHIS, CDC, and FWS regulations and guidance and discussions
with agency officials.
Note: FWS does not screen shipments of live animals for disease risk,
with the exception of imported salmon. FWS requires that all carriers
transporting wild mammals and birds to the United States have a
certificate of veterinary medical inspection signed by a veterinarian.
[A] CBP does not develop regulations for how to import an animal, so
it is not included in the list of regulating agencies.
[B] Feeder cattle from Mexico, which are cattle imported for the
purpose of feeding for a period of time prior to slaughter, are tested
for tuberculosis and brucellosis and checked for ticks prior to entry
into the United States. Breeding cattle are tested for tuberculosis
and brucellosis and checked for ticks.
[C] APHIS, FWS, and CDC do not perform this type of screening for this
imported animal.
[D] Cattle are visually inspected at the quarantine facility.
[E] APHIS requires that dogs imported to handle livestock must be
inspected and quarantined at the ports of entry and tested for
tapeworm.
[F] APHIS requires that dogs imported from countries where screwworm
is thought to exist have a health certificate from a veterinarian from
the exporting country stating that the dog is free from screwworm.
[G] CDC generally requires certification of rabies vaccination for
dogs imported from countries identified by CDC as places where rabies
is present.
[H] APHIS does not have any regulations in place to assess the disease
risk of turtle imports. APHIS prohibits the importation of the
following types of turtles: leopard tortoise, African spurred
tortoise, and Bell's hingeback tortoise.
[I] CDC does not have any regulations in place to assess the disease
risk of turtle imports. CDC restricts the import of turtles with a
carapace shell length of 4 inches or less to less than 7; it requires
a permit for a shipment of more than six turtles that will be used for
science, exhibition, or education.
[J] FWS does not screen all shipments of turtles for disease risk. It
requires 48-hour notification of the shipment and shipment declaration
forms, which provide a description of the animals in the shipment. FWS
visually inspects some live animal shipments (e.g., 18 percent in
fiscal year 2008). The purpose of the inspection is to determine
whether the animals are on the Lacey Act's list of prohibited
injurious animals or are prohibited from entry based on the Endangered
Species Act of 1973 and international agreements to regulate
threatened or endangered species, such as the Convention on
International Trade in Endangered Species of Wild Fauna and Flora--as
well as to assess whether the turtles are in compliance with APHIS and
CDC regulations.
[K] In 2003, CDC restricted the importation of rodents from Africa.
[L] FWS inspects shipments of rodents from Africa to assess whether
the rodents are in compliance with CDC regulations.
[End of table]
[End of section]
Appendix VI: Experts Responding to Our Survey on Live Animal Imports:
This appendix provides the affiliations of federal and state
government, academics, nongovernmental, and industry experts who
completed one or both rounds of a two-round survey from January 2010
to May 2010 to identify potential gaps in the current statutory and
regulatory framework, how well the responsible federal agencies work
together to meet their responsibilities, and appropriate corrective
actions.
* Biological Scientist, Centers for Epidemiology and Animal Health,
Veterinary Services, U.S. Animal and Plant Health Inspection Service:
* Senior Advisor for Science and Policy, U.S. Department of Homeland
Security:
* State Public Health Veterinarian and Assistant State Epidemiologist,
Infectious Disease Epidemiology, Office of Public Health, Louisiana
Department of Health and Hospitals:
* Director, Veterinary Regulatory Support, Plant Protection and
Quarantine, U.S. Animal and Plant Health Inspection Service:
* Veterinary Medical Officer, Western Region Import and Export
Coordinator, Veterinary Services, U.S. Animal and Plant Health
Inspection Service:
* Professor, Department of Veterinary Pathology, College of Veterinary
Medicine, University of Georgia:
* Policy Director, Global Invasive Species Programme:
* Director, Science Center, Natural Resources Defense Council:
* Virginia M. Ullman Professor, Arizona State University:
* Executive Vice President and General Director for Living
Institutions, Wildlife Conservation Society:
* Director of Regulatory Affairs, Taylor Shellfish Company, Inc.
* Veterinary Medical Officer, National Wildlife Health Center, U.S.
Geological Survey:
* National Director, Veterinary Medicine, PETCO Animal Supplies, Inc.
* Senior Veterinarian, Los Angeles County Department of Public Health,
Veterinary Public Health and Rabies Control Program:
* Associate Vice President, Conservation Medicine, Wildlife Trust:
* Professor and Director, Southeastern Cooperative Wildlife Disease
Study, University of Georgia:
* Chief, Division of Management Authority, International Affairs
Program, U.S. Fish and Wildlife Service:
* Special Agent in Charge, Office of Law Enforcement, U.S. Fish and
Wildlife Service:
* Professor of Epidemiology, Department of Pathobiological Sciences,
School of Veterinary Medicine, University of Wisconsin-Madison:
* Branch Chief, Convention on International Trade in Endangered
Species Operations, Division of Management Authority, U.S. Fish and
Wildlife Service:
* Executive Director, Global Initiative for Food Systems Leadership
and Professor, School of Public Health and College of Veterinary
Medicine, University of Minnesota:
* Director, National Center for Import and Export, Veterinary
Services, U.S. Animal and Plant Health Inspection Service:
* Director of International Conservation, Defenders of Wildlife:
* Senior Wildlife Veterinarian and Supervisor, California Department
of Fish and Game:
* Fish and Wildlife Biologist, Branch of Aquatic Invasive Species,
U.S. Fish and Wildlife Service:
* Wildlife Health Specialist, Arizona Game and Fish Department:
* Professor of International Health and of Medicine, Boston University:
* Public Health Veterinarian, National Association of State Public
Health Veterinarians:
* Associate Professor of Biology, and Director, Program in Sustainable
Development and Conservation Biology, Department of Biology,
University of Maryland:
* Branch Chief, Quarantine and Border Health Services Branch, U.S.
Centers for Disease Control and Prevention:
* Chief, Branch of Aquatic Invasive Species, U.S. Fish and Wildlife
Service:
* Professor, School for Global Animal Health, Executive Director,
Washington Animal Disease Diagnostic Laboratory, Director, Animal
Health Research Center, Washington State University College of
Veterinary Medicine:
* Professor of Pathology, Western University of Health Sciences
College of Veterinary Medicine:
* Vice President of Veterinary Services, Chicago Zoological Society:
* Branch Chief, Agriculture Production, Office of Health Affairs, U.S.
Department of Homeland Security:
* Assistant Director, Live Animal Imports, National Center for Import
and Export, U.S. Animal and Plant Health Inspection Service:
* Chairman, Health and Regulatory Committee, American Horse Council:
* Amphibian and Reptile Coordinator, Association of Fish and Wildlife
Agencies:
* Research Branch Chief, Arizona Game and Fish Department:
* Wildlife Veterinary Specialist, Wildlife Disease Laboratory,
Michigan Department of Natural Resources and Environment:
* Vice President, Government Affairs, Association of Zoos and
Aquariums:
* Executive Director, Association of American Veterinary Medical
Colleges:
* Epidemiologist, (formerly) Johns Hopkins Bloomberg School of Public
Health, Johns Hopkins University:
* Operations Specialist, Delta Air Lines, Inc.
* Manager, Live Animals and Perishables, Special Cargo Standards,
International Air Transport Association:
* Coordinator, Wildlife Management Division, Arizona Game and Fish
Department:
* Postdoctoral Research Fellow, Center for Forest Sustainability,
School of Forestry and Wildlife Sciences, Department of Biological
Sciences, Auburn University:
* General Manager, Koppert Biological Systems, Inc.
* Supervisor, Wildlife Health Section, Wildlife Disease Laboratory,
Michigan Department of Natural Resources:
* Eastern Region Import Export Coordinator, Veterinary Services, U.S.
Animal and Plant Health Inspection Service:
* Assistant Director Zoonotic, Influenza and Vector Borne Disease
Unit, Bureau of Communicable Disease, New York City Department of
Health and Mental Hygiene:
* Assistant Research Professor, Ecology and Evolutionary Biology,
Brown University:
* Assistant Director for Field Programs, Global Health Program,
Wildlife Conservation Society:
* Outreach Coordinator, Fisheries and Habitat Conservation, Branch of
Invasive Species, U.S. Fish and Wildlife Service:
* State Public Health Veterinarian and Section Manager, Zoonoses and
Special Projects Section, Michigan Department of Community Health:
* Acting Director Agriculture Policy and Planning, Agriculture
Programs and Trade Liaison, Office of Field Operations, U. S. Customs
and Border Protection:
* Vice President, Conservation and Science, Lincoln Park Zoo:
* Director, Planning, Finance, and Strategy Staff, Veterinary
Services, U.S. Animal and Plant Health Inspection Service:
* Corporate Vice President, Veterinary and Professional Services,
Charles River Laboratories, Inc.
* Public Health Veterinarian, Zoonotic and Vector-borne Disease
Program, Office of Environmental Health and Safety, Washington State
Department of Health:
[End of section]
Appendix VII: GAO Survey Questions and Responses:
Expert Survey: Live Animal Imports into the United States and the
Spread of Animal and Zoonotic Diseases:
We conducted a two-round survey to identify (1) potential gaps in the
current statutory and regulatory framework that may allow for the
introduction of and spread of zoonotic and animal diseases, (2) how
well the responsible federal agencies work together to meet their
responsibilities, and (3) potential barriers to collaboration. We
identified potential experts on disease risk posed by live animal
imports who had primary employment responsibilities related to or
dependent on live animal imports, authored peer-reviewed papers,
presented at professional conferences, provided testimony on the
subject matter to Congress, or were recognized by their peers as
experts on live animal imports. We then selected experts from federal
and state government, academia, nongovernmental organizations, and
industry to obtain a broad spectrum of views. The first round of the
survey consisted of five open-ended questions (questions that solicit
additional information) in which experts provided their opinions on
gaps in the current statutory and regulatory framework, how well the
responsible federal agencies work together to meet their
responsibilities, and potential barriers to collaboration. In the
first round, we received responses from 33 out of the 39 experts
contacted, resulting in a response rate of about 85 percent. We
performed a content analysis of the responses to the open-ended
questions in order to compile a list of gaps in the statutory and
regulatory framework, corrective actions to address those gaps, the
effectiveness of federal agencies' collaboration, and barriers to
federal agencies' collaboration mentioned by the experts. We used this
list to construct the second round of survey questions. These were
primarily closed-ended (questions with a set of answers to choose
from). We expanded our second round of the survey to include
additional experts recommended by those responding to our first round
and other experts. Of the 64 experts we contacted, 56 provided
responses, resulting in a response rate of about 88 percent in the
second round. The first round of the survey was conducted from January
through February 2010, and the second round was conducted from April
through May 2010. While this appendix displays only the quantitative,
closed-ended responses, we also relied on the responses to the
qualitative, open-ended questions to inform our findings in this
report. The views expressed by the experts responding to our surveys
do not necessarily represent the views of GAO.
Round One Questions:
1. What weaknesses or gaps, if any, do you feel exist in the statutory
and regulatory framework governing live animal imports with respect to
preventing the introduction of zoonotic and animal diseases?
2. What corrective actions should be taken to address these weaknesses
or gaps?
3. Federal agencies responsible for live animal imports include Animal
and Plant Health Inspection Service (APHIS), Centers for Disease
Control and Prevention (CDC), Customs and Border Protection (CBP), and
Fish and Wildlife Service (FWS). How effectively (or not) do the
federal agencies collaborate to meet their responsibilities?
4. What barriers exist for collaboration among federal agencies?
5. During our site visits with regulatory authorities, we heard about
their goal to facilitate efficient cargo and passenger import
processing while preventing prohibited animals and animal products to
be imported into the United States. What is the best way to ensure
that statutes and regulations prevent importation of zoonotic and
animal diseases without impeding commerce and passenger travel?
6. If you consulted with others within your agency, firm, or
organization when answering the questions, how many others did you
consult?
Your Background:
7. Please briefly describe your expertise. Include professional
credentials, membership and roles in professional associations, titles
of publications, congressional testimonies, primary employment
responsibilities related to or dependent on live animal imports, etc.
Round Two Questions and Responses:
Section 1: Participant Status:
1. What is your full name?
2. What is your title?
3. What is the name of your organization?
4. What is your telephone number?
5. What is your e-mail address?
6. Did you complete a survey in round 1 or are you a new participant
in Round 2?
* I completed a survey in Round #1 - Skip to question #8:
* I am a new participant in Round #2 - Continue to question #7:
7. What is your background or expertise related to live animal imports?
Section 2: Animal and Plant Health Inspection Service (APHIS):
8. Based on your knowledge of APHIS's statutory and regulatory
framework, do you believe changes Are or Are Not needed to prevent the
importation of zoonotic and animals diseases?
Response: Changes are needed;
Number of responses: 53.
Response: Changes are not needed, Skip To Question #10;
Number of responses: 2.
Response: No response;
Number of responses: 1.
9. How much, if at all, do you support or oppose the following
potential changes for APHIS to prevent the importation of zoonotic and
animal diseases?
Potential change: A-APHIS resources should be leveraged with FWS to
prevent importation of animal diseases;
Strongly support: 39;
Somewhat support: 10;
Neither support nor oppose: 0;
Somewhat oppose: 1;
Strongly oppose: 2;
Don't know: 2;
No response: 2.
Potential change: B-APHIS resources should be leveraged with CDC to
prevent importation of zoonotic diseases;
Strongly support: 37;
Somewhat support: 11;
Neither support nor oppose: 2;
Somewhat oppose: 0;
Strongly oppose: 2;
Don't know: 2;
No response: 2.
Potential change: C-APHIS should have the authority to consider
wildlife disease risk as part of its existing risk assessment
process[A];
Strongly support: 36;
Somewhat support: 13;
Neither support nor oppose: 3;
Somewhat oppose: 1;
Strongly oppose: 0;
Don't know: 2;
No response: 2.
[A] One expert provided two responses, "Strongly support" and
"Somewhat support" for question 9C.
[End of table]
Section 3: Centers for Disease Control and Prevention (CDC):
10. Based on your knowledge of CDC's statutory and regulatory
framework, do you believe changes ARE or ARE NOT needed to prevent the
importation of zoonotic diseases?
Response: Changes are needed;
Number of responses: 50.
Response: Changes are not needed; Skip To Question #12;
Number of responses: 5.
Response: No response;
Number of responses: 1.
[End of table]
11. How much, if at all, do you support or oppose the following
potential changes for CDC to prevent the importation of zoonotic
diseases?
Potential change: A-CDC should have the authority to use pre-import
screening to mitigate the risk of live animal imports;
Strongly support: 31;
Somewhat support: 9;
Neither support nor oppose: 4;
Somewhat oppose: 4;
Strongly oppose: 2;
Don't know: 1;
No response: 5.
Potential change: B-CDC should quarantine high-risk animals to allow
assessment of the animals' health;
Strongly support: 25;
Somewhat support: 12;
Neither support nor oppose: 5;
Somewhat oppose: 6;
Strongly oppose: 3;
Don't know: 0;
No response: 5.
[End of table]
Section 4: Fish and Wildlife Service (FWS):
12. Based on your knowledge of FWS's statutory and regulatory
framework, do you believe changes ARE or ARE NOT needed to prevent the
importation of zoonotic and animal diseases?
Response: Changes are needed;
Number of responses: 52.
Response: Changes are not needed; Skip To Question #14;
Number of responses: 3.
Response: No response;
Number of responses: 1.
[End of table]
13. How much, if at all, do you support or oppose the following
potential changes for FWS to prevent this importation of zoonotic and
animal diseases?
Potential change: A-FWS should have the authority to use pre-import
screening to mitigate the risk of live animal imports;
Strongly support: 38;
Somewhat support: 6;
Neither support nor oppose: 3;
Somewhat oppose: 4;
Strongly oppose: 0;
Don't know: 2;
No response: 3.
Potential change: B-FWS should have the authority to quarantine live
wildlife after import;
Strongly support: 32;
Somewhat support: 10;
Neither support nor oppose: 3;
Somewhat oppose: 7;
Strongly oppose: 0;
Don't know: 1;
No response: 3.
Potential change: C-FWS should classify species that may be carrying
infectious agents as injurious wildlife;
Strongly support: 25;
Somewhat support: 12;
Neither support nor oppose: 3;
Somewhat oppose: 9;
Strongly oppose: 2;
Don't know: 2;
No response: 3.
Potential change: D-FWS should expedite the process for classifying
species as injurious wildlife;
Strongly support: 31;
Somewhat support: 12;
Neither support nor oppose: 2;
Somewhat oppose: 3;
Strongly oppose: 0;
Don't know: 5;
No response: 3.
[End of table]
Section 5: Interagency Collaboration:
14. Based on your knowledge of the current statutory and regulatory
framework, do you believe a centralized agency should be created to
regulate all live animal imports?
Response: Yes, a centralized agency should be created;
Number of responses: 27.
Response: No, a centralized agency should not be created; Skip To
Question #16;
Number of responses: 29.
Response: No response;
Number of responses: 0.
[End of table]
15. Within which of the following should a centralized agency be
placed?
Response: Animal and Plant Health Inspection Service (APHIS);
Number of responses: 17.
Response: Customs and Border Protection (CBP);
Number of responses: 0.
Response: Centers for Disease Control and Prevention (CDC);
Number of responses: 2.
Response: Fish and Wildlife Service (FWS);
Number of responses: 1.
Response: A new agency created to regulate live animal imports;
Number of responses: 8.
Response: No response;
Number of responses: 28.
[End of table]
16. How much, if at all, do you support or oppose the creation of a
workgroup to help federal agencies collaborate in preventing the
importation of zoonotic and animal diseases?
Response: Strongly support;
Number of responses: 44.
Response: Somewhat support;
Number of responses: 8.
Response: Neither support nor oppose;
Number of responses: 3.
Response: Somewhat oppose;
Number of responses: 0.
Response: Strongly oppose;
Number of responses: 0.
Response: Don't know;
Number of responses: 0.
Response: No response;
Number of responses: 1.
[End of table]
17. How important, if at all, is representation from the following
entities on such a workgroup?
Entity: A-Academia;
Very important: 18;
Moderately important: 20;
Somewhat important: 13;
Slightly important: 3;
Not at all important: 2;
Don't know: 0;
No response: 0.
Entity: B-APHIS;
Very important: 52;
Moderately important: 4;
Somewhat important: 0;
Slightly important: 0;
Not at all important: 0;
Don't know: 0;
No response: 0.
Entity: C-Aquaculture;
Very important: 22;
Moderately important: 15;
Somewhat important: 12;
Slightly important: 7;
Not at all important: 0;
Don't know: 0;
No response: 0.
Entity: D-Aquariums;
Very important: 13;
Moderately important: 16;
Somewhat important: 19;
Slightly important: 6;
Not at all important: 1;
Don't know: 1;
No response: 0.
Entity: E-CDC;
Very important: 49;
Moderately important: 5;
Somewhat important: 1;
Slightly important: 0;
Not at all important: 0;
Don't know: 1;
No response: 0.
Entity: F-CBP;
Very important: 39;
Moderately important: 6;
Somewhat important: 8;
Slightly important: 1;
Not at all important: 1;
Don't know: 1;
No response: 0.
Entity: G-FWS;
Very important: 52;
Moderately important: 4;
Somewhat important: 0;
Slightly important: 0;
Not at all important: 0;
Don't know: 0;
No response: 0.
Entity: H-International Air Transport Association;
Very important: 16;
Moderately important: 16;
Somewhat important: 15;
Slightly important: 7;
Not at all important: 0;
Don't know: 2;
No response: 0.
Entity: I-International Civil Aviation Organization;
Very important: 6;
Moderately important: 17;
Somewhat important: 14;
Slightly important: 9;
Not at all important: 3;
Don't know: 7;
No response: 0.
Entity: J-Livestock industry;
Very important: 21;
Moderately important: 15;
Somewhat important: 12;
Slightly important: 7;
Not at all important: 1;
Don't know: 0;
No response: 0.
Entity: K-National Oceanic and Atmospheric Administration;
Very important: 20;
Moderately important: 12;
Somewhat important: 11;
Slightly important: 7;
Not at all important: 3;
Don't know: 3;
No response: 0.
Entity: L-Nonprofit organizations;
Very important: 8;
Moderately important: 11;
Somewhat important: 18;
Slightly important: 13;
Not at all important: 3;
Don't know: 3;
No response: 0.
Entity: M-Organizations that use imported live animals for research;
Very important: 21;
Moderately important: 11;
Somewhat important: 18;
Slightly important: 4;
Not at all important: 1;
Don't know: 1;
No response: 0.
Entity: N-Pet industry;
Very important: 24;
Moderately important: 14;
Somewhat important: 9;
Slightly important: 8;
Not at all important: 0;
Don't know: 1;
No response: 0.
Entity: O-Port authorities;
Very important: 25;
Moderately important: 19;
Somewhat important: 7;
Slightly important: 2;
Not at all important: 2;
Don't know: 1;
No response: 0.
Entity: P-Poultry industry;
Very important: 18;
Moderately important: 17;
Somewhat important: 9;
Slightly important: 10;
Not at all important: 1;
Don't know: 1;
No response: 0.
Entity: Q-State agricultural agencies;
Very important: 27;
Moderately important: 19;
Somewhat important: 6;
Slightly important: 2;
Not at all important: 2;
Don't know: 0;
No response: 0.
Entity: R-State public health agencies;
Very important: 25;
Moderately important: 16;
Somewhat important: 10;
Slightly important: 2;
Not at all important: 2;
Don't know: 1;
No response: 0.
Entity: S-State wildlife agencies;
Very important: 27;
Moderately important: 18;
Somewhat important: 6;
Slightly important: 2;
Not at all important: 2;
Don't know: 1;
No response: 0.
Entity: T-U.S. Geological Survey;
Very important: 22;
Moderately important: 11;
Somewhat important: 13;
Slightly important: 3;
Not at all important: 4;
Don't know: 3;
No response: 0.
Entity: U-World Organisation for Animal Health;
Very important: 25;
Moderately important: 17;
Somewhat important: 5;
Slightly important: 3;
Not at all important: 5;
Don't know: 1;
No response: 0.
Entity: V-World Health Organization;
Very important: 15;
Moderately important: 24;
Somewhat important: 8;
Slightly important: 3;
Not at all important: 5;
Don't know: 1;
No response: 0.
Entity: W-Zoos;
Very important: 18;
Moderately important: 19;
Somewhat important: 11;
Slightly important: 7;
Not at all important: 0;
Don't know: 1;
No response: 0.
[End of table]
18. What other entities, if any, should be included on such a
workgroup?
Answers included American College of Laboratory Animal Medicine;
American Medical Association; American Veterinary Medical Association;
Association of Fish and Wildlife Agencies; Council of State and
Territorial Epidemiologists; county departments of public health;
Defenders of Wildlife; Food and Agriculture Organization of the United
Nations; International Union for the Conservation of Nature; National
Association of State Public Health Veterinarians; National Institutes
of Health; National Science Foundation; Pet Industry Joint Advisory
Council; U.S. Agency for International Development; U.S. Coast Guard,
U. S. Department of Health and Human Services Office of Global Health
Affairs; U.S. Department of State; The Wildlife Society; Wildlife
Disease Association; Wildlife Trust.
19. How important, if at all, are the following activities for a
workgroup to help federal agencies collaborate in preventing the
importation of zoonotic and animal diseases?
Activity: A-Define the mission and scope of work related to live
animal imports for relevant federal agencies;
Very important: 44;
Moderately important: 6;
Somewhat important: 2;
Slightly important: 2;
Not at all important: 2;
Don't know: 0;
No response: 0.
Activity: B-Identify gaps in regulations related to live animal
imports among relevant federal agencies;
Very important: 50;
Moderately important: 3;
Somewhat important: 1;
Slightly important: 1;
Not at all important: 1;
Don't know: 0;
No response: 0.
Activity: C-Identify overlaps in regulations related to live animal
imports among relevant federal agencies;
Very important: 41;
Moderately important: 10;
Somewhat important: 3;
Slightly important: 0;
Not at all important: 1;
Don't know: 1;
No response: 0.
Activity: D-Recommend new legislation to prevent the importation of
zoonotic and animal diseases;
Very important: 27;
Moderately important: 16;
Somewhat important: 8;
Slightly important: 4;
Not at all important: 0;
Don't know: 1;
No response: 0.
Activity: E-Develop a coordinated national strategy to better align
activities, processes, and resources;
Very important: 52;
Moderately important: 4;
Somewhat important: 0;
Slightly important: 0;
Not at all important: 0;
Don't know: 0;
No response: 0.
Activity: F-Develop a risk assessment framework to identify animals,
diseases, and countries for appropriate action;
Very important: 41;
Moderately important: 12;
Somewhat important: 2;
Slightly important: 0;
Not at all important: 0;
Don't know: 1;
No response: 0.
Activity: G-Develop a research plan to help relevant federal agencies
in assessing disease risks;
Very important: 21;
Moderately important: 23;
Somewhat important: 8;
Slightly important: 2;
Not at all important: 1;
Don't know: 1;
No response: 0.
Activity: H-Examine methods to maximize inspection resources such as
reducing the number of ports of entry;
Very important: 32;
Moderately important: 17;
Somewhat important: 4;
Slightly important: 2;
Not at all important: 1;
Don't know: 0;
No response: 0.
Activity: I-Examine challenges for relevant federal agencies
associated with state regulations;
Very important: 27;
Moderately important: 18;
Somewhat important: 8;
Slightly important: 3;
Not at all important: 0;
Don't know: 0;
No response: 0.
Activity: J-Facilitate training for ports of entry staff;
Very important: 26;
Moderately important: 19;
Somewhat important: 4;
Slightly important: 6;
Not at all important: 1;
Don't know: 0;
No response: 0.
Activity: K-Develop a plan to leverage existing resources among
relevant federal agencies (e.g., sharing quarantine facilities,
training field staff, etc.);
Very important: 40;
Moderately important: 10;
Somewhat important: 4;
Slightly important: 2;
Not at all important: 0;
Don't know: 0;
No response: 0.
Activity: L-Designate resources to be shared among relevant federal
agencies for disease outbreaks;
Very important: 28;
Moderately important: 20;
Somewhat important: 6;
Slightly important: 0;
Not at all important: 2;
Don't know: 0;
No response: 0.
Activity: M-Develop a plan to ensure that data on all live animal
imports is available to relevant federal agencies;
Very important: 39;
Moderately important: 12;
Somewhat important: 4;
Slightly important: 0;
Not at all important: 1;
Don't know: 0;
No response: 0.
Activity: N-Establish an agreement between relevant federal agencies
and international aviation associations to enhance cooperation;
Very important: 20;
Moderately important: 19;
Somewhat important: 14;
Slightly important: 2;
Not at all important: 1;
Don't know: 0;
No response: 0.
Activity: O-Develop a process for relevant federal agencies to confer
with each other when entering into agreements with international;
Very important: 26;
Moderately important: 13;
Somewhat important: 13;
Slightly important: 1;
Not at all important: 1;
Don't know: 2;
No response: 0.
Activity: P-Develop a plan for relevant federal agencies to
collaborate in meeting the obligations of the World Health
Organization's International Health Regulations;
Very important: 20;
Moderately important: 16;
Somewhat important: 15;
Slightly important: 1;
Not at all important: 1;
Don't know: 3;
No response: 0.
Activity: Q-Develop a plan for relevant federal agencies to coordinate
counter measures against live animal smuggling;
Very important: 37;
Moderately important: 10;
Somewhat important: 6;
Slightly important: 2;
Not at all important: 0;
Don't know: 1;
No response: 0.
Activity: R-Develop a plan for identifying and implementing existing
Memoranda of Understandings among relevant federal agencies;
Very important: 23;
Moderately important: 23;
Somewhat important: 6;
Slightly important: 3;
Not at all important: 0;
Don't know: 1;
No response: 0.
Activity: S-Develop public outreach and education programs for those
likely to come in contact with imported animals to prevent contracting
or spreading diseases;
Very important: 26;
Moderately important: 14;
Somewhat important: 8;
Slightly important: 7;
Not at all important: 0;
Don't know: 1;
No response: 0.
[End of table]
20. Based upon your knowledge of interagency collaboration at ports of
entry, do you believe communications among the agencies are adequate?
Response: Adequate;
Number of responses: 3.
Response: Inadequate;
Number of responses: 53.
Response: No response;
Number of responses: 0.
[End of table]
21. How important, if at all, are the following activities to improve
interagency communications?
Activity: A-Convene regular risk management meetings;
Very important: 25;
Moderately important: 14;
Somewhat important: 10;
Slightly important: 4;
Not at all important: 1;
Don't know: 2;
No response: 0.
Activity: B-Integrate outside stakeholders into relevant risk
management activities;
Very important: 21;
Moderately important: 24;
Somewhat important: 4;
Slightly important: 5;
Not at all important: 0;
Don't know: 2;
No response: 0.
Activity: C-Designate a process, including interagency communication,
for CBP to hold animals at the port until necessary inspections can be
completed by appropriate federal agencies;
Very important: 27;
Moderately important: 14;
Somewhat important: 8;
Slightly important: 3;
Not at all important: 3;
Don't know: 1;
No response: 0.
Activity: D-Establish compatible data systems containing information
for managing, processing, and analyzing imports among relevant federal
agencies;
Very important: 41;
Moderately important: 10;
Somewhat important: 4;
Slightly important: 1;
Not at all important: 0;
Don't know: 0;
No response: 0.
[End of table]
22. Based upon your knowledge of interagency collaboration at ports of
entry, do you believe training among the agencies is adequate or
inadequate?
Response: Adequate;
Number of responses: 8.
Response: Inadequate;
Number of responses: 46.
Response: No response;
Number of responses: 2.
[End of table]
23. How important, if at all, are the following activities to improve
interagency training?
Activity: A-Improve cross-training on other federal agencies'
regulations;
Very important: 35;
Moderately important: 9;
Somewhat important: 6;
Slightly important: 4;
Not at all important: 0;
Don't know: 2;
No response: 0.
Activity: B-Improve cross-training on state, regional, and local
regulations;
Very important: 27;
Moderately important: 11;
Somewhat important: 10;
Slightly important: 4;
Not at all important: 3;
Don't know: 1;
No response: 0.
Activity: C-Improve training on zoonotic and animal disease risks;
Very important: 35;
Moderately important: 11;
Somewhat important: 8;
Slightly important: 0;
Not at all important: 1;
Don't know: 1;
No response: 0.
Activity: D-Improve training on recognition of zoonotic and animal
diseases;
Very important: 38;
Moderately important: 12;
Somewhat important: 2;
Slightly important: 1;
Not at all important: 2;
Don't know: 1;
No response: 0.
Activity: E-Improve training on animal identification;
Very important: 29;
Moderately important: 15;
Somewhat important: 8;
Slightly important: 1;
Not at all important: 1;
Don't know: 2;
No response: 0.
Activity: F-Create liaison positions among the federal agencies to
coordinate training opportunities;
Very important: 23;
Moderately important: 17;
Somewhat important: 4;
Slightly important: 7;
Not at all important: 2;
Don't know: 3;
No response: 0.
[End of table]
Section 6: Enforcement of Regulations:
24. How important, if at all, are the following enforcement actions to
prevent the importation of zoonotic and animal diseases?
Activity: A-Provide additional FWS port inspectors ;
Very important: 31;
Moderately important: 12;
Somewhat important: 5;
Slightly important: 3;
Not at all important: 1;
Don't know: 4;
No response: 0.
Activity: B-Increase importer user fees to be specifically designated
for enforcement activities ;
Very important: 34;
Moderately important: 4;
Somewhat important: 5;
Slightly important: 2;
Not at all important: 6;
Don't know: 5;
No response: 0.
Activity: C-Identify methods to ensure that animals from banned
countries are not routed through another country prior to importation;
Very important: 41;
Moderately important: 8;
Somewhat important: 1;
Slightly important: 3;
Not at all important: 2;
Don't know: 1;
No response: 0.
Activity: D-Increase penalties for live animal smuggling violations ;
Very important: 40;
Moderately important: 8;
Somewhat important: 3;
Slightly important: 3;
Not at all important: 0;
Don't know: 2;
No response: 0.
Activity: E-Enforce penalties for live animal smuggling violations ;
Very important: 42;
Moderately important: 10;
Somewhat important: 0;
Slightly important: 1;
Not at all important: 0;
Don't know: 3;
No response: 0.
[End of table]
Section 7: Agency Data Used for Live Animal Imports:
25. How important, if at all, is making the following data accessible
on the Web?
Data: A-FWS's Law Enforcement Management Information System ;
Very important: 14;
Moderately important: 18;
Somewhat important: 5;
Slightly important: 5;
Not at all important: 2;
Don't know: 12;
No response: 0.
Data: B-APHIS's Import Tracking System data ;
Very important: 15;
Moderately important: 16;
Somewhat important: 6;
Slightly important: 5;
Not at all important: 3;
Don't know: 11;
No response: 0.
[End of table]
Section 8: Other Comments:
26. What comments, if any, do you have about the issues discussed in
this survey?
27. What other live animal import concerns, if any, do you have that
we have not discussed?
Note: We used the responses to questions 26 and 27 to inform our
findings in this report.
[End of section]
Appendix VIII: Comments from the U.S. Department of Agriculture:
USDA:
United States Department of Agriculture:
Office of the Secretary:
Washington, D.C. 20250:
October 21, 2010:
Ms. Lisa Shames, Director:
Natural Resources and Environment:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
The United States Department of Agriculture (USDA) appreciates the
opportunity to comment on the GAO draft report, "Live Animal Imports:
Agencies Need Better Collaboration to Reduce the Risk of Animal-
Related Diseases" (11-09). While the report contains individual
Recommendations for the Secretary of Agriculture, we have globally
addressed these Recommendations.
First and foremost, USDA agrees with these recommendations. USDA is
deeply committed to the protection of American agriculture, as well as
to the protection of farmed animal health and welfare, and to
maintaining an effective strategy to prevent, contain or eradicate
outbreaks of animal diseases. USDA appreciates GAO's emphasis on
increasing the level of collaboration among federal agencies with
differing types of oversights for animal importations.
As the GAO audit pointed out, USDA, as well as some other federal
agencies, currently has limited statutory authorities regarding the
importation of animal commodities that are capable of introducing or
otherwise acting as vectors for important diseases of animals and/or
humans. Moreover, USDA (and many other government entities) is working
to find ways to effectively and efficiently carry out our mission
priorities in light of constrained funding. Such enforcement
considerations would also necessarily apply to any further authorities
that may be sought or realized by a Department. USDA believes that a
key component to successfully leveraging the different Departments'
strengths, while minimizing the individual limitations of each
Department, lies in finding new ways to approach these opportunities.
USDA, therefore, would support the formation of an inter-departmental
Steering Committee for the oversight of animal importations, whose co-
chairs, representing USDA, Departments of Health and Human Services,
Homeland Security, and the Interior, would report the Committee's
findings and progress directly to their respective Secretaries. An
USDA nominee for this Committee could be determined by November 1,
2010. If the notion of forming such a Committee received support from
other government entities, USDA would support convening the Committee
as soon as possible. Prior to the first meeting, USDA would provide
input for specific agenda items and would work with other entities to
create an agenda that focused on the issues of collaboration and
focused oversight as highlighted in the GAO audit.
USDA would also work with the other Departments to create a Committee
charter with a clear mission statement, Committee goals and
objectives, and progress milestones for increasing the effectiveness
of animal importation oversights ” all of which would be directly
responsive to GAO's recommendations.
USDA believes that among other things, such a Committee could examine
and discuss the specific statutory authorities currently supporting
the processes in USDA and other Departments by which animals are
imported to the United States, with the specific goal of identifying
areas of overlapping, concurrent, or non-existent jurisdictions. In
collaboration with the Committee and other Departments, USDA would
also seek to determine the need for creating additional authority;
clarify the scope of existing authority; and implement current
authority more efficiently through expanded Memoranda of Agreements or
other inter-departmental cooperative measures.
As these factors are discussed and refined, the need for streamlining
or re-directing existing resources, or to acquire additional resource
allocations, would become clearer. With that added clarity, USDA would
then formulate a list of action steps which we would submit in a
report to GAO. This report from USDA would outline the components of a
successful strategy for addressing GAO's recommendations in a timely
manner. Once the avenues of increased collaboration have been
identified, USDA would also communicate these strategies with its
stakeholders for additional inputs.
Sincerely,
Signed by:
Edward Avalos:
Under Secretary:
Marketing and Regulatory Programs:
[End of section]
Appendix IX: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
Ms. Lisa Shames:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
Subject: Draft Report GAO-11-09, Live Animal Imports: Agencies Need
Better Collaboration to Reduce the Risk of Animal-Related Diseases
(Job Code 361116).
The Department of Homeland Security (DHS) appreciates the opportunity
to review and comment on the draft report referenced above. We agree
with the intent of the two recommendations.
Recommendation 1: Develop and implement, in coordination with the
relevant federal agencies, a strategy for their collaboration in
preventing the importation of animals that may be carrying zoonotic
and animal diseases from entering the United States. This strategy
should help the agencies:
* Identify and resolve differing program priorities so that the
agencies can work collaboratively to ensure that live animal imports
posing a risk of zoonotic and animal diseases do not enter the United
States. Such efforts could include collaborative methods for
prevention, such as a comprehensive risk assessment system for live
animal imports;
* Lay out individual agency roles and responsibilities for all live
animal imports, including how a collaborative effort will be led;
* Identify resources dedicated to live animal imports and leverage
these resources to the extent possible to support the agencies'
efforts;
* Examine ways to systematically share data on shipments of live
animal imports that are regulated by more than one agency until ITDS
is fully operational; and;
* Explore the need for any additional legislative or executive
authority to develop and implement this strategy such as the authority
to establish a coordinating entity (e.g., an interagency workgroup).
Response: The Department concurs with the intent of GAO's
recommendation and we will work with the pertinent organizations
within the Departments of Agriculture, Health and Human Services, and
Interior to gauge interest in developing a joint strategic
implementation plan to address preventing the importation of animals
that may be carrying zoonotic and animal diseases from entering the
United States.
Of note, currently the U.S. Customs and Border Protection, Office of
Field Operations (OFO), Agriculture Programs and Trade Liaison (APTL)
collaborates continuously with the U.S. Department of Agriculture
(USDA), Animal and Plant Health Inspection Service (APHIS) to
facilitate live animal imports. Procedures outlined in USDA's API-US
Animal Product Manual in Chapter 2, "Procedures" and Chapter 3 "Live
Animal and Related Materials" for Customs and Border Protection
Officers (CBPOs) and Customs and Border Protection Agriculture
Specialists (CBPASs) to make appropriate agency referrals. These
procedures include referral information (Chapter 2) and tables
(Chapter 3) to guide CBPASs and CBPOs to the appropriate regulating
agency for the clearance of dogs, cats, laboratory mammals,
amphibians, reptiles, fish, monkeys, and other nonhuman primates. The
referring agencies listed are the Fish and Wildlife Service (FWS), or
the Center for Disease Control and Prevention (CDC). Also, CBPASs and
CBPOs refer horses, cattle, sheep, goats, swine, and pet birds
directly to the APHIS-Veterinary Service (VS) for clearance.
Section 421 (e) of the Homeland Security Act of 2002 (the Act),
transferred to the U.S. Department of Homeland Security (DHS)
functions of APHIS relating to agricultural import and entry
inspections. Article 2 of the Memorandum of Agreement between the DHS
and USDA outlines the extent of CBP's role with live animal imports.
Article 2 (f) states "Referring all live animals, embryos, semen, and
other viable animal products to USDA" and to "Notify APHIS-VS when
live animals are present." Additionally CBP, OFO has national bird
handling standard operating procedures (SOPs). CBP's bird handling
SOPs provide information to the ports of entry (POEs) and includes, as
applicable, the CBP Offices of Border Patrol and Air and Marine, and
list responsibilities for CBP and APHIS. CBP and APHIS have SOPs along
the Southern Border to facilitate the inspection of feeder cattle. CBP
and APHIS have guidance for coordinating APHIS-VS and CBP processing
of live animal importations arriving from Canada at land border POEs.
Although CBPASs and CBPOs at POEs refer all live animal imports to the
appropriate regulating agency, they are not solely dedicated to this
particular function. CBPOs and CBPASs facilitate all cargo and
commodities for the trade industry into the United States. POEs
maintain quarantine rooms, personal protective equipment, cages, and
other quarantine materials for all birds encountered from all
countries including when the country of origin of the bird is unknown.
Seized pet birds are held by CBP and turned over to APHIS-VS.
Recommendation 2: Jointly determine, in collaboration with CBP, the
data that APHIS, CDC, and FWS will need ITDS to contain, so that
agencies can effectively oversee all live animal imports.
Response: CBP concurs with this recommendation and already has work in
progress to fulfill it. The draft report correctly details the
creation of the International Trade Data System (ITDS) to streamline
data requirements across all agencies. The CBP, Office of
International Trade has been working in conjunction with the Animal
Plant Health Inspection Service (APHIS), Center for Disease Control
(CDC), and Fish and Wildlife Service (FWS) to address data needs for
each of these agencies. The CBP, Office of International Trade has
already established a mechanism where it collaborates with other
government agencies on efforts aimed at addressing their data needs
within the Automated Commercial Environment (ACE). The process
includes the assignment of an ACE liaison to participating government
agencies in order to address their data needs. The data elements are
then evaluated, streamlined, and included in the ITDS Standard Data
Set (SDS), which serves as a common data dictionary for all government
agencies participating in the ACE pilot. CBP, APHIS, FWS. and CDC are
all active members within ITDS and have initiated the first steps of
data sharing within ACE. The concept of operations plan for the APHIS
has already been approved by CBP. The FWS have submitted their concept
of operations plan, which is still under legal review by both
agencies. Both APHIS and the FWS have had their data needs mapped to
the ITDS SDS. The CDC has not yet submitted their concept of
operations to CBP. However, CBP has begun preliminary discussions with
the CDC involving the integration of their data needs into the SDS.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO-OIG Liaison Office:
[End of section]
Appendix X: Comments from the Department of the Interior:
Note: GAO comments supplementing those in the report text appear at
the end of this appendix.
United States Department of the Interior:
Office Of The Secretary:
Washington, DC 20240:
Ms. Lisa Shames:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Ms. Shames:
Thank you for providing the Department of the Interior the opportunity
to review and comment on the draft Government Accountability Office
Report entitled "Live Animal Imports: Agencies Need Better
Collaboration to Reduce the Risk of Animal-Related Diseases" (GAO-11-
09).
The enclosure contains some general and specific comments. The
Department concurs with the major findings and recommendations
included in the report.
If you have any questions, or need additional information, contact
Kathy Garrity, Fish and Wildlife Service, at (703) 358-2551.
Sincerely,
Signed by:
Thomas L. Strickland:
Assistant Secretary for Fish and Wildlife and Parks:
Enclosure:
[End of letter]
Enclosure:
Department of the Interior:
Comments on the GAO draft report on:
Live Animal Imports: Agencies Need Better Collaboration to Reduce the
Risk of Animal-Related Diseases (GAO 11-09):
General comments:
No reference has been made in the report to the possible confusion
that may be caused by multiple agencies having related authorities.
Does the public know where to find data/information on imports and
restrictions? Although it was not a central question GAO was asked to
review, outreach could have been reviewed/analyzed a little more,
since it could play an important role in reducing risks of animal-
related diseases. [See comment 1]
Also, no reference is made to any efforts to prevent the introduction
of diseases in container water. We recommend adding "Federal, state,
and NGO partners should initiate discussions to address potential
disease threats posed by container water (e.g. water used to transport
ornamental fish or other aquatics)." [See comment 2]
The report should emphasize the National Aquatic Animal Health Plan
(NAAHP) as a model for Federal cooperation with regard to movement of
aquatic animal diseases. In the future, the NAAHP will be broadened to
include amphibians and reptiles. [See comment 3]
Specific comments:
"Highlights" Page, 2nd bullet: re: FWS regulation of invasive species.
The reference to review of a petition on amphibians fails to explain
why this is relevant (i.e., because it is a petition to restrict
imports of amphibians (that carry choridfungus.) Also, this is a
reaction to a petition and really does not demonstrate how FWS is
being proactive in applying its authority. [See comment 4]
"Highlights" Page: "In contrast, the U.S. Department of
Agriculture's..." implies an equality of effort by agencies to prevent
the movement of diseases in the live animal import trade, but also
implies equality between the three agencies with regard to
authority. In reality, USDA-APHIS' authority is much broader than that
of the USFWS; therefore, equality cannot be inferred. We recommend the
following wording: "USDA's authority is much broader than that of the
USFWS with regard to movement of aquatic pathogens, and is focused on
agricultural species. The USFWS' authority is focused on
native aquatic species in the wild. All agencies should work within
their authorities and collaborate to better prevent the movement of
aquatic pathogens." [See comment 5]
Page 3, 1st sentence: "More than 1 billion live animals were legally
imported into the United States for agriculture, clinical research,
education and exhibition, and the aquarium and pet industries."
Suggest adding "and other uses" - There are other possible uses that
do not need to be mentioned but should at least be acknowledged (e.g.,
furs). [See comment 6]
Page 4, 2nd bullet: "The Department of the Interior's Fish and
Wildlife Service (FWS) administers the prohibition against the import
of live animals..." FWS also has the authority to list dead organisms
as injurious wildlife, and has done so specifically in the case of
salmonids to mitigate the risk of disease transmission, the key
element of the GAO report. This omission occurs elsewhere in the
report and should be corrected (pages 9 and 20). [See comment 7]
Page 8: We recognize that CBP provides assistance to FWS in enforcing
import regulations; however, we believe the responsibilities described
are overstated. When a live animal import arrives at a port of entry,
CBP does not hold and refer the import to FWS. FWS is routinely
notified by the importer/exporter and/or the airline. [See comment 8]
Page 10, 1st full paragraph: "According to the FWS data system, about
177 million live animals ” nearly all wildlife ” were imported under
FWS regulation in fiscal year 2009". The use of the word "nearly" is
inaccurate. The FWS regulates all wildlife. [See comment 9]
Page 13, 4th line: it should say "comprehensive science-based" not
"comprehensive-based science"? [See comment 10]
Page 21, 2nd line: Bd pathogen (Batrachockytriurn dendrobatidis) does
not cause a fungus, it is a fungus. [See comment 11]
Page 22, middle of 1st paragraph: "FWS is reviewing several proposals
to...preventing the spread of invasive species, including:...
developing a risk assessment process with scientifically credible
procedures; and supporting regulatory and educational approaches." The
statement assumes our current procedures are not scientifically valid.
Please revise to state: "FWS is reviewing several proposals
to...preventing the spread of invasive species, including:...revising
its risk assessment process; and supporting improved regulatory and
educational approaches." [See comment 12]
Page 22, 2nd paragraph: "Experts also identified the need for an
entity to help the agencies overcome these barriers." The report seems
to suggest a new entity is needed to help improve coordination, yet we
already have the National Invasive Species Council and Aquatic
Nuisance Species Task Force. No mention is made of either of these
bodies, or why they could not effectively serve this role. (Also
appears on page 32) [See comments 13 and 14]
Page 22: Although Agencies Have Collaborated to Meet Common Goals,
They Face Barriers to Additional Collaboration ” This section states
that CBP usually contacts FWS Inspectors to determine whether a
particular type of turtle is banned in statute or regulation. This is
inaccurate and not a function of CBP. FWS is usually notified by the
importer/exporter or the airline. [See comment 8]
Page 24: GAO notes that the principal barrier to collaboration is
agencies' failure to take a broader view of the entire importation
process. Likewise, GAO statement "...focusing instead on only those
components of the process each agency controls." is not quite
accurate, as agency focus is legislatively dictated by authorizations
(see comment "Highlights Page" above). We suggest that GAO consider
asking agencies to redouble collaborative efforts within their
authorities to prevent import and movement of aquatic pathogens.
[See comment 15]
Page 30, 1st full paragraph: "While the agencies have worked
together...they may not be able to determine whether their funding and
staff are sufficient..." This evaluation has occurred as part of the
mandate from the Secretary of the Interior for FWS to comprehensively
review its statutory authorities, regulations, and processes under the
injurious wildlife provisions of the Lacey Act. Recommendations are
moving presently through the FWS and DOI approval processes. [See
comment 16]
Page 32, last paragraph: GAO asked experts whether a workgroup should
be created to help federal agencies collaborate. However, there is no
consideration of whether there may be an existing group that could
perform this function. Use of an existing body could facilitate
collaboration and efficiency by avoiding unnecessary proliferation of
groups. The National Invasive Species Council (NISC) was established
by Executive Order 13112 (EO) to improve coordination and
collaboration among federal agencies and with experts and stakeholders
on invasive species issues, including the risk of animal related
diseases being introduced by invasive species. The Department of
Homeland Security and the Department of Health and Human Services are
members of NISC; while the Department of the Interior and the
Department of Agriculture are co-chairs of NISC. The HO also
established the Invasive Species Advisory Committee (ISAC) which
includes nonfederal experts and stakeholders from across the nation.
ISAC and NISC may establish subcommittees, workgroups or task teams to
consider specific issues; and this has occurred to address a number of
issues. The report should state that, in addition to the option of
creating a new workgroup, there may be an existing group whose scope
could be expanded to play this role. [See comment 14]
Page 55, Appendix V Note at the bottom of the table: indicates that
FWS only screens shipments of live animals for disease risk for salmon
and CITES listed species only. This is inaccurate. Our regulations
also require the trade to provide health certificates for all mammals
and birds that are wildlife. [See comment 17]
The following are GAO's comments on the Department of the Interior's
letter.
GAO Comments:
1. In the report, we state that federal agencies face a range of
barriers when they attempt to collaborate with other agencies and that
these barriers can confuse and frustrate program customers. In
addition, as the Department of the Interior notes, this issue was not
part of our objectives.
2. Our report does not attempt to describe all of the pathways by
which live animal imports could introduce diseases into the United
States. However, we modified the report to include a reference to
container water in which aquatic animals are transported as a
potential pathway.
3. In the report, we state that the National Aquatic Animal Health
Plan is an example of federal agencies' joint strategies to reduce
disease risks from live animal imports. We have added language to
provide more information on this plan's relevant efforts.
4. We revised the report to reflect this comment by deleting from the
highlights page the reference to FWS's review of a petition on
amphibians.
5. We added language to the highlights page to clarify that FWS was
directed to review statutory authorities and regulations to address
existing problems associated with nonnative live animals.
6. We added language to the report to clarify that imported live
animals are used for additional purposes.
7. We modified language in the report to clarify that FWS' authority
to list organisms as injurious wildlife is not limited to live animals.
8. We modified the report to attribute a description of CBP's
processes to CBP officials only.
9. We modified the report to clarify that FWS regulates all wildlife.
10. We did not change the language because it is a quote from the
cited National Academies of Sciences report that we attributed.
11. We modified the report to clarify that the Bd pathogen is a fungus.
12. We modified the report to clarify that FWS is revising its risk
assessment procedures.
13. The National Invasive Species Council's activities to help federal
agencies collaborate are described in the report. We added information
on the Invasive Species Advisory Committee, which works closely with
the National Invasive Species Council. In addition, we added
information on the Aquatic Nuisance Species Task Force.
14. The use of an existing interagency body to serve as a coordinating
entity to help federal agencies prevent the importation of animals
that may be carrying zoonotic and animal diseases was not mentioned in
experts' responses to the first round of our survey, which was the
basis for our second round of survey questions. Placing a coordinating
entity for live animal imports within an existing interagency body may
help in avoiding duplication of effort. We recommended the development
and implementation of a strategy to help the agencies explore the need
for any additional legislative or executive authority to develop and
implement this strategy, such as the authority to establish a
coordinating entity (e.g., an interagency workgroup). If the agencies
determine that it is appropriate to place the coordinating entity for
live animal imports within an existing interagency body, this response
would be consistent with our recommendation.
15. We modified the report to clarify that agencies focus on only
those components of the process each agency controls under its
statutory authority. As noted in the report, in January 2010, the
Secretary of the Interior directed FWS to comprehensively review
statutory authorities and regulations.
16. We modified the report to add that an evaluation of the amount of
FWS's funding and level of staff for live animal imports has occurred.
17. We modified the report to clarify that FWS requires that all
carriers transporting wild mammals and birds to the United States have
a certificate of veterinary medical inspection signed by a
veterinarian.
[End of section]
Appendix XI: GAO Contact and Staff Acknowledgments:
GAO Contact:
Lisa Shames, (202) 512-3841 or shamesl@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Thomas M. Cook, Assistant
Director; Kevin S. Bray; Gary T. Brown; Elizabeth Curda; Mary Denigan-
Macauley; Elizabeth Dunn; Jeanette Jacobs; Mitchell Karpman; Diane G.
LoFaro; Terry Richardson; Cynthia Saunders; Carol Herrnstadt Shulman;
Kathryn A. Smith; Kiki Theodoropoulos; and Megan M. Taylor made key
contributions to this report.
[End of section]
Related GAO Products:
National Security: Key Challenges and Solutions to Strengthen
Interagency Collaboration. [hyperlink,
http://www.gao.gov/products/GAO-10-822T]. Washington, D.C.: June 9,
2010.
Language Access: Selected Agencies Can Improve Services to Limited
English Proficient Persons. [hyperlink,
http://www.gao.gov/products/GAO-10-91]. Washington, D.C.: April 26,
2010.
Biosurveillance: Developing a Collaboration Strategy Is Essential to
Fostering Interagency Data and Resource Sharing. [hyperlink,
http://www.gao.gov/products/GAO-10-171]. Washington, D.C.: December
18, 2009.
Food Safety: Agencies Need to Address Gaps in Enforcement and
Collaboration to Enhance Safety of Imported Food. [hyperlink,
http://www.gao.gov/products/GAO-09-873]. Washington, D.C.: September
15, 2009.
Seafood Fraud: FDA Program Changes and Better Collaboration among Key
Federal Agencies Could Improve Detection and Prevention. [hyperlink,
http://www.gao.gov/products/GAO-09-258]. Washington, D.C.: February
19, 2009.
Veterinarian Workforce: Actions Are Needed to Ensure Sufficient
Capacity for Protecting Public and Animal Health. [hyperlink,
http://www.gao.gov/products/GAO-09-178]. Washington, D.C.: February 4,
2009.
Natural Resource Management: Opportunities Exist to Enhance Federal
Participation in Collaborative Efforts to Reduce Conflicts and Improve
Natural Resource Conditions. [hyperlink,
http://www.gao.gov/products/GAO-08-262]. Washington, D.C.: February
12, 2008.
National Animal Identification System: USDA Needs to Resolve Several
Key Implementation Issues to Achieve Rapid and Effective Disease
Traceback. [hyperlink, http://www.gao.gov/products/GAO-07-592].
Washington, D.C.: July 6, 2007.
Avian Influenza: USDA Has Taken Important Steps to Prepare for
Outbreaks, but Better Planning Could Improve Response. [hyperlink,
http://www.gao.gov/products/GAO-07-652]. Washington, D.C.: June 11,
2007.
Homeland Security: Management and Coordination Problems Increase the
Vulnerability of U.S. Agriculture to Foreign Pests and Disease.
[hyperlink, http://www.gao.gov/products/GAO-06-644]. Washington, D.C.:
May 19, 2006.
Results-Oriented Government: Practices That Can Help Enhance and
Sustain Collaboration among Federal Agencies. [hyperlink,
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2005.
Managing for Results: Barriers to Interagency Coordination.
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106]. Washington,
D.C.: March 29, 2000.
Agency Performance Plans: Examples of Practices That Can Improve
Usefulness to Decisionmakers. [hyperlink,
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February 26, 1999.
Agencies' Annual Performance Plans Under the Results Act: An
Assessment Guide to Facilitate Congressional Decisionmaking.
[hyperlink, http://www.gao.gov/products/GAO/GGD/AIMD-10.1.188].
Washington, D.C.: February 1998.
Wildlife Protection: Fish and Wildlife Service's Inspection Program
Needs Strengthening. [hyperlink,
http://www.gao.gov/products/GAO/RCED-95-8]. Washington, D.C.: December
29, 1994.
[End of section]
Footnotes:
[1] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21,
2005).
[2] GAO, Avian Influenza: USDA Has Taken Important Steps to Prepare
for Outbreaks, but Better Planning Could Improve Response, [hyperlink,
http://www.gao.gov/products/GAO-07-652] (Washington, D.C.: June 11,
2007).
[3] Other federal agencies also have specific responsibilities. For
example, under the Marine Mammal Protection Act, the Department of
Commerce's National Marine Fisheries Service administers prohibitions
on the importation of certain marine mammals.
[4] Invasive species may prey upon, displace, or otherwise harm native
species. Some invasive species also alter ecosystem processes,
transport disease, interfere with crop production, or cause disease in
animals or humans.
[5] According to APHIS and FWS officials, the two data systems may
overlap because the agencies regulate some of the same species, such
as birds and certain fish. As such, the total number of imported
animals is not the sum of each agency's total number of reported
animals.
[6] GAO, Managing for Results: Barriers to Interagency Coordination,
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106] (Washington,
D.C.: Mar. 29, 2000).
[7] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[8] American Veterinary Medical Association, One Health: A New
Professional Imperative (2008).
[9] Exec. Order No. 13,112, 64 Fed. Reg. 6183(Feb. 3, 1999).
[10] National Research Council of the National Academies, Committee on
Assessing the Nation's Framework for Addressing Animal Diseases,
Animal Health at the Crossroads: Preventing, Detecting, and Diagnosing
Animal Diseases (Washington, D.C.: 2005).
[11] Defenders of Wildlife, Broken Screens: The Regulation of Live
Animal Imports in the United States (Washington, D.C.: 2007).
[12] B. I. Pavlin, L. M. Schloegel, and P. Daszak, "Risk of Importing
Zoonotic Diseases through Wildlife Trade, United States," Emerging
Infectious Diseases, vol. 15, no. 11 (November 2009).
[13] U.S. Department of Agriculture, Office of Inspector General,
Audit Report: USDA's Controls Over Animal Import Centers, Report No.
33601-11-Ch (Washington, D.C.: August 2010).
[14] U.S. Department of Agriculture, Office of Inspector General,
Midwest Region, Audit Report: USDA's Controls Over the Importation and
Movement of Live Animals, Report No. 50601-0012-Ch (Washington, D.C.:
March 2008).
[15] U.S. Department of Agriculture, Animal and Plant Health
Inspection Service, VS2015: A Strategic Look at the Future of APHIS'
Veterinary Services, (October 2008).
[16] FWS clarified the number of species listed as injurious under the
Lacey Act as at least 231 species, including 100 species of walking
catfish, 60 species of flying fox or fruit bats, 28 species of
snakehead fish, and 19 species of mongoose.
[17] On March 23, 2010, the House Committee on Natural Resources'
Subcommittee on National Parks, Forests and Public Lands and
Subcommittee on Insular Affairs, Oceans and Wildlife held a joint
hearing, "How to Manage Large Constrictor Snakes And Other Invasive
Species."
[18] [hyperlink, http://www.gao.gov/products/GAO/GGD-00-106].
[19] The Department of Health and Human Services is currently
reviewing public comments on its strategic plan.
[20] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[21] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[22] National Aquatic Animal Health Task Force, National Aquatic
Animal Health Plan (August 2008).
[23] This plan was developed by a task force commissioned by the Joint
Subcommittee on Aquaculture, which was authorized by the National
Aquaculture Act of 1980. Its mission is to increase the overall
effectiveness and productivity of federal aquaculture research,
transfer, and assistance programs.
[24] According to the task force, aquatic nuisance species are aquatic
and terrestrial organisms, introduced into new habitats throughout the
United States and other areas of the world, that produce harmful
impacts on aquatic natural resources in these ecosystems and on the
human use of these resources.
[25] Pub .L. No. 101-646 104 Stat. 2761.
[26] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[27] GAO, National Security: Key Challenges and Solutions to
Strengthen Interagency Collaboration, [hyperlink,
http://www.gao.gov/products/GAO-10-822T] (Washington, D.C.: June 9,
2010).
[28] According to the Department of the Interior, such an evaluation
has occurred at the direction of the Secretary of the Interior. FWS
was directed to comprehensively review its statutory authorities,
regulations, and processes under the injurious wildlife provisions of
the Lacey Act, and recommendations are moving presently through the
FWS and department approval processes.
[29] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[30] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[31] Section 405 of the Security and Accountability for Every Port Act
of 2006 (SAFE Port Act), Pub. L. No. 109-347, 120 Stat. 1884, requires
the Secretary of the Treasury to oversee the establishment of a
comprehensive information system, and requires a report to be
submitted to the Committee on Finance, United States Senate, and
Committee on Ways and Means, House of Representatives, each fiscal
year. The most recent report was submitted in September 2009.
[32] GAO, Managing for Results: Enhancing Agency Use of Performance
Information for Management Decision Making, [hyperlink,
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: September
2005).
[33] APHIS, Veterinary Services Strategic Plan, FY06-FY11.
[34] CBP, Strategic Plan FY2009-2014 (Washington, D.C.: July 2009) and
CBP, Field Operations Strategic Plan FY2007-2011 (Washington, D.C.:
September 2006).
[35] CDC, FY2008 Centers for Disease Control and Prevention Annual
Performance Report.
[36] FWS, Office of Law Enforcement Strategic Plan 2006-2010 (December
2005).
[37] Imported live bats do not have a specific regulation. However,
CDC regulates bats as a vector for infectious diseases. CDC defines a
vector as an animal that conveys or is capable of conveying infectious
agents from a person or animal to another person or animal.
[End of section]
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