a

GAO

United States Government Accountability Office

Report to Congressional Requesters

May 2006 HOMELAND 

SECURITY

Management and 

Coordination 

Problems Increase the 

Vulnerability of U.S. 

Agriculture to Foreign 

Pests and Disease

GAO-06-644
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2006

HOMELAND SECURITY

Management and Coordination Problems 

Increase the Vulnerability of U.S. 

Agriculture to Foreign Pests and Disease 

Highlights of GAO-06-644, a report to 

congressional requesters 

U.S. agriculture generates over $1

trillion in annual economic activity, 

but concerns exist about the 

sector’s vulnerability to a natural or 

deliberate introduction of foreign 

livestock, poultry, and crop pests 

and disease. Under the Agricultural

Quarantine Inspection (AQI) 

program, international passengers 

and cargo are inspected at U.S.

ports of entry to seize prohibited 

material and intercept foreign 

agricultural pests. The Homeland 

Security Act of 2002 transferred 

AQI inspections from the U.S. 

Department of Agriculture (USDA) 

to the Department of Homeland

Security (DHS) and left certain

other AQI responsibilities at USDA. 

GAO examined (1) the extent to 

which USDA and DHS have

changed the inspection program 

since the transfer, (2) how the 

agencies have managed and

coordinated their responsibilities, 

and (3) how funding for 

agricultural inspections has been

managed since the transfer.

What GAO Recommends

GAO recommends, among other 

things, that DHS identify and assess

the major risks posed by foreign

pests and disease and develop and 

implement a national staffing 

model to ensure that staff levels are 

sufficient to meet those risks and 

that DHS and USDA analyze the full

cost of performing AQI inspections 

and ensure that user fees cover the 

program’s costs. USDA and DHS 

generally agreed with the report’s

recommendations. 

After the terrorist attacks of September 11, 2001, federal agencies’ roles and 

responsibilities were modified to help protect agriculture. In March 2003, 

more than 1,800 agriculture specialists within USDA’s Animal and Plant 

Health Inspection Service (APHIS) became DHS Customs and Border 

Protection (CBP) employees, while USDA retained responsibility for AQI 

activities such as setting inspection policy, providing training, and collecting 

user fees. Since the transfer, the agencies have expanded training on 

agriculture issues for CBP officers and agriculture specialists. CBP and 

APHIS also have taken steps to enable agriculture specialists to better target 

shipments and passengers for inspections and established a process to 

assess how CBP agriculture specialists are implementing AQI policy. Finally, 

CBP created a new agriculture liaison position in each of its district field 

offices to advise regional directors on agricultural issues. 

While these are positive steps, the agencies face management and 

coordination problems that increase the vulnerability of U.S. agriculture to 

foreign pests and disease. CBP has not developed sufficient performance 

measures that take into account the agency’s expanded mission or consider 

all pathways by which prohibited agricultural items or foreign pests may 

enter the country. Specifically, although CBP’s measures focus on two 

pathways that pose a risk to U.S. agriculture, they do not consider other key 

pathways such as commercial aircraft, vessels, and truck cargo. Also, 

although CBP has hired more than 630 specialists since the transfer, it has 

not yet developed or used a risk-based staffing model to ensure that 

adequate numbers of agriculture specialists are staffed to areas of greatest 

vulnerability. CBP also has not used available inspection and interception 

data to evaluate the performance of the AQI program. CBP and APHIS also 

continue to experience difficulty in sharing information such as key policy

changes and urgent inspection alerts, and CBP has allowed the number and 

proficiency of agriculture canine units to decline.

Although APHIS is legally authorized (though not required) to charge AQI 

user fees to cover program costs, we found that the agencies have not taken 

the necessary steps to ensure that user fees cover AQI costs. Consequently,

the agencies had to use other authorized funding sources to pay for the 

program. Also, because of weaknesses in the design of CBP’s new financial 

management system, CBP was unable to provide APHIS with information on 

the actual costs of the AQI program by user-fee type—for example, fees paid

by international air passengers. APHIS uses this information to set future 

user-fee rates. Finally, in fiscal years 2004 and 2005, APHIS did not transfer 

AQI funds to CBP as agreed to by both agencies, causing some ports of entry 

to reduce spending on inspection activities in fiscal year 2005. www.gao.gov/cgi-bin/getrpt?GAO-06-644.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Daniel Bertoni 

at (202) 512-3841 or bertonid@gao.gov. 
Page i GAO-06-644 DHS Agricultural Quarantine Inspections

Contents

Letter 1

Results in Brief 3

Background 6

CBP and APHIS Have Taken Steps to Strengthen the Agriculture 

Quarantine Inspection Program 15

Management and Coordination Problems May Leave U.S. 

Agriculture Vulnerable to Foreign Pests and Disease 19

Financial Management Issues at CBP and APHIS Adversely Affect 

the AQI Program 29

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 39

Appendixes

Appendix I: Scope and Methodology 41

Appendix II: Results of GAO Survey of CBP Agricultural Specialists 44

Appendix III: Comments from the Department of Agriculture 59

GAO Comments 61

Appendix IV: Comments from the Department of Homeland Security 62

GAO Comments 68

Appendix V: GAO Contact and Staff Acknowledgments 69

Tables Table 1: Average Inspection Rates before and after the Transfer 

from APHIS to CBP 23

Table 2: Average Interception Rates before and after the Transfer 

from APHIS to CBP 24

Table 3: AQI User-Fee Collections and Program Costs, Fiscal Years 

2001 through 2005 30

Table 4: AQI User-Fee Funds Transferred from APHIS to CBP 

during Fiscal Years 2004 and 2005 34

Figures Figure 1: CBP Activity at U.S. Ports of Entry, 2005 9

Figure 2: Example of Primary and Secondary Inspection 

Procedures at Airport 12

Figure 3: Collection and Transfer of User Fees from APHIS to CBP 

for Fiscal Year 2006 36
Contents

Page ii GAO-06-644 DHS Agricultural Quarantine Inspections

Abbreviations

APHIS Animal and Plant Health Inspection Service

AQI Agricultural Quarantine Inspection

AQIM Agricultural Quarantine Inspection Monitoring

ATS Automated Targeting System

CBP Customs and Border Protection

DHS Department of Homeland Security

FACT Act Food, Agriculture, Conservation, and Trade Act of 1990

FLETC Federal Law Enforcement Training Center

FSIS Food Safety and Inspection Service

SITC Smuggling Interdiction and Trade Compliance

TECS Treasury Enforcement Communications System

USDA U.S. Department of Agriculture

WADS Work Accomplishment Data System

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Page 1 GAO-06-644 DHS Agricultural Quarantine Inspections

United States Government Accountability Office

Washington, D.C. 20548

A

May 19, 2006 Letr

The Honorable Robert F. Bennett

Chairman

The Honorable Herb Kohl

Ranking Minority Member 

Subcommittee on Agriculture, Rural Development,

and Related Agencies

Committee on Appropriations 

United States Senate

The Honorable Henry Bonilla 

Chairman

The Honorable Rosa DeLauro 

Ranking Minority Member 

Subcommittee on Agriculture, Rural Development, Food and Drug

Administration, and Related Agencies

Committee on Appropriations

House of Representatives

The Honorable Tom Harkin

Ranking Democratic Member

Committee on Agriculture, Nutrition, and Forestry

United States Senate

Agriculture—the largest industry and employer in the United States, 

generating more than $1 trillion in economic activity annually—is 

threatened by the entry of foreign pests and disease that can harm the 

economy, the environment, plant and animal health, and public health. The 

U.S. Department of Agriculture (USDA) estimates that these biological 

invaders cost the American economy tens of billions of dollars annually in 

lower crop values, eradication programs, and emergency payments to 

farmers. As we reported in 2005, the terrorist attacks of September 11, 

2001, have heightened concerns about agriculture’s vulnerability to 

terrorism, including the deliberate introduction of livestock, poultry, and 

crop diseases.1

 To safeguard U.S. agriculture from the catastrophic 

economic losses that would likely result from accidental or deliberate 

introduction of a foreign pest or disease such as avian influenza or foot1

GAO, Homeland Security: Much Is Being Done to Protect Agriculture from a Terrorist 

Attack, but Important Challenges Remain, GAO-05-214 (Washington, D.C.: Mar. 8, 2005).
Page 2 GAO-06-644 DHS Agricultural Quarantine Inspections

and-mouth disease, Department of Homeland Security (DHS) agriculture 

specialists work at ports of entry to inspect passengers, baggage, cargo, 

and mail entering the country in airplanes, ships, trucks, and railcars for 

prohibited agricultural materials that may serve as carriers of these pests 

and disease.

Since the early 1900s, USDA was responsible under its Agricultural 

Quarantine Inspection (AQI) program for inspecting agricultural products 

entering the country. Following the events of September 11, 2001, the 

Congress passed the Homeland Security Act of 2002, transferring USDA’s 

Animal and Plant Health Inspection Service (APHIS) port inspection 

activities and those of other federal inspection agencies responsible for 

monitoring the entry of passengers and cargo into the United States—the 

Department of the Treasury’s U.S. Customs Service and the Department of 

Justice’s Immigration and Naturalization Service—to the newly created 

Department of Homeland Security Customs and Border Protection (CBP).2

Beginning in March 2003, more than 1,800 frontline agriculture specialists3

who had formerly reported to APHIS became CBP employees, as CBP 

incorporated the protection of U.S. agriculture into its primary 

antiterrorism mission.4

 Unlike the other former federal inspection 

agencies, which were moved to DHS in their entirety, APHIS continues to 

exist within USDA and retains responsibility for domestic animal and plant 

programs and several AQI program activities, such as setting inspection 

policy, providing training, and collecting AQI user fees.

2

Pub. L. No. 107-296, 116 Stat. 2135 (2002). Section 421 of the Act transferred agricultural 

inspection functions from USDA to DHS; section 403 transferred Customs functions to DHS; 

and section 441 transferred the Border Patrol to DHS.

3

This number included 317 specialist vacancies that were also transferred.

4

The Department of Homeland Security’s Customs and Border Protection Service has two 

priority missions: (1) detecting and preventing terrorists and terrorist weapons from 

entering the United States, and (2) facilitating the orderly and efficient flow of legitimate 

trade and travel. CBP’s supporting missions include interdicting illegal drugs and other 

contraband; apprehending individuals who are attempting to enter the United States 

illegally; inspecting inbound and outbound people, vehicles, and cargo; enforcing all laws of 

the U.S. at the border; regulating and facilitating international trade; collecting import 

duties; enforcing U.S. trade laws; and protecting U.S. agricultural and economic interests 

from harmful pests and disease.
Page 3 GAO-06-644 DHS Agricultural Quarantine Inspections

Responding to concerns that the transfer of agricultural inspections from 

APHIS to CBP could shift the focus away from agriculture to other DHS 

priorities, the conference report accompanying the Consolidated 

Appropriations Act for Fiscal Year 2005 requested that we report on 

coordination between USDA and DHS to ensure that U.S. agriculture is 

protected from accidentally or intentionally introduced pests and disease.5

We also received a request from the Ranking Member of the Senate 

Agriculture, Nutrition, and Forestry Committee to evaluate AQI inspection 

issues. As agreed with your offices, we are presenting our responses to 

both requests in this report. 

This report assesses (1) the extent to which USDA and DHS have changed 

the Agricultural Quarantine Inspection program since the transfer of 

responsibilities from USDA to DHS, (2) how the departments have 

managed and coordinated their responsibilities, and (3) how funding for 

agricultural inspections has been managed since the transfer from USDA to 

DHS.

To address these objectives, we surveyed a nationally representative 

sample of agriculture specialists about their work experiences since the 

transfer; analyzed APHIS’s inspection and interception data for fiscal years 

2000 through 2005; visited agriculture training facilities in Florida, Georgia, 

and Maryland; and reviewed interagency agreements related to the AQI 

program and other documentation, such as staffing information, training 

materials, budget information, and financial systems that CBP uses to track 

AQI-related costs. We also interviewed key program officials at APHIS and 

CBP headquarters and field offices. We performed a reliability assessment 

of the data we analyzed and determined that the data were sufficiently 

reliable for the purposes of this report. More details on our scope and 

methodology appear in appendix I. We conducted our review from April 

2005 through March 2006 in accordance with generally accepted 

government auditing standards.

Results in Brief Since the transfer of AQI responsibilities from APHIS to CBP, the two 

agencies have taken several steps to strengthen the agricultural quarantine 

inspection program and integrate agriculture issues into CBP’s passenger 

and cargo inspection programs. First, CBP has undertaken several training 

5

H.R. Rep. No. 108-792, at 666 (2004).
Page 4 GAO-06-644 DHS Agricultural Quarantine Inspections

initiatives for CBP officers, whose primary duty is customs and 

immigration inspection. Newly hired officers are trained in agricultural 

issues at the Federal Law Enforcement Training Center and at their 

respective ports of entry. The training provides them with basic agriculture 

knowledge to help them determine when to refer passengers and cargo to 

CBP agriculture specialists for in-depth inspections. Second, CBP 

agriculture specialists now have access to CBP’s classified data systems, 

which enables them to better target for inspection passengers and cargo 

posing the greatest risk of introducing pests and disease into the United 

States. For example, agriculture specialists now use CBP’s Automated 

Targeting System to identify high-risk shipments before they enter the 

United States. Third, in fiscal year 2005, CBP and APHIS established a 

formal assessment process to ensure that ports continue to carry out 

agricultural inspections in accordance with APHIS’s regulations, policies, 

and procedures. Finally, to help ensure that agriculture issues are 

sufficiently addressed, CBP recently established agriculture liaisons in 

each of its 20 district field offices to provide input to operational decisions 

made by CBP field office directors—who oversee ports of entry—and 

provide senior-level leadership for agriculture specialists.

Despite efforts to improve the AQI program, key management and 

coordination challenges exist that increase the vulnerability of U.S. 

agriculture to foreign pests and disease. First, CBP has not adopted 

sufficient performance measures for AQI. Instead, it carried over the two 

performance measures that APHIS used before the transfer, which neither 

take into account CBP’s expanded mission nor consider other important 

pathways—commercial aircraft, vessels, and truck cargo—that may pose a 

risk to U.S. agriculture. Second, although APHIS updated a staffing model 

shortly after the transfer with recommendations for the number of 

agriculture specialists necessary to staff the various ports, CBP did not use 

it, or any other model, when determining where to assign the more than 600 

agriculture specialists hired since the transfer. As a result, CBP does not 

have reasonable assurance that these specialists are staffed to areas of 

greatest vulnerability. Although CBP officials told us the agency is planning 

to develop its own staffing model, it has not yet done so. Third, agriculture 

specialists routinely input data on inspection activities and outcomes, but 

CBP has not used these data to evaluate the performance of the AQI 

program. Our analysis of this data indicates that performance varies 

significantly across different regions of the United States. Fourth, despite 

an interagency agreement intended to facilitate coordination and 

communication between CBP and APHIS, agriculture specialists are not 

consistently receiving notifications of changes to inspection policies and 
Page 5 GAO-06-644 DHS Agricultural Quarantine Inspections

urgent inspection alerts, in large part because of problems with 

dissemination of information down the CBP chain of command. For 

example, on the basis of our survey results, we estimate that only 21 

percent of agriculture specialists always receive urgent alerts in a timely 

manner. Finally, CBP has allowed the agriculture canine program—a key 

tool for targeting passengers and cargo for detailed inspections—to 

deteriorate. Currently, dozens more agriculture canine units are vacant, and 

the proficiency scores of the remaining canine units have declined, limiting 

the essential contributions these dogs can make to preventing entry of 

prohibited agricultural items. 

Financial management issues at CBP and APHIS adversely affect the AQI 

program’s ability to perform border inspections. First, although the law 

authorizes (but does not require) user fees to cover all costs of the AQI 

program, in the 3 years since the transfer, user fees have not been sufficient 

to cover program costs. Consequently, in fiscal years 2003 through 2005, the 

agencies had to use AQI fees collected in previous fiscal years or other 

available appropriations to pay for the program. CBP has stated that 

without increasing current user-fee rates, AQI program costs will continue 

to exceed user-fee collections. APHIS and CBP plan to address the funding 

issue, but they have only recently begun to work together to reassess userfee rates. Second, because of a weakness in the design of CBP’s new 

financial management system, CBP was unable to provide APHIS with 

information on the actual costs of the AQI program broken out by user-fee 

type—for example, fees paid by international air passengers—for fiscal 

year 2005. As a result, APHIS was not able to evaluate the extent to which 

individual user fees cover program costs. CBP officials told us that, for 

fiscal year 2006, CBP is working to correct this weakness. Finally, although 

APHIS agreed to transfer funds to CBP on a regular basis during fiscal 

years 2004 and 2005, these transfers were often delayed and their amounts 

varied from what was agreed to. This is partly due to APHIS making errors 

in processing some transfers. As a result, some ports had to reduce 

spending for needed supplies or delay hiring personnel in fiscal year 2005, 

according to CBP officials. In October 2005, the agencies signed a revised 

agreement specifying the schedule and amounts to be transferred, which, 

according to APHIS and CBP officials, will help address some of these 

problems. However, of the three scheduled payments APHIS has made so 

far this fiscal year, one was $20,000 less than the agreed upon amount.

We are making several recommendations aimed at helping the agencies 

ensure the effectiveness of agricultural quarantine inspection programs 

and protect U.S. agriculture from accidental or deliberate introduction of 
Page 6 GAO-06-644 DHS Agricultural Quarantine Inspections

foreign pests and disease. For example, we recommend that the Secretary 

of Homeland Security address financial management issues to ensure 

financial accountability for AQI funds. We also recommend that the 

Secretary of Agriculture ensure the timely and accurate transfer of AQI 

user fees to DHS. Finally, we recommend that the Secretaries of Homeland 

Security and Agriculture work together to revise AQI program performance 

measures, develop a risk-based staffing model, improve interagency 

communication to ensure that agriculture specialists receive important 

information, strengthen the canine program, and address user-fee issues 

that threaten the viability of the AQI program.

In commenting on a draft of this report, USDA and DHS generally agreed 

with the report’s recommendations and noted that various initiatives are 

either planned or under way to address our recommendations. USDA’s 

comments and our response are contained in appendix III, and DHS’s 

comments and our response are contained in appendix IV. The departments 

also provided technical comments, which we have incorporated into this 

report, as appropriate.

Background Agricultural inspections at U.S. ports of entry had been the responsibility of 

USDA since 1913. Following the events of September 11, 2001, the 

Congress passed the Homeland Security Act of 2002, which combined the 

inspection activities of the Department of the Treasury’s Customs Service, 

the Department of Justice’s Immigration and Naturalization Service, and 

APHIS into the newly created DHS Customs and Border Protection (CBP). 

Among other things, the act (1) transferred, to the Department of 

Homeland Security, APHIS’s responsibility for inspecting passenger 

declarations and cargo manifests, international air passengers, baggage, 

cargo, and conveyances and holding suspect articles in quarantine to 

prevent the introduction of plant or animal diseases; and (2) authorized 

USDA to transfer up to 3,200 agricultural quarantine inspection (AQI) 

personnel to DHS. 
Page 7 GAO-06-644 DHS Agricultural Quarantine Inspections

The Secretaries of the Department of Homeland Security (DHS) and the 

United States Department of Agriculture (USDA) signed a memorandum of 

agreement in February 2003, agreeing to work cooperatively to implement 

the relevant provisions of the Homeland Security Act of 2002 and to ensure 

necessary support for and coordination of the AQI program functions.6

 The 

agreement detailed how the AQI program was to be divided, with some 

functions transferred to DHS and others retained by USDA. Agricultural 

import and entry inspection functions transferred to DHS included (1) 

reviewing passenger declarations and cargo manifests and targeting for 

inspection high-risk agricultural passenger/cargo shipments; (2) inspecting 

international passengers, luggage, cargo, mail, and means of conveyance; 

and (3) holding suspect cargo and articles for evaluation of plant and 

animal health risk in accordance with USDA regulations, policies, and 

guidelines. Functions remaining in USDA included (1) providing riskanalysis guidance, including in consultation with DHS, and the setting of 

inspection protocols; (2) applying remedial measures other than 

destruction and re-exportation, such as fumigation, to commodities, 

conveyances, and passengers; and (3) providing pest identification services 

at plant inspection stations and other facilities. The parties agreed to 

cooperate in the financial management functions, including development 

of annual plans and budgets, AQI user fees, and funds control and financial 

reporting procedures. 

To carry out its new inspection responsibilities, CBP established a “One 

Face at the Border” initiative, which unified the customs, immigration, and 

agricultural inspection processes by cross-training CBP officers and 

agriculture specialists to (1) prevent terrorists, terrorist weapons, and 

contraband from entering the United States; (2) identify people seeking to 

enter the United States illegally and deny them entry; and (3) protect U.S. 

agricultural and economic interests from harmful pests and diseases.

Unlike the Customs Service and the Immigration and Naturalization 

Service, which were moved to DHS in their entirety, APHIS continues to 

exist within USDA and retains responsibility for conducting veterinary 

inspections of live imported animals; establishing policy for inspections 

and quarantines; providing risk analysis; developing and supervising 

6

See Memorandum of Agreement Between the United States Department of Homeland 

Security and the United States Department of Agriculture (DHS Agreement Number: BTS03-0001; USDA-APHIS Agreement Number: 03-1001-0382-MU) at 

http://www.aphis.usda.gov/ppq/moa-dhs.html (downloaded Apr. 24, 2006).
Page 8 GAO-06-644 DHS Agricultural Quarantine Inspections

training on agriculture for CBP agriculture specialists; conducting 

specialized inspections of plant or pest material; identifying agricultural 

pests; and collecting AQI user fees. CBP and APHIS agreed to support their 

respective AQI duties by sharing funds from USDA-collected AQI user fees 

levied on international air passengers, commercial aircraft, ships, trucks, 

and railroad cars.

CBP agriculture specialists are assigned to 161 of the 317 ports of entry that 

CBP staffs.7

 As shown in figure 1, these ports collectively handle thousands 

of sea containers and aircraft and over a million passengers each day.

7

Current as of February 2006.
Page 9 GAO-06-644 DHS Agricultural Quarantine Inspections

Figure 1: CBP Activity at U.S. Ports of Entry, 2005

Sources: GAO analysis of CBP data; MapArt (map).

Seattle

Detroit

Chicago

Laredo

Houston

Portland

Hawaii Alaska Puerto Rico

Los Angeles

San Diego

Boston

Buffalo

New York

Baltimore

San

Francisco

Miami

Tampa

San Juan

Tuscon El Paso

New Orleans

Atlanta

District field office (region)

Port of entry staffed with agriculture specialists

Day in the Life of CBP at the Borders

• 1,181,605 passengers and pedestrians

• 333,226 incoming privately owned vehicles

• 235,732 incoming international air passengers

• 79,107 shipments of goods approved for entry

• 71,858 passengers/crew arriving by ship

• 69,370 truck, rail, and sea containers

• 1,145 seized prohibited meat, plant materials, 

or animal products, including 147 agricultural 

pests at ports of entry
Page 10 GAO-06-644 DHS Agricultural Quarantine Inspections

Each port of entry can comprise one or more facilities—airports, seaports, 

or land border crossings—where CBP officers and agriculture specialists 

process arriving passengers and cargo. For example, the port of Buffalo, 

New York, has an airport and land border inspection facilities, whereas the 

Port of Atlanta has only the Atlanta Hartsfield/Jackson International 

Airport. Individual port directors are responsible for overseeing port 

operations and assigning agriculture specialists to specific port facilities. 

The ports are organized into 20 district field offices, each with a director of 

field operations who is responsible for the operation of multiple ports in a 

given geographic area and serves as a liaison between CBP headquarters 

and port management.

Day-to-day operations for agriculture specialists may include inspecting 

pedestrians, passengers, cargo, and vehicles for pests and contraband. 

Such inspections generally follow a two-stage process—primary and 

secondary inspections. Figure 2 shows the passenger inspection process at 

an international airport, as an example.
Page 11 GAO-06-644 DHS Agricultural Quarantine Inspections

[This page left intentionally blank]
Page 12 GAO-06-644 DHS Agricultural Quarantine Inspections

Figure 2: Example of Primary and Secondary Inspection Procedures at Airport

Passenger deplanes

and proceeds to

immigration

Passenger claims

baggage

CPB officer reviews customs

documents and interviews

passenger

CBP agriculture K-9 team searches

baggage area

Primary inspection performed by CBP officers

No

Maybe

Passenger is referred to 

secondary agriculture 

inspection

A

B

Determine whether 

passenger could 

be carrying a

prohibited

agriculture

item?
Page 13 GAO-06-644 DHS Agricultural Quarantine Inspections

a

After material has been seized, the agriculture specialist either sends an unknown detected pest to 

the APHIS pest identifiers or the material is sent to the incinerator to be destroyed. 

A primary inspection could include questioning passengers about their 

origin and destination, reviewing their written declarations, and screening 

their baggage with detector dogs to determine whether to refer the 

passengers for a secondary inspection. A secondary inspection involves a 

more detailed questioning of the passenger and an examination of their 

baggage by X-ray and, if necessary, by hand search. Procedures for 

inspecting commercial shipments vary according to factors such as the 

type of agricultural product, risk level associated with the product, and 

country of origin. To reduce the risk of foreign pests and disease entering 

Does

passenger

questioning or 

the X-ray show

possible prohibited

agriculture

item?

Does

agriculture

specialist find a

prohibited

agriculture

item?

Secondary inspection by CBP agriculture specialist

No No

Yes

Yes

Baggage is screened Passenger and baggage

are hand searched

Passenger exits

the airport

Seize quarantine material

a

Agriculture Specialist

may impose fine

Passenger and

baggage released

Interview with agriculture 

specialist

Passenger is given any 

opportunity to surrender the 

prohibited agriculture items

A

B

Source: GAO analysis of CBP documents and interviews.
Page 14 GAO-06-644 DHS Agricultural Quarantine Inspections

the United States, agriculture specialists review cargo documents to select 

shipments for more detailed physical inspection.

The Food, Agriculture, Conservation, and Trade Act of 1990, as amended 

(FACT Act), authorizes APHIS to set and collect user fees for AQI services 

provided in connection with the arrival of international air passengers and 

conveyances (e.g., commercial aircraft and trucks) at a port in the customs 

territory of the United States.8 The six AQI user fees are assessed on 

international air passengers, commercial aircraft, commercial vessels, 

commercial trucks, commercial truck decals, and commercial railroad 

cars.9

 These user fees are paid directly by shipping companies or indirectly 

by air passengers through taxes on tickets. The international passenger and 

commercial aircraft fees are calculated and remitted quarterly by the 

individual airline companies to USDA, while rail car fees are remitted 

monthly. CBP collects the commercial vessel, truck, and truck decal fees at 

the time of inspection. International air passengers and commercial 

conveyances entering the United States from Canada are exempt from the 

user fees. The FACT Act authorizes user fees for (1) providing AQI services 

for the conveyances, cargo, and passengers listed above; (2) providing 

preclearance or preinspection at a site outside the customs territory of the 

United States to international airline passengers, commercial vessels, 

commercial trucks, commercial railroad cars, and commercial aircraft; and 

(3) administering the AQI user-fee programs.

AQI user fees have been revised several times since the FACT Act was 

passed in 1990. In November, 1999, APHIS published a final rule in the 

Federal Register that amended the user-fee regulations by adjusting the 

fees charged for certain AQI services for part of fiscal year 2000 and for 

fiscal years 2001 and 2002.10 The user-fee adjustments were intended to 

ensure that APHIS covered the anticipated actual cost of providing AQI 

services. Subsequent rule making, culminating in a final rule published in 

the Federal Register on January 24, 2003, extended the adjusted fees

8

21 U.S.C. § 136a(a)(1). These fees are to be credited to the Department of Agriculture 

accounts that incur the costs associated with the AQI services. The fees remain available 

until expended without fiscal year limitation.

9

In addition to the six agriculture user fees, CBP inspections are supported by 32 other user 

fees that are administered by the Departments of the Treasury and Justice. Each 

department’s user fees include separate rate structures and country exemptions.

1064 Fed. Reg. 62089 (Nov. 16, 1999).
Page 15 GAO-06-644 DHS Agricultural Quarantine Inspections

indefinitely, beyond fiscal year 2002, until the fees are revised again.11 On 

December 9, 2004, APHIS published an interim rule to raise user fees, 

effective January 1, 2005.12

CBP and APHIS Have 

Taken Steps to 

Strengthen the 

Agricultural 

Quarantine Inspection 

Program

Since the transfer of agricultural quarantine inspections to CBP, the agency 

has increased training in agricultural issues for CBP officers and developed 

a national standard for in-port training. In addition, CBP and APHIS have 

enhanced the ability of agriculture specialists to better target inspections at 

the ports. The two agencies also established a joint program to review the 

agricultural inspections program on a port-by-port basis, and CBP created 

new agricultural liaison positions at the field office level to advise regional 

port directors on agricultural issues.

CBP and APHIS Have 

Expanded Training on 

Agriculture Issues

CBP has undertaken several training initiatives for CBP officers, whose 

primary duty is customs and immigration inspection. Under CBP, newly 

hired CBP officers receive 16 hours of training on agricultural issues at the 

Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia. 

Under APHIS, agriculture courses for Customs and Immigrations officers 

had been limited to 4 hours and 2 hours, respectively, of classroom 

overviews on agriculture issues. The revamped training provides the newly 

hired CBP officers with basic agriculture information so they know when 

to either prohibit entry or refer potential agricultural threats to CBP 

agriculture specialists. In addition to a more comprehensive course, the 

curriculum provides for additional testing on AQI knowledge. For example, 

classroom simulations include agricultural items, and CBP officers’ written 

proficiency tests now include questions on agricultural inspections. 

In addition, CBP and APHIS have undertaken an initiative to expand 

agriculture training for all CBP officers at their respective ports of entry. 

The purpose of these modules—designed for Customs and Immigration 

officers—was to provide officers with the ability to make informed 

decisions on agricultural items at high-volume border traffic areas or to 

facilitate the clearance of travelers and cargo at ports without agriculture 

specialists, such as some ports of entry along the Canadian border. 

1168 Fed. Reg. 3375 (Jan. 24, 2003).

1269 Fed. Reg. 71660.
Page 16 GAO-06-644 DHS Agricultural Quarantine Inspections

According to agency officials, the agencies have now expanded training to 

16 hours of lecture and 8 hours of on-the-job training, including 

environment-specific modules for six inspection environments: northern 

border, southern border, international mail/expedited courier, maritime, 

airport processing, and preclearance (i.e., inspections of passengers and 

cargo prior to arrival in the United States). 

Additionally, CBP and APHIS have formalized the in-port training program 

and have developed a national standard for agriculture specialists. Under 

APHIS, depending on the port to which they were assigned, newly hired 

agriculture specialists spent anywhere from 1 week to 1 year shadowing 

senior agriculture specialists. After the transfer, CBP formalized this 

process to ensure all agriculture specialists were receiving the necessary 

on-the-job training. This formalized process includes a checklist of 

activities for agriculture specialists to master and is structured in two 

modules: an 8-week module on passenger inspection procedures and a 10-

week module on cargo inspection procedures.

Based on our survey of agriculture specialists, we estimate that 75 percent 

of specialists hired by CBP believe that they received sufficient training (on 

the job and at the Professional Development Center) to enable them to 

perform their agriculture inspection duties. An estimated 13 percent of 

specialists believe that they probably or definitely did not receive adequate 

training, and another 13 percent either were uncertain or did not answer 

the question. (See app. II, survey question 12.)

CBP and APHIS Have Taken 

Steps to Improve Targeting 

of Agricultural Inspections

CBP and APHIS have also taken steps to better identify and target 

shipments and passengers that present potentially high risk to U.S. 

agriculture. Under CBP, some agriculture specialists receive training and 

access to computer applications such as CBP’s Automated Targeting 

System (ATS), which is a computer system that, among other things, is 

meant to (1) identify high-risk inbound and outbound passengers and cargo 

for terrorist links, smuggling of WMD, drugs, currency, and other 

contraband; (2) focus limited inspection resources on higher-risk 

passengers and cargo; (3) facilitate expedited clearance or entry for lowrisk passengers and cargo; and (4) enable users to create ad-hoc queries to
Page 17 GAO-06-644 DHS Agricultural Quarantine Inspections

filter data to meet specific research needs.13 ATS helps agriculture 

specialists select which cargo shipments to inspect based on detailed 

information contained in the cargo manifests and other documents that 

shipping companies are required to submit before the ship arrives in a port. 

CBP and APHIS headquarters personnel also use ATS data to identify 

companies that have violated U.S. quarantine laws. For example, recently 

the two agencies used ATS to help identify companies that have smuggled 

poultry products in seafood containers from Asia, according to a senior 

APHIS official. The U.S. currently bans uncooked poultry products from 

Asian countries because of concerns over avian influenza.

CBP and APHIS are working together to further refine ATS’s effectiveness 

in identifying and targeting shipments of agricultural products. Specifically, 

APHIS assigned a permanent liaison to the CBP National Targeting Center 

in April 2005 to help develop a rule set (a computerized set of criteria) that 

will automate the process of identifying companies or individuals that pose 

a significant agroterrorism risk to U.S. agriculture. According to the APHIS 

liaison, the rule set will eventually be applicable to nonagroterrorism 

events, such as smuggling and shipments that are not compliant with U.S. 

quarantine regulations. CBP officials told us that the agency has set a 

September 2006 release date for the first version of the rule set. CBP 

officials also told us that the agency is testing an interim rule set for highrisk commodities regulated by USDA’s Food Safety Inspection Service 

(FSIS) that they expect to release in July 2006.14

In addition to ATS, agriculture specialists now also have access to the 

Treasury Enforcement Communications System (TECS)—a computerized 

information system for identifying individuals and businesses suspected of 

violating federal law. TECS serves as a communications system between 

Treasury law enforcement offices and other federal, state, and local law 

enforcement agencies. 

13We did not independently assess DHS’s use of ATS for agricultural inspections. CBP 

commented that agriculture specialists receive on-the-job training in ATS. No classroom 

training has been provided, with the exception of 3 classes in fiscal year 2005 for agriculture 

specialists in maritime.

14The FSIS rule set contains criteria that identify (1) shipments entering ports with no 

nearby inspection house, (2) shipments not listing companies identified as approved foreign 

producers of beef and poultry products, (3) shipments not listing companies identified as 

approved foreign producers of certain other agricultural products, (4) shipments from 

countries not authorized to export certain agricultural products to the United States, (5) 

FSIS prior violators, and (6) shipments from countries of interest to CBP.
Page 18 GAO-06-644 DHS Agricultural Quarantine Inspections

ATS and TECS complement other targeting tools already used by 

agriculture specialists under APHIS. Specifically, agriculture specialists 

continue to use CBP’s Automated Commercial System to review the 

manifests of incoming shipments. At select ports, agriculture specialists 

also continue to use APHIS’s Agricultural Quarantine Inspection 

Monitoring (AQIM) system to estimate the amount of quarantine items or 

pests entering the country. CBP agriculture specialists submit AQIM data to 

APHIS, where it is used to estimate the extent to which agricultural pests 

and diseases approach the United States through various pathways (e.g., 

international air passengers).

CBP and APHIS Have 

Established a Review 

Process for Assessing Port 

Compliance with 

Agricultural Inspection 

Policy

In fiscal year 2005, CBP and APHIS established a formal assessment 

process to ensure that ports of entry continue to carry out agricultural 

inspections in accordance with APHIS’s regulations, policies, and 

procedures. According to an APHIS official, the new formal assessment 

process is a means for APHIS to gather some of the information necessary 

to formulate agricultural inspection policy. The assessments, called Joint 

Agency Quality Assurance Reviews, entail a visit to ports by APHIS and 

CBP officials, who complete a questionnaire based on interviews with the 

port director and other CBP personnel and through direct observation of 

port operations by the review team. The reviews cover topics such as (1) 

coordination with other federal agencies, (2) training for agriculture 

specialists, (3) access of agriculture specialists to regulatory manuals, and 

(4) processes for handling violations at the port, inspecting passenger 

baggage and vehicles, and intercepting, seizing, and disposing of 

confiscated materials.

The review teams report on best practices and deficiencies at each port and 

make recommendations for corrective actions. For example, a review of 

two ports found that they were both significantly understaffed, and that 

CBP agriculture specialists at one of the ports were conducting superficial 

inspections on commodities that should have been inspected more 

intensely. At the same ports, the review identified best practices in the 

placing of personnel from CBP, APHIS, and FDA in the same facility and the 

targeting of tile imports from Italy and Turkey for possible agroterrorism 

risks.15 As of February 2006, the joint review team has conducted reviews 

15Imports of nonagricultural products such as tile may impact agriculture because, 

according to APHIS, wood packing material used to help transport tile has been a major 

source of pest interceptions.
Page 19 GAO-06-644 DHS Agricultural Quarantine Inspections

of nine ports, and the agencies plan to complete seven additional reviews in 

fiscal year 2006, according to a senior APHIS official.

CBP Has Established New 

Agriculture Liaisons to 

Advise Regional Directors

In May 2005, CBP required that each director in its 20 field offices identify 

and appoint an agriculture liaison, with background and experience as an 

agriculture specialist, to provide CBP field office directors with agriculturerelated input for operational decisions and provide agriculture specialists 

with senior-level leadership. CBP officials told us that all district field 

offices had established the liaison position as of January 2006. The CBP 

agriculture liaison duties include, among other things, advising the director 

of the field office on agricultural functions; providing oversight for data 

management, statistical analysis, and risk management; and providing 

oversight and coordination for agriculture inspection alerts. 

Since the creation of the position, agriculture liaisons have begun to 

facilitate the dissemination of urgent alerts from APHIS to CBP. For 

example, following a large increase in the discovery of plant pests at a port 

in November 2005, the designated agriculture liaison sent notice to APHIS, 

which then issued alerts to other ports. Subsequent communications 

between APHIS and CBP identified the agriculture liaison at the initial port 

as a contact for providing technical advice for inspecting and identifying 

this type of plant pest.

Management and 

Coordination Problems 

May Leave U.S. 

Agriculture Vulnerable 

to Foreign Pests and 

Disease

Several management and coordination problems exist that may leave U.S. 

agriculture vulnerable to foreign pests and disease. CBP has not developed 

sufficient performance measures to manage and evaluate the AQI program. 

CBP also has not developed a staffing model to determine how to allocate 

newly hired agriculture specialists or used available data to evaluate the 

effectiveness of the AQI program. In addition, information sharing and 

coordination between CBP and APHIS has been problematic. Finally, the 

agriculture canine program has deteriorated.

CBP Lacks Adequate 

Performance Measures for 

Agricultural Quarantine 

Inspections

The Government Performance and Results Act of 1993 requires federal 

agencies to develop and implement appropriate measures to assess
Page 20 GAO-06-644 DHS Agricultural Quarantine Inspections

program performance.16 Yet, 3 years after the transfer, CBP has yet to 

develop and implement its own performance measures for the AQI 

program despite changes in the program’s mission. Instead, according to 

senior CBP officials, CBP carried over two measures that APHIS used to 

assess the AQI program before the transfer: the percentage of (1) 

international air passengers and (2) border vehicle passengers that comply 

with AQI regulations. However, these measures address only two 

pathways, neglecting commercial aircraft, vessel, and truck cargo 

pathways. CBP’s current performance measures also do not provide 

information about changes in inspection and interception rates, which 

could prove more useful in assessing the efficiency and effectiveness of 

agriculture inspections in different regions of the country or at individual 

ports of entry. They also do not address the AQI program’s expanded 

mission—to prevent agroterrorism while facilitating the flow of legitimate 

trade and travel. CBP officials told us that the agency recognizes that the 

current performance measures are not satisfactory and is planning new 

performance measures for the fiscal year 2007 performance cycle. 

However, such measures had not yet been developed at the time of our 

review.

CBP Made Progress Hiring 

Agriculture Specialists but 

Still Lacks a Risk-Based 

Staffing Model

To accomplish the split in AQI responsibilities in March 2003, APHIS 

transferred a total of 1,871 agriculture specialist positions, including 317 

vacancies, and distributed these positions across CBP’s 20 district field 

offices.17 According to senior officials involved with the transfer, APHIS’s 

determinations were made under tight time frames and required much 

guess work. As a result, from the beginning, CBP lacked adequate numbers 

of agriculture specialists and had little assurance that the appropriate 

numbers of specialists were staffed at the ports of entry. Since then, CBP 

has hired more than 630 specialists, but the agency has not yet developed 

or used a risk-based staffing model for determining where to assign its 

agriculture specialists.

Our guidelines for internal control in the federal government state that 

agencies should have adequate mechanisms in place to identify and analyze 

1631 U.S.C. §§ 1115-1116.

17CBP organizes individual ports of entry into 20 district field offices that are composed of 

individual ports of entry. At the time of the transfer, agriculture specialists (or vacancies) 

were assigned to 139 individual ports of entry.
Page 21 GAO-06-644 DHS Agricultural Quarantine Inspections

risks and determine what actions should be taken to mitigate them.18 One 

such risk involves the changing nature of international travel and 

agricultural imports, including changes to the (1) volume of passengers and 

cargo, (2) type of agricultural products, (3) countries of origin, and (4) 

ports of entry where passengers and cargo arrive in the United States. One 

action to mitigate risk is development and implementation of a staffing 

model to help determine appropriate staffing levels to address these 

changing operating conditions. 

APHIS developed a staffing model, prior to the transfer of AQI functions to 

CBP, to calculate the number of agriculture specialists necessary to staff 

the various ports according to work load. However, according to APHIS 

officials, the model was no longer useful because it had not considered the 

split of inspectors between the two agencies. Although APHIS updated the 

model in June 2004 at CBP’s request, CBP still did not use this or any other 

staffing model when assigning the newly hired specialists to the ports. 

According to CBP officials, the agency did not use APHIS’s model because 

it did not consider some key variables, such as the use of overtime by 

staff.19 CBP officials also told us the agency is planning to develop its own 

staffing model, but they were unable to provide us with planned milestones 

or a timeline for completion. Until such a risk-based model is developed 

and implemented, CBP does not know if it has an appropriate number of 

agriculture specialists at each port.

An area of potential vulnerability that should be considered in staffing the 

ports relates to the experience level of agriculture specialists at the ports. 

More than one-third of CBP agriculture specialists were hired since the 

transfer—and most within the last year. For example, San Francisco lost 19 

specialists since 2003 but gained only 14 new hires or transfers, leaving 24 

vacancies as of the end of fiscal year 2005. APHIS officials expressed 

concern about the turnover of staff at some ports because many of the 

newly hired CBP agriculture specialists “will need time to get up to speed 

and do not possess the institutional knowledge related to agricultural 

issues that the more seasoned specialists had.” The official added that the 

18See GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-

21.3.1 (Washington, D.C.: November 1999).

19APHIS commented that overtime is unpredictable and, therefore, should not be considered 

by the staffing model. Rather, the staffing model could have been adjusted to account for 

longer hours of coverage.
Page 22 GAO-06-644 DHS Agricultural Quarantine Inspections

experience level of specialists is of particular concern at ports of entry 

staffed by only 1 or 2 agriculture specialists.

CBP Has Not Used Key Data 

to Evaluate Effectiveness of 

AQI Program

According to APHIS, data in its Work Accomplishment Data System 

(WADS) can help program managers evaluate the performance of the AQI 

program by indicating changes in a key measure—the frequency with 

which prohibited agricultural materials and reportable pests are found 

(intercepted) during inspection activities. CBP agriculture specialists 

routinely record data in WADS for each port of entry, including monthly 

counts of (1) arrivals of passengers and cargo to the United States via 

airplane, ship, or vehicle; (2) agricultural inspections of arriving passengers 

and cargo; and (3) inspection outcomes (i.e., seizures or detections of 

prohibited (quarantined) agricultural materials and reportable pests). 

However, CBP has not used this data to evaluate the effectiveness of the 

AQI program. Our analysis of the data shows that average inspection and 

interception rates have changed significantly in some geographical regions 

of the United States, with rates increasing in some regions and decreasing 

in others (see tables 1 and 2).

Table 1 compares average inspection rates—the number of passenger and 

cargo inspections relative to the total number of arrivals in each CBP 

district field office—for the 42 months before and 31 months after the 

transfer. Average inspection rates declined significantly in five district field 

offices (Baltimore, Boston, Miami, San Francisco, and “Preclearance” in 

Canada, the Caribbean, and Ireland), whereas rates increased significantly 

in seven other districts (Buffalo, El Paso, Laredo, San Diego, Seattle, 

Tampa, and Tucson).
Page 23 GAO-06-644 DHS Agricultural Quarantine Inspections

Table 1: Average Inspection Rates before and after the Transfer from APHIS to CBP

Source: GAO calculations of APHIS’s Work Accomplishment Data System, fiscal years 2000-2005.

a

Because of rounding, values in the difference column may not equal the difference between rounded 

inspection rates.

b

Statistical significance for each field office was calculated at the 99.75 percent confidence level so that 

the confidence level of all 21 statistical significance outcomes, collectively, is about 95 percent.

c

Preclearance inspections were conducted at 14 locations in Canada, the Caribbean, and Ireland. 

Individuals arriving in the U.S. from those locations did not undergo another inspection upon arrival in 

the United States. According to CBP, preclearance inspections were done only as a pilot and not as an 

ongoing program within the agency.

Similarly, table 2 compares average interception rates—the number of pest 

interceptions relative to the total number of passenger and cargo 

inspections in each CBP district field office—for the two periods of time. 

The average rate of interceptions decreased significantly at ports in six 

Percent

District field office

Average inspection rate 

before (October 1999-

February 2003)

Average inspection rate 

after (March 2003-

September 2005) Differencea

Statistical

significanceb

Atlanta 9.7 8.8 -0.9 No

Baltimore 18.2 10.0 -8.2 Yes

Boston 30.9 13.0 -17.9 Yes

Buffalo 0.1 0.5 0.3 Yes

Chicago 18.0 18.5 0.5 No

Detroit 3.1 2.9 -0.2 No

El Paso 2.9 4.4 1.5 Yes

Houston 13.2 12.1 -1.1 No

Laredo 7.7 8.8 1.1 Yes

Los Angeles 12.5 10.4 -2.1 No

Miami 35.8 23.1 -12.7 Yes

New Orleans 37.6 41.8 4.3 No

New York 12.0 11.8 -0.2 No

Preclearancec 7.8 3.4 -4.4 Yes

Portland 13.0 12.6 -0.4 No

San Diego 12.6 16.3 3.6 Yes

San Francisco 40.4 19.0 -21.4 Yes

San Juan 62.4 57.6 -4.8 No

Seattle 2.3 3.1 0.8 Yes

Tampa 19.6 30.7 11.1 Yes

Tucson 2.6 4.0 1.4 Yes
Page 24 GAO-06-644 DHS Agricultural Quarantine Inspections

district field offices—El Paso, New Orleans, New York, San Juan, Tampa, 

and Tucson—while average interception rates have increased significantly 

at ports in the Baltimore, Boston, Detroit, Portland, and Seattle districts. 

Decreases in interception rates, in particular, may indicate that some CBP 

districts are less effective at preventing entry of prohibited materials since 

the transfer from APHIS to CBP. 

Table 2: Average Interception Rates before and after the Transfer from APHIS to CBP

Source: GAO calculations of APHIS’s Work Accomplishment Data System, fiscal years 2000-2005.

a

Because of rounding, values in the difference column may not equal the difference between rounded 

interception rates.

b

Statistical significance for each field office was calculated at the 99.75 percent confidence level so that 

the confidence level of all 21 statistical significance outcomes, collectively, is about 95 percent.

Percent

District field office

Average interception 

rate before (October 

1999-February 2003)

Average interception 

rate after (March 2003-

September 2005) Differencea

Statistical 

significanceb

Atlanta 10.7 11.5 0.8 No

Baltimore 7.6 10.4 2.8 Yes

Boston 3.9 12.4 8.5 Yes

Buffalo 15.4 30.2 14.8 No

Chicago 6.8 5.6 -1.3 No

Detroit 7.7 20.7 13.0 Yes

El Paso 9.4 5.7 -3.7 Yes

Houston 7.9 8.4 0.4 No

Laredo 4.4 3.9 -0.5 No

Los Angeles 7.4 8.7 1.3 No

Miami 5.3 5.8 0.4 No

New Orleans 5.9 3.5 -2.4 Yes

New York 18.1 10.2 -7.9 Yes

Preclearancec 10.1 24.4 14.2 Yes

Portland 9.6 14.9 5.3 Yes

San Diego 1.3 1.4 0.2 No

San Francisco 10.5 10.6 0.1 No

San Juan 6.1 3.5 -2.5 Yes

Seattle 30.1 46.5 16.4 Yes

Tampa 8.3 3.0 -5.2 Yes

Tucson 9.0 7.0 -2.0 Yes
Page 25 GAO-06-644 DHS Agricultural Quarantine Inspections

c

Preclearance inspections were conducted at 14 locations in Canada, the Caribbean, and Ireland. 

Individuals arriving in the United States from those locations did not undergo another inspection upon 

arrival in the United States. According to CBP, preclearance inspections were done only as a pilot and 

not as an ongoing program within the agency.

Of particular note are three districts that have experienced a significant 

increase in their rate of inspections and a significant decrease in their 

interception rates since the transfer. Specifically, since the transfer, ports in 

the Tampa, El Paso, and Tucson districts appear to be more efficient at 

inspecting (e.g., inspecting a greater proportion of arriving passengers or 

cargo) but less effective at interceptions (e.g., intercepting fewer 

prohibited agricultural items per inspection). Also of concern are three 

districts—San Juan, New Orleans, and New York—that are inspecting at 

about the same rate, but intercepting less, since the transfer. 

When we showed the results of our analysis to senior CBP officials, they 

were unable to provide an explanation for these changes or to determine 

whether the current rates were appropriate relative to the risks, staffing 

levels, and staffing expertise associated with individual districts or ports of 

entry. These officials also noted that CBP has had problems interpreting 

APHIS data reports because CBP lacks staff with expertise in agriculture 

and APHIS’s data systems in some district offices. CBP is working on a plan 

to collect and analyze agriculture-related data in the system it currently 

uses for customs inspections, but the agency has yet to complete or 

implement the plan. 

Information Sharing and 

Coordination between CBP 

and APHIS Have Been 

Problematic

CBP and APHIS have an interagency agreement for sharing changes to 

APHIS’s policy manuals and agriculture inspection alerts, which impact 

CBP’s agricultural mission. APHIS maintains several manuals on its Web 

site that are periodically updated for agriculture specialists’ use. These 

manuals include directives about current inspection procedures as well as 

policies about which agricultural items from a particular country are 

currently permitted to enter the United States. When APHIS updates a 

manual, the agency sends advance notice to CBP headquarters personnel, 

but agriculture specialists in the ports frequently do not receive these 

notices. Before the transfer of agriculture specialists to CBP, APHIS emailed policy manual updates directly to specialists, according to a senior 

APHIS official. However, since the transfer, CBP has not developed a list of 

all agriculture specialists’ e-mail addresses. As a result, APHIS uses an “adhoc e-mail list” to notify CBP agriculture specialists of policy manual 

updates. When an agriculture specialist or supervisor sends an e-mail to the 

APHIS official who maintains the contact list, that person’s e-mail address 
Page 26 GAO-06-644 DHS Agricultural Quarantine Inspections

is then manually added to the list. The official also noted he has added email addresses sent in by former APHIS personnel who noticed that they 

were no longer receiving manual update notifications, as they had prior to 

the transfer to CBP. However, the official also stated that his list is not an 

official mailing list and is not representative of all of the ports.20 CBP also 

could not tell us if the list was accurate or complete.

Several agriculture specialists we spoke with indicated that they (1) 

frequently did not receive any notification from APHIS or CBP when 

manuals were updated, (2) received updates sporadically, or (3) were 

unsure whether they received all of the relevant updates. Moreover, based 

on our survey of agriculture specialists, we estimate that 20 percent of 

agriculture specialists do not regularly receive notices that the manuals 

have been updated. According to our survey, 50 percent of agriculture 

specialists always have access to the online manuals. However, according 

to specialists we spoke with, it is difficult to keep up with changes to the 

manuals without being notified as to which policies or procedures are 

updated by APHIS. One inspector expressed dismay that specialists at the 

port to which he had recently transferred were unaware of new regulations 

for conducting inspections to safeguard against avian influenza. 

Agriculture specialists at a different port told us that they continue to refer 

to the hard copies of APHIS’s manuals, which APHIS has not updated since 

it stopped producing hard copies in 2003.

In addition, although CBP and APHIS have established a process to 

transmit inspection alerts down the CBP chain of command to agriculture 

specialists, many frontline specialists we surveyed or interviewed at the 

ports were not always receiving relevant agriculture alerts in a timely 

manner. They identified the time required for dissemination of agriculture 

alerts down the CBP chain of command as an issue of concern. Specifically, 

based on our survey, we estimate that only 21 percent of specialists always 

received these alerts in a timely manner. The level of information sharing 

appears to be uneven between ports and pathways at ports. For example, 

an agricultural specialist at one port told us that he received information 

directly from APHIS on pest movements and outbreaks. An agriculture 

supervisor at a second port noted that information sharing had improved 

20During the course of our audit, CBP established a Web site for agriculture specialists on its 

intranet that contains notices of updates to agricultural inspection manuals. However, at the 

time of our audit, CBP and APHIS still had not developed a formal system to notify 

specialists directly of manual updates.
Page 27 GAO-06-644 DHS Agricultural Quarantine Inspections

after port officials established a plant pest risk committee comprising local 

officials from APHIS, CBP, and other agencies. However, an agriculture 

specialist at a third port we visited told us that specialists there did not 

receive any information on pests from APHIS, while a second specialist at 

the same port expressed concern that alerts on disease outbreaks such as 

avian influenza arrive many days after the outbreaks are first reported.

With regard to coordination between CBP and APHIS, we found that APHIS 

officers responsible for tracing the pathways of prohibited agricultural 

items into the United States have experienced difficulty or delays in gaining 

access to some ports of entry. After the transfer, APHIS and CBP agreed to 

restrict APHIS officials’ access to ports of entry to ensure clear separation 

of responsibilities between the two agencies. Under the memorandum of 

agreement, CBP may grant or refuse access to ports by APHIS personnel, 

but APHIS officials noted that the difficulties and delays in getting 

information from the ports has made some of APHIS’s Smuggling 

Interdiction and Trade Compliance (SITC) activities difficult, if not 

impossible. Per the agreement, APHIS personnel—including SITC 

inspectors—are to make advance arrangements with local CBP port 

directors for access to agriculture inspection areas. CBP agreed to provide 

APHIS with a written response to any request for access to ports of entry 

but did not specify a time frame for this response. 

Prior to the transfer, APHIS SITC inspectors regularly worked with APHIS 

agriculture inspectors to (1) trace the movement of prohibited agricultural 

items found in U.S. markets back to ports of entry (traceback), (2) identify 

parties responsible for importing prohibited items, and (3) determine 

which weaknesses in inspection procedures allowed the items to enter the 

United States. Currently, SITC inspectors are still responsible for tasks 

such as surveying local markets for prohibited agricultural products and 

gathering information to identify and intervene in the movement of 

smuggled agricultural commodities that could potentially harm U.S. 

agriculture. According to SITC officials, their ability to gather timely 

information at ports of entry is extremely important to SITC’s mission. 

They added that delays in special operations or port visits following the 

discovery of prohibited items make it much harder to trace the pathway of 

such items into the United States.

Although SITC officials noted that their inspectors have received access to 

some ports to perform their duties, they added that CBP has delayed or 

denied access to SITC inspectors at other ports in both the eastern and 

western United States. The SITC officials stated that there have been 
Page 28 GAO-06-644 DHS Agricultural Quarantine Inspections

incidents in which CBP did not respond to requests for access until months 

after APHIS made them. For example, in 2005, SITC requested permission 

to conduct two special operations at U.S. international airports to help 

determine whether passengers or cargo from certain countries posed a risk 

in importing or smuggling poultry products that could be infected with 

avian influenza. In justifying the operations, SITC wrote, “Many illegal and 

possibly smuggled avian products have been seized” in several states 

surrounding the airports. In one case, CBP took 3 months to approve the 

request; however, SITC had already canceled the operation 2 months 

earlier because of CBP’s lack of response. CBP approved another special 

operation several months after SITC’s request, but later canceled it because 

SITC uniforms did not match CBP specialists’ uniforms, according to 

senior SITC officials. They added that CBP’s other reasons for delaying or 

canceling joint operations and visits included (1) inadequate numbers of 

CBP specialists to participate in operations, (2) scheduling conflicts 

involving CBP port management, and (3) concerns about SITC inspectors’ 

lack of security clearances.

Agriculture Canine Program 

Has Deteriorated

Agriculture canines are a key tool for targeting passengers and cargo for 

inspection, but we found that the program has deteriorated since the 

transfer. The number and proficiency of canine teams has decreased 

substantially over the last several years. Specifically, APHIS had 

approximately 140 canine teams nationwide at the time of the transfer, but 

CBP currently has approximately 80 such teams, about 20 percent of which 

are newly hired, according to agency officials. They added that, although 

CBP has authorized the hiring of 15 more agriculture canine teams, the 

positions remain vacant as of the end of 2005. According to APHIS, CBP 

has not been able to fill available APHIS agriculture specialist canine 

training classes. After consulting with CBP, APHIS scheduled 7 agriculture 

canine specialist training classes in fiscal year 2005 but canceled 2 because 

CBP did not provide students. Similarly, in fiscal year 2006, APHIS 

scheduled 8 classes, but, as of April, had to cancel 3 for lack of students to 

train. In 2005, 60 percent of the 43 agriculture canine teams tested failed the 

USDA proficiency test, and APHIS officials told us proficiency has declined 

since the transfer. These proficiency tests, administered by APHIS, require 

the canine to respond correctly in a controlled, simulated work 

environment and ensure that canines are working effectively to catch 

potential prohibited agricultural material.

Potential reasons for the deterioration in proficiency scores include CBP 

not following policy and procedures for the canine program and changes in 
Page 29 GAO-06-644 DHS Agricultural Quarantine Inspections

the program management structure. The policy manual for the canine 

program states that canines should (1) receive about 4 hours of training per 

week and (2) have minimal down time in order to maintain their 

effectiveness. In general, canine specialists we interviewed expressed 

concern that the proficiency of their canines was deteriorating due to a 

lack of working time. That is, the dogs were sidelined while the specialist 

was assigned to other duties. Furthermore, based on results of our survey, 

we estimate that 46 percent of canine specialists were directed to perform 

duties outside their primary canine duties several times a week or every 

day. Additionally, an estimated 65 percent of canine specialists sometimes 

or never had funding for training supplies. Another major change to the 

canine program, following the transfer, was CBP’s elimination of all former 

APHIS canine management positions. In some cases, agriculture canine 

teams now report to supervisory agriculture specialists, who may not have 

any canine experience. Formerly, canine teams reported to both the in-port 

management and regional canine program coordinators, who were 

experienced canine managers. The program coordinators monitored the 

canine teams’ proficiency and ensured that teams maintained acceptable 

performance levels. According to CBP, the agency is considering 

developing a new management structure to improve the effectiveness of its 

canine program. However, little progress has been made to date.

Financial Management 

Issues at CBP and 

APHIS Adversely 

Affect the AQI Program

The law authorizes user fees to cover the costs of the AQI program. 

However, in the 3 years since the transfer, user fees have not been 

sufficient to cover AQI program costs.21 CBP believes that unless the 

current user-fee rates are increased, the program will continue to face 

annual shortfalls to the detriment of the AQI program. In addition, CBP 

underwent a financial management system conversion for fiscal year 2005 

and was unable to provide APHIS with actual cost information needed to 

evaluate the extent to which individual user fees cover program costs. 

Furthermore, APHIS did not always make regular transfers of funds to CBP 

as it had agreed to, causing CBP to use other funding sources or to reduce 

spending. 

21The Secretary of Agriculture may prescribe and collect fees sufficient to cover the cost of 

providing inspection services. In addition, the law requires that the Secretary of Agriculture 

ensure that the amount of the fees be commensurate with the costs of agricultural 

quarantine and inspection services with respect to the class of persons or entities paying the 

fees. 21 U.S.C. § 136a.
Page 30 GAO-06-644 DHS Agricultural Quarantine Inspections

User Fees Have Not Been 

Sufficient to Cover AQI 

Program Costs

The Secretary of Agriculture has the discretion to prescribe user fees to 

cover the costs of the AQI program, but program costs have exceeded userfee collections since the transfer of AQI inspection activities to CBP. 

Following the events of September 11, 2001, a sharp drop in the number of 

international airline passengers entering the United States caused a drop in 

AQI revenue (approximately 80 percent of total AQI user-fee collections 

come from fees on international airline passengers). Despite the drop in 

revenue, APHIS had to increase AQI inspection activities because of postSeptember 11 concerns about the threat of bioterrorism. According to 

USDA, agriculture specialists began inspecting a greater volume of cargo 

entering the United States and a greater variety of types of cargo than they 

had in prior years. Such operations are personnel-intensive and, therefore, 

costly. Consequently, when the transfer occurred in fiscal year 2003, AQI 

program costs exceeded revenues by almost $50 million. The shortfall 

increased to almost $100 million in the first full fiscal year after the 

transfer. Table 3 provides AQI user-fee collections and program costs for 

fiscal years 2001 through 2005.

Table 3: AQI User-Fee Collections and Program Costs, Fiscal Years 2001 through 2005

Sources: APHIS and CBP.

Notes: Negative values shown in parentheses.

a

Program costs as reported by the agencies.

b

Not applicable because CBP did not incur program costs until March 1, 2003.

c

CBP costs for fiscal year 2003 began on March 1, 2003, when AQI inspections were transferred to 

CBP.

For fiscal years 2004 and 2005, the 2 full fiscal years since the transfer, total 

AQI costs exceeded user-fee collections by more than $125 million. 

Consequently, in fiscal years 2004 and 2005, APHIS used AQI user-fee 

collections from previous years, and CBP used another available

Dollars in thousands 

Fiscal year

2001 2002 2003 2004 2005

User-fee collections $255,141 $208,688 $227,823 $256,104 $331,636

Total program costsa 222,707 250,810 279,150 355,521 357,403

 APHIS costs 222,707 250,810 194,030 133,000 134,995

 CBP costs b b 85,120c 222,521 222,408

Total program costs in excess of 

user-fee collections ($32,434) $42,122 $51,327 $99,417 $25,767
Page 31 GAO-06-644 DHS Agricultural Quarantine Inspections

appropriation to cover AQI costs.22 In October 2004, APHIS’s Associate 

Deputy Administrator of Plant Protection and Quarantine wrote to the 

Executive Director of CBP’s Office of Budget, noting, “We are in dire need 

of generating increased revenue for the AQI program; without an increase, 

the AQI account could run out of money on or about July 19, 2005.” The 

letter also discussed a three-phase approach to ensuring fiscal solvency for 

the AQI program. The first phase consisted of establishing increased 

interim user-fee rates to cover costs of pay raises and inflation. The second 

phase involved removing the exemption from paying AQI user fees granted 

to passengers, cargo, and commercial vehicles at ports of entry along the 

U.S.—Canada border. The third phase included identifying all current and 

future needs of the AQI program, not just pay raises and inflation, to ensure 

that user fees fully cover AQI program costs. APHIS estimated that it would 

take up to 2 years to complete the entire Federal Register process and 

make new phase-three fees effective. 

On December 9, 2004, APHIS proceeded with the first phase by publishing 

an interim rule to raise user fees, effective January 1, 2005, through 2010.23

However, because of the method APHIS used to estimate AQI program 

costs, this phase-one increase in user-fee revenues is not likely to be 

enough to cover program costs through fiscal year 2010. Specifically, 

APHIS used estimated fiscal year 2004 program costs—$327 million—plus 

1.5 percent of these costs for pay raises and inflation (or about $4.9 million) 

to set the fiscal year 2005 user fees. However, APHIS’s base calculation 

used CBP’s estimated share of fiscal year 2004 user-fee funds—totaling 

$194 million—but not CBP’s actual reported costs for fiscal year 2004—

totaling $222.5 million. Thus, the difference between CBP’s actual and 

estimated costs of $28.5 million was not included in the base calculation, 

resulting in less revenue for the program.24 CBP subsequently 

acknowledged that APHIS’s decision not to include CBP’s actual fiscal year 

2004 costs in the user-fee increase “has put CBP in the position where 

incoming APHIS user-fee revenues fall short of the expected cost of 

22APHIS recognized the need to maintain a reasonable reserve balance in the AQI account to 

provide the program with a means to ensure continuity of AQI services in cases of 

fluctuation in activity volumes, bad debt, carrier insolvency, or other unforeseen events, 

such as those of September 11, 2001, that could result in substantial cost increases and 

lower-than-expected revenues.

2369 Fed. Reg. 71660.

24According to CBP, APHIS consistently uses the same approach for their costs, reporting its 

share of collections rather than actual costs.
Page 32 GAO-06-644 DHS Agricultural Quarantine Inspections

operating the [AQI] program.” CBP finance officials also told us that 

because the costs of performing AQI activities was approximately $222 

million in each of the previous 2 years, it is unlikely that the projected $211 

million to be transferred to CBP for fiscal year 2006 will be sufficient to 

cover program costs for fiscal year 2006 and beyond. 

Despite the shortfall between user-fee collections and program costs, 

APHIS has not completed the second or third phases of its proposal. As of 

May 2006, the Secretary of Agriculture had not made a decision whether to 

proceed with the proposal to lift the Canadian exemption.25 CBP officials 

told us that unless the Canadian exemption is lifted, the agency cannot hire 

the over 200 additional agriculture specialists that it has determined are 

needed to perform additional inspections on the northern border. APHIS 

officials told us that because lifting the Canadian exemption will affect 

estimates of future revenue used in calculating new user-fee rates, APHIS 

and CBP have not begun the third phase of revising user fees, which APHIS 

estimates will take approximately 2 years.

CBP Could Not Provide 

APHIS with the Actual Cost 

Information

CBP is required by the interagency agreement to establish a process in its 

financial management system to report expenditures by each AQI fee type, 

such as those paid by international passengers and commercial aircraft. 

APHIS uses this information to set user-fee rates and to audit user-fee 

collections. Although CBP provided detailed cost information by activity 

and user-fee type to APHIS for fiscal year 2004, CBP provided only 

estimated cost information for fiscal year 2005 because of a weakness in 

the design of the agency’s new financial management system. In November 

2005, CBP conducted an internal review and determined that its reported 

costs of almost $208 million did not include about $15 million in additional 

salary costs for CBP agriculture supervisors. CBP officials told us that 

these costs were not included, in large part, because the agency adopted a 

new financial management system in fiscal year 2005 that allowed 

agriculture supervisors to record their time spent on AQI activities in a 

joint account that combined customs, immigration, and agricultural 

quarantine inspection activities. Thus, the costs related to only agricultural 

activities could not be segregated.

25Canadian Exemption Removal Rule (Docket No. 01-109-1).
Page 33 GAO-06-644 DHS Agricultural Quarantine Inspections

A senior CBP finance official told us that CBP’s Office of Finance could 

have provided rough estimates of costs by activity to APHIS but chose not 

to do so because they did not want to combine actual and estimated costs 

in the same document. Instead, CBP provided estimates of cost by user-fee 

type in January 2006. CBP did provide APHIS with the required accounting 

of obligations incurred by program office (e.g., Office of Training and 

Development, Applied Technology Division, Office of Asset Management, 

and Office of Chief Counsel) and budget codes (e.g., salary, overtime, and 

office supplies) for fiscal year 2005. However, a senior APHIS budget 

official told us that this cost information was not helpful to APHIS for 

reviewing the user-fee rates because they needed the breakdown of actual 

costs by user-fee type and because APHIS could not determine if the costs 

were accurate. Until CBP’s financial management system can provide 

actual costs by activity and AQI user-fee type, APHIS will not be able to 

accurately determine the extent to which the user fees need to be revised. 

In addition, without such information, APHIS does not know whether 

inspections of international airline passengers and commercial aircraft, 

vessels, trucks, and railroad cars are being funded by revenue from the 

appropriate user fee.

APHIS Did Not Always 

Make Regular Transfers of 

AQI Funds to CBP

Although many of the AQI functions were transferred to CBP when the 

Department of Homeland Security was formed, APHIS continues to collect 

most user fees and transfers a portion of the collections to CBP on a 

periodic basis.26 For fiscal years 2004 and 2005, these transfers were often 

delayed and their amounts were sometimes less than expected, which 

adversely affected CBP agricultural inspection activities. In February 2004, 

USDA and DHS agreed that APHIS would transfer one-fourth of the annual 

amount of estimated user-fee collections to CBP at the beginning of each 

quarter, or if the balance in the account was not sufficient to transfer the 

full quarterly amount in advance, APHIS could make monthly transfers. 

APHIS officials told us, however, that the agency chose to transfer funds to 

CBP every other month because the AQI account would not always have 

had sufficient funds to make quarterly transfers, and monthly transfers 

would have been administratively burdensome. Nevertheless, as table 4 

shows, CBP frequently did not receive the transfers at the time specified or 

26APHIS collects user fees for international air passengers, commercial aircraft, and rail 

cars. CBP collects user fees for commercial vessels, trucks, and truck decals, transfers the 

entire collection amount to APHIS, and receives a portion back from APHIS through the 

periodic transfers.
Page 34 GAO-06-644 DHS Agricultural Quarantine Inspections

for the agreed upon amount in fiscal years 2004 and 2005. Consequently, 

according to CBP officials, the agency’s finance office had to use funding 

sources that they had planned to use for other purposes. In addition, CBP 

officials told us some ports had to reduce spending for supplies needed for 

inspection activities or delay hiring personnel or purchasing equipment. 

Then, for the last transfer of the fiscal year, APHIS did not notify CBP until 

August 2005 that the transfer would total $43.9 million, about $11 million 

more than expected (see table 4). As a result, CBP’s budget plans had to be 

revised late in the year to accommodate this additional funding. 

Table 4: AQI User-Fee Funds Transferred from APHIS to CBP during Fiscal Years 

2004 and 2005

Dollars in thousands

Month

Agreed upon 

quarterly transfer 

schedule Actual transfers

Fiscal year 2004

October 2003 $48,500 $0

November 2003 0 0

December 2003 0 0

January 2004 48,500 0

February 2004 0 0

March 2004 0 0

April 2004 48,500 118,000

May 2004 0 0

June 2004 0 29,500

July 2004 48,500 0

August 2004 0 29,500

September 2004 0 17,000

Total, fiscal year 2004 $194,000 $194,000

Fiscal year 2005

October 2004 $48,814 $0

November 2004 0 32,820

December 2004 0 0

January 2005 48,814 0

February 2005 0 65,640

March 2005 0 0

April 2005 48,814 32,820
Page 35 GAO-06-644 DHS Agricultural Quarantine Inspections

Sources: APHIS and CBP budget offices.

a

Totals may not be exact due to rounding.

In addition, technical difficulties in the fund transfer process also delayed 

the transfer of funds to CBP, and at one point during fiscal year 2004, CBP 

did not have available funding from user fees for over 6 months. In this 

instance, APHIS transferred $88.5 million from October 2003 to February 

2004 into a DHS Treasury account used for fiscal year 2003 transfers. 

However, APHIS officials told us that the Office of Management and Budget 

had established a new Treasury account for CBP, and CBP officials did not 

advise APHIS of the change. Ultimately, APHIS withdrew the funds from 

the original account and transferred them as part of the April 2004 transfer, 

which totaled $118 million, but it took longer than 5 months to resolve the 

issue. Similarly, two other fund transfers were delayed in fiscal year 2005 

because APHIS did not comply with a Treasury rule requiring that agencies 

cite the relevant statutory authority when submitting a request to transfer 

funds to another agency. In one instance, APHIS ultimately transferred 

$65.6 million to CBP in February 2005 rather than transferring one payment 

in January 2005 for $32.8 million and another payment in February 2005 for 

$32.8 million.

In October 2005, APHIS and CBP revised their agreement, which outlined 

the process the agencies would follow for transferring user fees and the 

financial reporting on the use of those funds. Under the revised agreement, 

APHIS, beginning in November 2005, is to make 6 bimonthly transfers to 

CBP in fiscal year 2006 totaling $211.1 million. Figure 3 illustrates the 

process APHIS uses to collect user fees and transfer funds to CBP for fiscal 

year 2006.

Month

Agreed upon 

quarterly transfer 

schedule Actual transfers

May 2005 0 0

June 2005 0 32,820

July 2005 48,814 0

August 2005 0 43,900

September 2005 0 0

Total, fiscal year 2005 $195,257a $208,000

(Continued From Previous Page)

Dollars in thousands
Page 36 GAO-06-644 DHS Agricultural Quarantine Inspections

Figure 3: Collection and Transfer of User Fees from APHIS to CBP for Fiscal Year 

2006

a

The six AQI user fees are assessed on international air passengers, commercial aircraft, commercial 

vessels, commercial trucks, commercial truck decals, and commercial railroad cars.

5 5

5 5

Traveler pays user fee as

part of an international 

airline ticket price 

(FY 2006 fees are $5)a

Airline submits user fee to an 

APHIS-controlled “lockbox” 

up to 31 days after the end 

of the quarter in which the 

trip is taken

APHIS divides the funds between 

CBP and APHIS

In FY 2006, APHIS will make 

bimonthly transfers of 

approximately $35,186,667 into a

Treasury account designated for 

CBP

CBP Treasury Account

Nov. 2005 Jan. 2006

$35,166,667 $35,206,667

Mar. 2006

$35,186,667

CBP AQI activities include, 

among other things, AQI

inspections of:

• air passengers

• cargo

• means of conveyance 

(e.g., vessel, aircraft)

APHIS AQI activities include, 

among other things:

• providing training to CBP 

agriculture specialists

• pest identification

• product traceback

• development of AQI 

regulations, policies, and 

procedures

Total 2006:

CBP: $211,120,000

APHIS: $137,019,925

Airline Ticket

Gate Seat

John Doe

D3 14C

Depart

Arrive

Los Angeles

Paris, France

60.64% 39.36%

CBP APHIS

Source: GAO analysis of CBP and APHIS documents.
Page 37 GAO-06-644 DHS Agricultural Quarantine Inspections

As shown in figure 3, APHIS was to transfer $35,186,667 to CBP in 

November 2005. However, contrary to the new agreement, APHIS

transferred $35,166,667—$20,000 less than CBP expected—on November 

30, 2005. When asked why they did not receive the correct amount in 

accordance with the revised agreement, CBP officials agreed to investigate 

the discrepancy and found that their staff was working to correct the 

problem. APHIS officials told us that their budget office used a rounded 

amount of $211 million for the fiscal year to distribute the payments, 

resulting in the $20,000 shortage for the distribution. APHIS officials told us 

that the budget office did not have a copy of the current distribution 

schedule from the revised agreement and did not know the exact amount of 

the required payment. They also stated that the budget office now has the 

agreement and will make the proper bimonthly transfers going forward. 

According to APHIS officials, the January 2006 transfer included an 

additional $20,000 to address the discrepancy we identified with the 

November transfer. APHIS and CBP believe that the revised agreement, 

which also provides for quarterly face-to-face meetings between the 

agencies, should improve communication, assure transparency in the 

transfer process, and prevent future problems in the transfer of funds.

Conclusions The global marketplace and increased imports of agricultural products and 

international travelers into the United States have increased the number of 

pathways for the movement and introduction of foreign, invasive 

agricultural pests and diseases, such as avian influenza and foot-and-mouth 

disease. Maintaining the effectiveness of federal programs to prevent 

accidental or deliberate introduction of potentially destructive organisms is 

critical given the importance of agriculture to the U.S. economy. 

Accordingly, effective management of AQI programs is necessary to ensure 

that agriculture issues receive appropriate attention in the context of CBP’s 

overall missions of detecting and preventing terrorists and terrorist 

weapons from entering the United States and facilitating the orderly and 

efficient flow of legitimate trade and travel. 

Although the transfer of agricultural quarantine inspections from USDA’s 

APHIS to DHS’s CBP has resulted in some improvements as a result of the 

integration of agriculture issues into CBP’s overall antiterrorism mission, 

significant coordination and management issues remain that leave U.S. 

agriculture vulnerable to the threat of foreign pests and disease. Because 

the Homeland Security Act of 2002 divided AQI responsibilities between 

USDA and DHS, the two departments must work more closely to address 

key coordination weaknesses, including enhancing communication 
Page 38 GAO-06-644 DHS Agricultural Quarantine Inspections

between APHIS’s AQI policy experts and CBP’s agriculture specialists in 

the field, to ensure that critical inspection information reaches these 

frontline inspectors; to review policies and procedures for the agriculture 

canine program to improve the effectiveness of this key inspection tool; 

and to revise AQI user fees. Furthermore, both departments must work to 

address key management weaknesses in their respective areas of 

responsibility. Specifically, in light of the AQI program’s expanded mission, 

DHS needs to develop and adopt meaningful performance measures to 

assess the AQI program’s effectiveness at intercepting prohibited 

agricultural materials; implement a national risk-based staffing model to 

ensure that adequate numbers of agriculture specialists are staffed to areas 

of greatest vulnerability; and review its financial management systems to 

ensure financial accountability for funds allocated to the AQI program. It is 

also important that user fees be adjusted to meet the program’s costs, as 

authorized (but not required) by law. Without decisive action, APHIS and 

CBP could be forced to cut back on agriculture inspections if costs 

continue to exceed program revenues. Such cutbacks could increase the 

potential for animal and plant pests and diseases to enter the United States 

and could disrupt trade if agriculture specialists were not available to 

inspect and clear passengers and cargo on a timely basis. By overcoming 

these challenges, the United States would be in a better position to protect 

agriculture from the economic harm posed by foreign pests and disease.

Recommendations for 

Executive Action

To ensure the effectiveness of CBP and APHIS agricultural quarantine 

inspection programs designed to protect U.S. agriculture from accidental 

or deliberate introduction of foreign pests and disease, we are making the 

following seven recommendations:

We recommend that the Secretaries of Homeland Security and Agriculture 

work together to

• adopt meaningful performance measures for assessing the AQI 

program’s effectiveness at intercepting foreign pests and disease on 

agricultural materials entering the country by all pathways—including 

commercial aircraft, vessels, and truck cargo—and posing a risk to U.S. 

agriculture;

• establish a process to identify and assess the major risks posed by 

foreign pests and disease and develop and implement a national staffing 

model to ensure that agriculture staffing levels at each port are 

sufficient to meet those risks; 
Page 39 GAO-06-644 DHS Agricultural Quarantine Inspections

• ensure that urgent agriculture alerts and other information essential to 

safeguarding U.S. agriculture are more effectively shared between the 

departments and transmitted to DHS agriculture specialists in the ports;

• improve the effectiveness of the agriculture canine program by 

reviewing policies and procedures regarding training and staffing of 

agriculture canines and ensure that these policies and procedures are 

followed in the ports; and

• revise the user fees to ensure that they cover the AQI program’s costs.

We recommend that the Secretary of Homeland Security undertake a full 

review of its financial management systems, policies, and procedures for 

the AQI program to ensure financial accountability for funds allocated for 

agricultural quarantine inspections.

We recommend that the Secretary of Agriculture take steps to assess and 

remove barriers to the timely and accurate transfer of AQI user fees to 

DHS.

Agency Comments and 

Our Evaluation

We provided USDA and DHS with a draft of this report for their review and 

comment. We received written comments on the report and its 

recommendations from both departments.

USDA commented that the report accurately captures some of the key 

operational challenges facing the two departments as they work to protect 

U.S. agriculture from unintentional and deliberate introduction of foreign 

agricultural pests and diseases. USDA generally agreed with the report’s 

recommendations, adding that APHIS has already made some 

improvements to address our recommendations. For example, the 

department reported that APHIS has made improvements in the transfer of 

funds to CBP as a result of revisions to the interagency agreement with 

CBP. We had noted these changes in the report. In addition, USDA offered 

to work with DHS on our recommendations that DHS (1) adopt meaningful 

performance measures to assess AQI program’s effectiveness and (2) 

establish a process to identify and assess the major risks posed by foreign 

pests and disease and develop and implement a national staffing model to 

address those risks. We modified the recommendations to involve USDA 

accordingly. USDA’s written comments and our detailed response appear in 

appendix III. USDA also provided technical comments that we 

incorporated, as appropriate, throughout the report.
Page 40 GAO-06-644 DHS Agricultural Quarantine Inspections

DHS commented that the report was balanced and accurate and agreed 

with its overall substance and findings. DHS generally agreed with our 

recommendations and indicated that CBP has begun the process of 

implementing, or has implemented parts of, our recommendations. For 

example, as we note in the report, CBP has begun the process of creating 

new performance measures for assessing the AQI program’s effectiveness. 

DHS stated that the new measures are scheduled to be in place by the 

beginning of fiscal year 2007. Also, DHS commented that CBP has 

developed a prototype staffing model methodology that it intends to 

develop into a final model to monitor and track the evolving staffing needs 

and priorities of the agency. With regard to our recommendation that DHS 

review its financial management systems to ensure accountability for AQI 

funds, DHS stated that it believes actions taken over the course of our 

review have addressed our concerns. We continue to believe that DHS 

needs to monitor outcomes of these recent changes during the coming 

fiscal year to ensure that they provide necessary accountability for the use 

of AQI funds. DHS’s written comments and our detailed response appear in 

appendix IV. DHS also provided technical comments that we incorporated, 

as appropriate, throughout the report.

We are sending copies of this report to the Secretaries of Homeland 

Security and Agriculture and interested congressional committees. We will 

also make copies available to others on request. In addition, this report will 

be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or bertonid@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V.

Daniel Bertoni

Acting Director, Natural Resources and Environment
Page 41 GAO-06-644 DHS Agricultural Quarantine Inspections

Appendix I

Scope and Methodology AAppenednxidexiIs

To assess the extent to which the U.S. Department of Agriculture (USDA) 

and the Department of Homeland Security (DHS) have changed the 

Agricultural Quarantine Inspection (AQI) program since the transfer of 

responsibilities from USDA to DHS, we reviewed the 2003 Memorandum of 

Agreement between the United States Department of Homeland Security 

and the United States Department of Agriculture, dated February 28, 2003, 

and the associated appendixes governing how USDA and DHS are to 

coordinate inspection responsibilities. We also reviewed agency 

documentation, including training materials for newly hired Customs and 

Border Protection (CBP) officers, information on databases used by CBP 

agricultural specialists to target agriculture inspections, joint-agency 

reports on port compliance with agricultural inspection policy, and 

information related to CBP’s establishment and utilization of new 

agriculture liaison positions. In addition, we interviewed key program 

officials at USDA’s Animal and Plant Health Inspection Service (APHIS) and 

CBP to discuss changes to the AQI program, including officials responsible 

for training, implementing inspection targeting initiatives, conducting port 

reviews, and overseeing communication of agricultural issues within CBP.

To assess how the departments have managed and coordinated their 

agriculture inspection responsibilities, we reviewed the interagency 

memorandum of agreement between DHS and USDA and its associated 

appendixes. We also reviewed agency documentation, including DHS’s 

Performance and Accountability Reports, APHIS’s model for staffing 

agriculture specialists at ports, data from APHIS’s Work Accomplishment 

Data System for fiscal years 2000 through 2005, agency e-mails 

communicating agriculture alerts and policy information, proposals for 

joint-agency special operations at ports, and agency policy governing 

agriculture inspection training and the agriculture canine program. We 

performed a reliability assessment of the data we analyzed for fiscal years 

2000 through 2005 and determined that the data were sufficiently reliable 

for the purposes of this report. We also visited all three training centers for 

port of entry staff that conduct agricultural training—the USDA 

Professional Development Center, in Frederick, Maryland; the USDA 

National Detector Dog Training Center in Orlando, Florida; and the Federal 

Law Enforcement Training Center (FLETC) in Glynco, Georgia—to 

observe training and interview current students, instructors, and staff. In 

addition, we interviewed key program officials at CBP and APHIS with 

knowledge of AQI management issues, such as performance measures, 

staffing, interagency coordination, training, and the agriculture canine 

program. 
Appendix I

Scope and Methodology

Page 42 GAO-06-644 DHS Agricultural Quarantine Inspections

Furthermore, to ascertain agricultural specialists’ assessment of the 

agriculture quarantine inspection program since the transfer of inspection 

responsibilities from USDA to DHS, we drew a stratified random 

probability sample of 831 agriculture specialists from the approximately 

1,800 specialists (current as of Oct. 14, 2005) in the Department of 

Homeland Security’s Customs and Border Protection. All canine specialists 

were placed in one stratum; other strata were defined by the number of 

specialists at the respective ports. We conducted a Web-based survey of all 

specialists in the sample. Each sampled specialist was subsequently 

weighted in the analysis to account statistically for all specialists in the 

population. We received a response rate of 76 percent. We chose to sample 

agriculture specialists who had recently been hired by CBP, as well as 

former APHIS employees who had been transferred to CBP, including 

agriculture supervisors, to get their various perspectives on the AQI 

program.

The survey contained 31 questions that asked for opinions and assessments 

of (1) agriculture inspection training, (2) agriculture inspection duties, (3) 

communication and information sharing within CBP and between other 

agencies, and (4) changes in the number of agriculture inspections and 

interceptions since the transfer. In addition, the survey included questions 

specifically for canine handlers, agriculture supervisors, and former APHIS 

employees. In developing the questionnaire, we met with CBP and APHIS 

officials to gain a thorough understanding of the AQI program. We also 

shared a draft copy of the questionnaire with CBP officials, who provided 

us with comments, including technical corrections. We then pretested the 

questionnaire with CBP agriculture specialists at ports of entry in Georgia, 

Maryland, Texas, and Washington state. During these pretests, we asked 

the officials to complete the Web-based survey as we observed the process. 

After completing the survey, we interviewed the respondents to ensure that 

(1) questions were clear and unambiguous, (2) the terms we used were 

precise, (3) the questionnaire did not place an undue burden on CBP 

agriculture specialists completing it, and (4) the questionnaire was 

independent and unbiased. On the basis of the feedback from the pretests, 

we modified the questions, as appropriate. 

The questionnaire was posted on GAO’s survey Web site. When the survey 

was activated, the officials who had been selected to participate were 

informed of its availability with an e-mail message that contained a unique 

user name and password. This allowed respondents to log on and fill out a 

questionnaire but did not allow respondents access to the questionnaires of 

others. The survey was available from November 17, 2005, until January 9, 
Appendix I

Scope and Methodology

Page 43 GAO-06-644 DHS Agricultural Quarantine Inspections

2006. Results of the survey to CBP agriculture specialists are summarized 

in appendix II.

Because we followed a probability procedure based on random selections, 

our sample is only one of a large number of samples we might have drawn. 

Since each sample could have provided different estimates, we express our 

confidence in the precision of our particular sample’s results as 95 percent 

confidence intervals (e.g., plus or minus 7 percentage points). These are 

intervals that would contain the actual population values for 95 percent of 

the samples we could have drawn. As a result, we are 95 percent confident 

that each of the confidence intervals in this report from our survey of 

agriculture specialists will include the true values in the study population. 

All percentage estimates from the survey of agriculture specialists have 

margins of error (that is, confidence interval widths) of plus or minus 10 

percentage points or less, unless otherwise noted. All numerical estimates 

other than percentages (e.g., means) have margins of error not exceeding 

plus or minus 15 percent of the value of those estimates, unless otherwise 

noted. 

To determine how funding for agriculture inspections has been managed 

since the transfer from USDA to DHS, we reviewed the interagency 

memorandum of agreement between DHS and USDA—specifically the 

appendix, Article 5: Transfer of Funds, originally signed on February 9, 

2004, and revised on October 5, 2005. Further, we compared the amount of 

revenue generated from the user fees with program costs reported by CBP 

and APHIS on agriculture inspections in fiscal years 2001 through 2005. We 

also reviewed relevant agency documentation, including proposals for 

increasing user-fee collections, budget classification handbooks, cost 

analysis worksheets, and user-fee collection and expense analyses. In 

addition, we reviewed how funds were transferred between APHIS and 

CBP and the impact of these transfers on their operations. Lastly, we 

interviewed senior CBP and APHIS financial management officials 

concerning AQI user-fee collections, cost management, and the transfer of 

funds from APHIS to CBP. 

We conducted our review from April 2005 through March 2006 in 

accordance with generally accepted government auditing standards.
Page 44 GAO-06-644 DHS Agricultural Quarantine Inspections

Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists ApendxiI

This appendix provides the results from our Web-based survey of CBP 

agriculture specialists. (App. I contains details of our survey methodology.) 

We selected a statistical sample of 831 specialists. Within this population, 

we asked questions of, and analyzed data for, three groups: (1) former 

APHIS inspectors—also referred to as plant protection and quarantine 

(PPQ) officers in the survey; (2) newly hired CBP agriculture specialists; 

and (3) canine agriculture specialists. The survey contained 31 questions 

about the experiences and opinions of the specialists. We omitted 

questions 3 and 23, which were used to help respondents navigate the 

survey. We received 628 completed surveys—an overall response rate of 76 

percent. We indicate the number of respondents below each question 

because not every respondent answered every question. We also rounded 

the responses to the nearest whole percent, and, therefore, totals may not 

add to 100 percent. 
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 45 GAO-06-644 DHS Agricultural Quarantine Inspections

Part 1: Demographic Information

1. What is your job title at CBP?

n=626

2. For which of the following pathways did you conduct agricultural 

inspections during the past year? (Please check all that apply.)

n=624

Title Percent

Agriculture Specialist 80

Agriculture Specialist/ Canine Handler 5

Supervisory Agriculture Specialist 13

Other 2

Pathway Percent

Did not conduct inspections 1

Aircraft 55

Air passenger 73

Air cargo 55

Maritime ship 34

Maritime passenger 18

Maritime cargo 32

Pedestrian 18

Vehicles 23

Truck 22

Bus 20

USPS mail 14

Express mail 16

Inland inspection 5

Rail cargo 17

Rail passenger 2

Other 5
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 46 GAO-06-644 DHS Agricultural Quarantine Inspections

Part 2: Information from Former USDA PPQ Officers

4. When did you begin working as a USDA PPQ Officer (not as an 

agriculture technician or aide)?

n=442

5. During your first year working as a USDA PPQ Officer, about how many 

weeks did you spend in on-the-job (in port) training? (Please include such 

things as shadowing, observation, and coaching. Do not include time 

spent at the Professional Development Center. If you spent less than one 

week, please enter 1.)

6. Do you believe you received sufficient training (on-the-job and at the 

Professional Development Center) to enable you to perform your 

agriculture inspection duties?

n=448

Year Percent

1960-1969 1

1970-1979 5

1980-1989 22

1990-1999 29

2000-2003 44

Type of training

Mean number

of weeks

Number of

respondents

Agriculture inspections 16 443

Not agriculture inspections 3 446

Response Percent

Definitely yes 58

Probably yes 32

Uncertain 1

Probably not 4

Definitely not 3

No answer 1
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 47 GAO-06-644 DHS Agricultural Quarantine Inspections

7. Are you, personally, doing more, about the same number, or fewer 

agriculture inspections compared to what you were doing before being 

transferred to CBP?

n=448

8. Are you, personally, doing more, about the same number, or fewer 

agriculture interceptions compared to what you were doing before being 

transferred to CBP?

n=448

Response Percent

Many more 10

Somewhat more 12

About the same 15

Somewhat fewer 24

Many fewer 35

Not applicable 5

No answer 0

Response Percent

Many more 5

Somewhat more 7

About the same 17

Somewhat fewer 19

Many fewer 41

Not applicable 9

No answer 1
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 48 GAO-06-644 DHS Agricultural Quarantine Inspections

9. Which of the following inspection activities did you regularly perform as 

a PPQ Officer prior to being transferred to CBP, and which do you regularly 

perform now? (Please check all that apply.)

Part 3: Information from CBP Agriculture Specialists Hired After 

March 1, 2003.

10. When did you begin working as a CBP Agriculture Specialist?

n=173

Inspection activity

Regularly 

performed as PPQ 

Officer but not now 

as a CBP 

Agriculture 

Specialist

(percent)

Not regularly 

performed as PPQ 

Officer but now as a 

CBP Agriculture 

Specialist

(percent)

Regularly 

performed as PPQ 

Officer and CBP 

Agriculture 

Specialist

(percent)

Not regularly 

performed as PPQ 

Officer and CBP 

Agriculture 

Specialist

(percent)

Number of 

respondents

Boarding aircraft 59 3 32 5 405

Boarding ships 40 4 27 30 350

Compliance 

agreements 43 3 22 32 363

Compliance checks 52 3 29 16 381

Disinfection 49 1 41 9 380

Fumigation 72 0 1 27 368

Roving 36 9 39 17 349

Safeguarding 40 3 53 4 404

Other 57 14 25 4 164

Year Percent

2003 3

2004 30

2005 66
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 49 GAO-06-644 DHS Agricultural Quarantine Inspections

11. During your first year working as a CBP Agriculture Specialist, about 

how many weeks did you spend in on-the-job (in port) training? (Please 

include such things as shadowing, observation, and coaching. Do not 

include time spent at the Professional Development Center. If you spent 

less than one week, please enter 1.)

n=170

a

The sampling margins of error of these estimates do not exceed plus or minus 20 percent of the value 

of the estimates.

12. Do you believe you received sufficient training (on-the-job and at the 

Professional Development Center) to enable you to perform your 

agriculture inspection duties?

n=174

Type of training

Began in 2003 or 2004 

(mean number of weeks)

Began in 2005 

(mean number of weeks)

Agriculture inspections 14a 12a

Not agriculture inspections 6 3

Response Percent

Definitely yes 36

Probably yes 39

Uncertain 11

Probably not 8

Definitely not 5

No answer 2
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 50 GAO-06-644 DHS Agricultural Quarantine Inspections

Part 4: Your Work at CBP

13. During the past 6 months about what percentage of your time did you 

spend on agriculture and nonagriculture CBP duties? (Please enter 

percentages in boxes. If none, enter 0. Percentage total should be 100.)

n=615

a

The sampling margins of error of this estimate is plus or minus 22 percent of the value of the estimate.

14. For each pay period, do you provide the number of hours you worked 

on agriculture inspection and the number of hours you worked on customs 

and immigration inspection to your supervisor or timekeeper?

n=626

Duties Mean 

Agriculture inspections and associated activities 62

Customs and Immigration inspections and associated activities 14

Work not related to inspections (e.g., administrative work, training) 21

Work other than that listed above 3a

Response Percent

Yes 9

No 81

No answer 10
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 51 GAO-06-644 DHS Agricultural Quarantine Inspections

15. Are the following supplies readily available to you? (Please check one in 

each row. If you do not use a supply, please check ‘Do not Use.’)

n=626

16. Do you have easy access to USDA regulatory manuals during 

inspections? (Please check one in each row.)

n=626

Percent

Supplies

Response

Always

Most of

the time

Some of

the time

Never or 

almost never Do not use No answer

Collection vials for pest samples 43 29 18 6 3 1

Forms for submitting pest samples 52 25 15 4 3 1

Garbage bags for intercepted 

material 43 28 17 8 4 1

Latex gloves 48 29 18 3 2 1

Percent

Type of manual

Response

Always

Most of

the time

Some of

the time

Never or

almost never Not applicable No answer

Online USDA regulatory 

manuals 50 23 16 9 2 1

Current (updated) printed 

USDA regulatory manuals 20 19 18 32 7 4
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 52 GAO-06-644 DHS Agricultural Quarantine Inspections

17. Do you have enough time to look for pests in agriculture materials 

intercepted from passengers?

n=626

18. How easy or difficult is it for you to get samples to a pest identifier?

n=626

Response Percent

Always 10

Most of the time 27

Some of the time 31

Never or almost never 15

Not applicable 15

No answer 2

Response Percent

Very easy 29

Somewhat easy 31

Neither easy nor difficult 14

Somewhat difficult 12

Very difficult 6

Not applicable 4

No answer 3
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 53 GAO-06-644 DHS Agricultural Quarantine Inspections

19. When you send a sample to a pest identifier, about how long does it 

usually take to get the results?

n=626

20. How are the following types of information delivered to you? If you do 

not receive a type of information on a regular basis, please indicate that. 

(Please check all that apply.)

Percent

Length of time

Type of sample 

Urgent Nonurgent

One day or less 41 5

2 to 3 days 24 9

4 days to 1 week 6 8

One week to 1 month 3 25

More than 1 month 4 36

Not applicable 11 6

No answer 12 13

Type of information

Method of delivery

E-mail 

from CBP 

(percent)

E-mail from 

another agency 

(percent)

Muster 

(percent)

Other type of 

communication

(percent)

Not received 

on a regular 

basis (percent)

Number of 

respondents

Urgent agriculture 

alerts 71 26 43 11 12 604

Pest alerts 65 31 35 10 13 599

Regulatory changes 53 33 23 11 20 590

Updated pages for 

regulatory manual 40 36 7 9 29 524
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 54 GAO-06-644 DHS Agricultural Quarantine Inspections

21. Is the information delivered to you in a timely manner? (Please check 

one in each row.)

n=626

22. During the past year, about how many hours per month did you spend 

compiling and entering data into the databases listed below? (Please check 

one in each row.)

n=626

Percent

Type of information

Response

Always 

Most of 

the time

Some of

the time

Never or 

almost never

Do not 

receive No answer

Urgent agriculture alerts 21 41 25 7 3 2

Pest alerts 19 42 25 8 4 2

Agriculture regulatory changes 17 38 26 12 5 2

Updated pages for agriculture 

regulatory manual 18 31 17 18 14 2

Percent

Database

Hours per month

Zero 1-5 6-10 11-15 16-20 21-25

Greater 

than 25 No answer

AQIM 39 27 11 3 3 1 6 11

EAN 47 22 8 1 2 0 2 18

PPQ280 43 24 7 2 3 1 5 16

WADS 42 24 7 6 2 2 4 13
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 55 GAO-06-644 DHS Agricultural Quarantine Inspections

Part 5: Questions for Canine Handlers

24. Are the following resources readily available to you? (Please check one 

in each row.)

n=62

25. During the past year, have there been any instances when you thought it 

would be helpful to contact the National Detector Dog Training Center, but 

you were told by CBP management not to contact them?

n=62

Percent

Resources

Response

Always Usually Sometimes Never

Not 

applicable No answer

Funding for veterinary visits 45 33 13 0 1 8

Funding for supplies (for example, 

training aids) 6 21 58 7 0 8

Funding for kennel space 60 19 6 0 6 9

Space for storage of supplies and 

practice materials 31 22 33 4 0 9

Refrigerator(s) for perishable training 

materials 52 21 15 3 0 9

Response Percent

Yes 65

No 18

Uncertain 4

No answer 12
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 56 GAO-06-644 DHS Agricultural Quarantine Inspections

26. Does CBP management allow you enough time each month to schedule 

training with your dog?

n=62

27. During the past year, about how frequently have you been directed to 

perform duties outside your primary mission as a Canine Handler?

n=62

Response Percent

Always 51

Most of the time 28

Some of the time 12

Never or almost never 1

Not applicable 0

No answer 8

Frequency Percent

Every day 22

Several times a week 24

Once a week 3

Two to three times a month 21

Once a month 4

Less than once a month 7

Never or almost never 7

No answer 11
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 57 GAO-06-644 DHS Agricultural Quarantine Inspections

Part 6: Your Views and Opinions about Working at CBP

28. Based on you own experiences, how would you describe the workrelated communication between Agriculture Specialists and the others 

listed below? (Please check one in each row.)

n=626

29. In your experience, does your port have enough Agriculture Specialists 

to carry out agriculture duties?

n=626

Percent

Other agency personnel 

Response

Excellent Good Fair Poor

No basis

to judge No answer

Agriculture specialists at other ports 8 28 23 29 11 1

CBP officers at your port 9 41 31 19 0 0

CBP supervisors 8 30 34 26 0 1

CBP chiefs and port directors 7 20 33 37 2 1

USDA PPQ and APHIS 10 31 27 26 5 1

USDA Veterinary Services 12 29 26 18 11 3

USDA Food Safety and Inspection Services 3 15 17 26 33 6

USDA meat inspectors 0 9 9 23 39 20

Fish and Wildlife Services 11 34 21 20 10 3

Centers for Disease Control 2 9 12 23 48 6

Food and Drug Administration 4 17 19 21 32 7

Public Health Service 3 11 13 24 41 7

Response Percent

Definitely yes 12

Probably yes 16

Uncertain 8

Probably not 21

Definitely not 42

No answer 1
Appendix II

Results of GAO Survey of CBP Agricultural 

Specialists

Page 58 GAO-06-644 DHS Agricultural Quarantine Inspections

30. How prepared do you feel for your duties as an Agriculture Specialist?

n=626

31. In general, do you feel that your work as a CBP Agriculture Specialist is 

respected by CBP Officers and Management?

n=626

Response Percent

Very well prepared 53

Somewhat prepared 33

Neither prepared or unprepared 5

Somewhat unprepared 4

Very unprepared 3

No answer 2

Percent

Other CBP 

personnel

Response

Definitely yes Probably yes Uncertain Probably not Definitely not No answer

CBP Officers 7 18 14 26 35 0

CBP Management 6 14 15 22 42 1
Page 59 GAO-06-644 DHS Agricultural Quarantine Inspections

Appendix III

Comments from the Department of 

Agriculture ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.
Appendix III

Comments from the Department of 

Agriculture 

Page 60 GAO-06-644 DHS Agricultural Quarantine Inspections
Appendix III

Comments from the Department of 

Agriculture 

Page 61 GAO-06-644 DHS Agricultural Quarantine Inspections

GAO Comments 1. We agree with USDA’s suggestion regarding two of our 

recommendations. We now recommend that the Secretaries of 

Agriculture and Homeland Security work together to (1) adopt 

meaningful performance measures for assessing the AQI program’s 

effectiveness at intercepting foreign pests and disease and (2) establish 

a process to identify and assess the major risks posed by foreign pests 

and disease and develop and implement a national staffing model to 

meet those risks.

2. USDA noted that revisions to APHIS’s agreement with CBP should 

address the concerns we raised in the report regarding the timely and 

accurate transfer of AQI funds to CBP. USDA states that APHIS made 

the first three transfers of fiscal year 2006 on time. We discuss these 

positive steps in our report and note a problem with one of APHIS’s 

transfers. As USDA carries out its three-phase approach to revising user 

fees, and DHS works to advance proposed consolidation of customs, 

immigration, and agriculture user fees (see app. IV), we believe that 

USDA must ensure that it follows the revised agreement to ensure 

timely and accurate transfer of AQI user fees to DHS.
Page 62 GAO-06-644 DHS Agricultural Quarantine Inspections

Appendix IV

Comments from the Department of Homeland 

Security ApendxiIV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.
Appendix IV

Comments from the Department of Homeland 

Security 

Page 63 GAO-06-644 DHS Agricultural Quarantine Inspections
Appendix IV

Comments from the Department of Homeland 

Security 

Page 64 GAO-06-644 DHS Agricultural Quarantine Inspections
Appendix IV

Comments from the Department of Homeland 

Security 

Page 65 GAO-06-644 DHS Agricultural Quarantine Inspections

See comment 2.
Appendix IV

Comments from the Department of Homeland 

Security 

Page 66 GAO-06-644 DHS Agricultural Quarantine Inspections

See comment 3.
Appendix IV

Comments from the Department of Homeland 

Security 

Page 67 GAO-06-644 DHS Agricultural Quarantine Inspections
Appendix IV

Comments from the Department of Homeland 

Security 

Page 68 GAO-06-644 DHS Agricultural Quarantine Inspections

GAO Comments 1. We continue to believe that the title of the report reflects our 

conclusion that U.S. agriculture is vulnerable to the unintentional or 

deliberate introduction of foreign pests and diseases as a result of the 

management and coordination issues we raise in the report. Until DHS 

adopts and tracks meaningful performance measures to assess the 

effectiveness of the AQI program, DHS does not know the effectiveness 

of the AQI program at performing its mission. Further, until DHS 

implements a national risk-based staffing model for agriculture 

specialists, it does not know whether adequate numbers of agriculture 

specialists are staffed to ports of entry most vulnerable to the 

introduction of foreign pests and disease.

2. We acknowledge, in the report, the steps that CBP has taken to improve 

communication and information sharing between headquarters and 

field offices. However, given the problems with information sharing 

that we identified in our survey of agriculture specialists, we continue 

to believe that additional actions are warranted to ensure that urgent 

agriculture alerts and other information are transmitted through the 

CBP chain of command to the agriculture specialists.

3. We acknowledge the operational challenges facing CBP as a result of 

having to manage three different sets of user fees (i.e., agriculture, 

customs, and immigration) to support inspection functions at U.S. ports 

of entry. For example, we identified in the report some of the 

timekeeping issues surrounding the need to appropriately separate 

time spent on agriculture, customs, and immigration functions. We 

understand that CBP concluded that to adequately address these 

challenges, congressional action may be required to consolidate the 

different user fees and their associated spending, fee setting, and costs 

recovery authorities and exemptions.
Page 69 GAO-06-644 DHS Agricultural Quarantine Inspections

Appendix V

GAO Contact and Staff Acknowledgments ApendxiV

GAO Contact Daniel Bertoni, (202) 512-3841 or bertonid@gao.gov

Staff 

Acknowledgments

In addition to the contact named above, Maria Cristina Gobin (Assistant 

Director), Terrance N. Horner Jr., Jeff Isaacs, Lynn Musser, Omari Norman, 

Minette Richardson, Steve Rossman, Sidney Schwartz, Robyn Trotter, and 

Diana Zinkl made key contributions to this report. Other contributors 

included Nancy Crothers, Casey Keplinger, and Kim Raheb.

(360553)
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