AVIAN INFLUENZA

USDA Has Taken 

Actions to Reduce 

Risks but Needs a 

Plan to Evaluate Its 

Efforts

Report to Congressional Requesters

April 2017

GAO-17-360

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-360, a report to 

congressional requesters

April 2017

AVIAN INFLUENZA

USDA Has Taken Actions to Reduce Risks but Needs 

a Plan to Evaluate Its Efforts

What GAO Found

When avian influenza outbreaks occur, they can have significant effects on 

human and animal health and the U.S. economy. With regard to human health, 

avian influenza rarely affects humans, but the World Health Organization 

estimates that two particular types of the virus have caused more than 2,100 

human infections and more than 800 deaths since 1997, primarily in Asia and the 

Middle East. With regard to animal health, avian influenza outbreaks can lead to 

large numbers of poultry deaths as a result of efforts to control and prevent the 

spread of the disease. For example, from December 2014 to June 2015, more 

than 50 million birds were destroyed in the largest outbreak in U.S. history. The 

effect of avian influenza on the health of other animal species varies. Swine are 

susceptible to both avian and human influenza viruses that, if mixed, could 

create a new virus to which humans are vulnerable. An outbreak can also have 

significant economic consequences; for example, the economic impacts of the 

2014 outbreak in the United States have been estimated to range from $1.0 to 

$3.3 billion.

USDA identified 15 areas with lessons learned from its responses to the 2014 

and 2016 outbreaks of avian influenza and 308 associated corrective actions.

For example, one lesson learned in the area of depopulation (mass culling of 

flocks) is that there were not enough skilled personnel available for depopulating

infected poultry, leading to delays and possibly increasing the spread of disease.

USDA has identified as completed about 70 percent of the 308 corrective actions 

to address all of the lessons learned. However, the agency has not evaluated the 

extent to which completed corrective actions—such as encouraging states to 

form depopulation teams—have helped resolve the problems identified, and it 

does not have plans for doing so. GAO has previously found that agencies may 

use evaluations to ascertain the success of corrective actions, and that a welldeveloped plan for conducting evaluations can help ensure that agencies obtain 

the information necessary to make effective program and policy decisions. Such 

a plan would help USDA ascertain the effectiveness of the actions it took to 

resolve problems identified during recent outbreaks.

On the basis of GAO’s analysis of federal efforts to respond to outbreaks and of 

stakeholders’ views, GAO identified ongoing challenges and associated issues 

that federal agencies face in mitigating the potential harmful effects of avian 

influenza. For example:

• One challenge is that federal efforts to protect poultry from avian 

influenza rely on voluntary actions by a wide range of poultry producers 

to take routine preventative measures—known as biosecurity— to 

protect their flocks from disease. USDA has two major initiatives under

way to encourage improvements to biosecurity.

• An associated issue that federal agencies face is that the chickens used 

to produce the eggs needed to manufacture critical human influenza 

vaccine are susceptible to influenza outbreaks. The Department of 

Health and Human Services is supporting the development of new 

vaccine manufacturing technologies to reduce reliance on eggs.

View GAO-17-360. For more information, 

contact Steve Morris at (202) 512-3841 or 

morriss@gao.gov.

Why GAO Did This Study

Avian influenza is an extremely 

infectious and potentially fatal disease 

in poultry. In 2014 and 2016, two 

outbreaks of avian influenza led to the 

deaths of millions of poultry in 15 

states and prompted emergency 

spending to control the disease. While 

the health risk to humans is low, 

humans have been infected with these 

viruses, sometimes fatally. A spike in 

fatal human infections in Asia began in 

late 2016.

GAO was asked to review several 

issues related to avian influenza. This 

report examines (1) how outbreaks of 

avian influenza have affected human 

health, animal health, and the U.S. 

economy, (2) the extent to which 

USDA has taken actions to address 

any lessons learned from its responses

to the outbreaks in 2014 and 2016, and 

how it plans to evaluate the actions’ 

effectiveness, and (3) ongoing 

challenges and associated issues, if 

any, federal agencies face in their 

efforts to mitigate the potential harmful 

effects of avian influenza. GAO 

reviewed global and domestic data on 

the effects of avian influenza and

USDA reports and corrective action 

data associated with its responses to 

the recent outbreaks, and interviewed 

federal officials and stakeholders from 

state agencies and the poultry industry.

What GAO Recommends

GAO recommends that USDA develop 

a plan for evaluating the effectiveness 

of the corrective actions it has taken.

USDA agreed with GAO’s

recommendation.
Page i GAO-17-360 Avian Influenza

Letter 1

Background 6

Avian Influenza Has Harmed Human Health, Animal Health, and 

the U.S. Economy 12

USDA Has Taken Corrective Actions to Address Lessons Learned 

but Does Not Have Plans to Evaluate Their Effectiveness 25

Federal Agencies Face Ongoing Challenges and Associated 

Issues in Their Efforts to Mitigate the Potential Harmful Effects 

of Avian Influenza 32

Conclusions 42

Recommendation for Executive Action 42

Agency Comments 42

Appendix I Selected Agencies with Responsibilities Related to Avian Influenza 44

Appendix II Results of Surveillance of Wild Birds for Avian Influenza, 

December 2014 through March 2017 47

Appendix III Comments from the U.S. Department of Agriculture 50

Appendix IV GAO Contact and Staff Acknowledgments 51

Related GAO Products 52

Tables

Table 1: Occurrences of Influenza A in Humans, from 1918 to 

March 2017 13

Table 2: Known Highly Pathogenic Avian Influenza Outbreaks in 

Commercial U.S. Poultry from 1924 to March 2017 15

Table 3: Low Pathogenic Avian Influenza Outbreaks in U.S. 

Commercial Poultry, from 2002 to March 2017 19

Contents
Page ii GAO-17-360 Avian Influenza

Table 4: U.S. Department of Agriculture (USDA) Obligations for 

Responses to Avian Influenza Outbreaks from 2014 to 

2016 21

Table 5: Examples of Lessons Learned and Corrective Actions 

U.S. Department of Agriculture (USDA) Identified after Its 

Responses to the 2014 and 2016 Outbreaks of Highly 

Pathogenic Avian Influenza 26

Table 6: Number of Corrective Actions U.S. Department of 

Agriculture (USDA) Identified Based on Lessons Learned 

From Its Responses to the 2014 and 2016 Outbreaks of 

Highly Pathogenic Avian Influenza, and Percent 

Completed 30

Table 7: Selected Agencies with Responsibilities Related to Avian 

Influenza and Its Effects on Human and Animal Health 44

Table 8: Detections of Highly Pathogenic Avian Influenza in Wild 

Birds in the United States from December 2014 to March 

2017 48

Figures

Figure 1: Ways in Which Avian Influenza Can Spread among 

Poultry Farms 8

Figure 2: Approximate Number of Birds Killed as a Result of the 

2014 Outbreak of Highly Pathogenic Avian Influenza, by 

State 17
Page iii GAO-17-360 Avian Influenza

Abbreviations

APHIS Animal and Plant Health Inspection Service

CDC Centers for Disease Control and Prevention

CFIA Canadian Food Inspection Agency

FDA Food and Drug Administration

HHS Department of Health and Human Services

Interior Department of the Interior

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-17-360 Avian Influenza

441 G St. N.W.

Washington, DC 20548

April 13, 2017

The Honorable Greg Walden

Chairman

The Honorable Frank Pallone

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable Tim Murphy

Chairman

The Honorable Diana DeGette

Ranking Member

Subcommittee on Oversight and Investigations

Committee on Energy and Commerce

House of Representatives

The Honorable Fred Upton

House of Representatives

Avian influenza is a highly infectious and, in some circumstances, fatal 

disease in poultry, including chickens, turkeys, ducks, geese, and other 

domesticated fowl. Most avian influenza viruses have low pathogenicity, 

meaning that they cause no signs or only minor clinical signs of infection 

in poultry. In contrast, highly pathogenic avian influenza can cause a high 

death rate in poultry.1 Two separate outbreaks of highly pathogenic avian 

influenza in the United States, one in 2014 and another in 2016, led to the 

deaths of millions of domesticated poultry in 15 states, caused economic 

losses for the U.S. poultry industry, and prompted emergency 

government spending on control measures.2 According to the Department 

 1U.S. Department of Agriculture (USDA) regulations define highly pathogenic avian 

influenza as (1) any influenza virus that kills at least 75 percent of eight 4- to 6-week-old 

susceptible chickens within 10 days following intravenous inoculation with 0.2 ml of a 1:10 

dilution of a bacteria-free, infectious allantoic fluid; (2) any H5 or H7 virus that does not 

meet the criteria in paragraph (1) of this definition, but has an amino acid sequence at the 

hemagglutinin cleavage site that is compatible with highly pathogenic avian influenza 

viruses; or (3) any influenza virus that is not an H5 or H7 subtype and that kills one to five 

chickens and grows in cell culture in the absence of trypsin. 9 C.F.R. § 53.1. 

2The first detection of highly pathogenic avian influenza in 2014 occurred in December of 

that year. Additional associated detections occurred through June 2015. In this report, we 

refer to those events as the 2014 outbreak. The 2016 outbreak concerned detections of 

highly pathogenic avian influenza in January of that year.

Letter
Page 2 GAO-17-360 Avian Influenza

of Health and Human Services’ (HHS) Centers for Disease Control and 

Prevention (CDC), while the risk posed to the general public by the avian 

influenza viruses that circulated in the 2014 and 2016 outbreaks was low, 

people in other countries have been infected, sometimes fatally, by 

similar viruses. For example, a similar avian influenza virus caused a 

spike in human infections and fatalities in China in late 2016 and early 

2017, particularly among people in direct contact with poultry. The U.S. 

outbreaks did not cause infections in humans. However, we previously 

found in June 2007 that health experts were concerned that if a subtype 

of avian influenza develops the capacity to spread easily from person to 

person, a pandemic could occur.3 According to the World Health 

Organization, controlling the virus in poultry is the principal way to reduce 

opportunities for human infection and, therefore, for a pandemic to 

emerge.

The U.S. Department of Agriculture (USDA) is responsible for acting to 

prevent, control, and eradicate any disease or pest of livestock, including 

foreign animal diseases such as highly pathogenic avian influenza, in 

domestic livestock and poultry.4 In doing so, USDA typically partners with 

states and industry in eradicating such diseases, with the agency’s level 

of involvement dependent upon states’ preparedness and the size of the 

outbreak. USDA’s Animal and Plant Health Inspection Service (APHIS), 

state and local animal health officials, and the poultry industry collaborate 

to eradicate avian influenza by, for example, depopulating (culling) 

affected poultry flocks to halt spread of the disease, cleaning and 

disinfecting premises and equipment, and testing for the presence of the 

virus. USDA compensates—indemnifies—poultry producers for birds and 

eggs lost to the disease and pays for cleaning, disinfection, and testing.5

 3GAO, Avian Influenza: USDA Has Taken Important Steps to Prepare for Outbreaks, but 

Better Planning Could Improve Response, GAO-07-652 (Washington, D.C.: June 11, 

2007). According to the CDC, there are four types of influenza viruses: A, B, C and D. 

Human influenza A and B viruses cause seasonal epidemics of disease almost every 

winter in the United States. The emergence of a new and very different influenza A virus 

to infect people can cause an influenza pandemic. Influenza type C infections generally 

cause a mild respiratory illness in people and are not thought to cause epidemics. 

Influenza D viruses primarily affect cattle and are not known to infect or cause illness in 

people. Pandemics happen when new (novel) influenza A viruses emerge that are able to

easily infect humans and spread from person to person in an efficient and sustained way.

4A foreign animal disease is a transboundary animal disease not known to normally exist 

in the U.S. animal population, according to USDA’s Highly Pathogenic Avian Influenza 

Response Plan: The Red Book (Draft August 2015).

5Unless otherwise noted, we use the term “poultry producer” to refer to those who raise 

and manage poultry, regardless of whether they own the birds. 
Page 3 GAO-17-360 Avian Influenza

CDC collaborates with USDA and with state and local public health 

agencies to monitor people who are involved in activities to control and 

eradicate an outbreak to determine whether they experience influenzalike illness that may be associated with an outbreak in poultry. The 

Department of the Interior’s (Interior) U.S. Geological Survey and U.S. 

Fish and Wildlife Service collaborate with USDA, HHS, state and local 

governments, and private interests to conduct surveillance of wild birds 

and other animals for avian influenza.6

You asked us to review several issues related to avian influenza. Our 

objectives were to (1) provide information on how avian influenza has 

affected human health, animal health, and the U.S. economy; (2) examine 

the extent to which USDA has taken actions to address any lessons 

learned from its responses to the avian influenza outbreaks in 2014 and 

2016 and how it plans to evaluate the effectiveness of such actions; and 

(3) identify what ongoing challenges and associated issues, if any, federal 

agencies face in their efforts to mitigate the potential harmful effects of 

avian influenza.

To provide information on how avian influenza has affected human 

health, animal health, and the U.S. economy, we reviewed data from the 

CDC, World Health Organization, and World Organisation for Animal 

Health, among other sources. Specifically, to provide information on 

human health, we reviewed global and U.S. data on avian influenzarelated human mortality and morbidity dating back to 1918, the first 

recorded pandemic of probable avian origin. Regarding animal health, we 

reviewed USDA data and scientific literature on highly pathogenic avian 

influenza outbreaks among poultry dating back to 1924, the first recorded 

outbreak of highly pathogenic avian influenza in the United States. For 

low pathogenic avian influenza outbreaks among poultry, we obtained 

USDA data starting in 2002 that were readily available in proceedings of 

the U.S. Animal Health Association’s annual meetings. For information 

regarding influenza in other mammals, we reviewed agency information, 

scientific literature, and interviewed federal, state, and industry officials. 

For wild birds, we reviewed scientific literature on federal monitoring from 

 6These agencies are members of The Interagency Steering Committee for Surveillance 

for Highly Pathogenic Avian Influenza in Wild Birds. According to the committee’s June 

2015 strategic plan, the committee will facilitate a coordinated and cooperative approach 

among federal and state agencies and other cooperators to surveil wild birds for the 

presence of avian influenza viruses in the United States. Surveillance methods include 

investigation of morbidity and mortality events, surveillance of live wild birds and hunterharvested birds, and environmental sampling.
Page 4 GAO-17-360 Avian Influenza

2006 to 2011 and monitoring data from 2014 to 2016, when Interior’s U.S. 

Geological Survey and USDA began their current wild bird surveillance 

program. Regarding impacts on the U.S. economy, we focused on the 

2014 outbreak of highly pathogenic avian influenza since it was the 

largest recent outbreak. We reviewed a variety of economic literature for 

information on the estimated costs of the 2014 outbreak to U.S. 

agriculture and consumers. We obtained data on USDA obligations for its 

responses to that outbreak, the January 2016 outbreak, and a May 2016 

low pathogenic avian influenza outbreak. To assess the reliability of the 

data sources noted above, we reviewed the data and supporting 

documentation and interviewed officials familiar with the data, and we

determined that the data were sufficiently reliable for providing 

information on the effects of avian influenza on human and animal health 

and the economy. We also asked for observations on the federal 

responses to the outbreaks of avian influenza through interviews with 

officials from USDA, HHS, Interior, and state and industry representatives 

in six states. We selected the six states—California, Indiana, Iowa, 

Minnesota, North Carolina, and Ohio—either because they were affected 

by the 2014 and 2016 highly pathogenic avian influenza outbreaks or 

because they have large poultry industries.7

To examine the extent to which USDA has taken actions to address any 

lessons learned from its responses to the 2014 and 2016 avian influenza 

outbreaks and how it plans to evaluate the effectiveness of such actions, 

we reviewed USDA’s after action reports of its responses to the 2014 

outbreak in western and midwestern states and the 2016 outbreak in 

Indiana.8 We also reviewed USDA’s Corrective Action Program database 

for tracking the agency’s progress in completing tasks identified in its after 

action reports and USDA documentation of specific steps taken in 

response to lessons learned. To examine USDA’s tracking of corrective 

actions in the database, we conducted an in-depth review of a 

nongeneralizable sample of 10 corrective actions listed in the database. 

 7California, Iowa, and Minnesota were directly affected by the outbreak of highly 

pathogenic avian influenza that began in 2014. Indiana was directly affected by the 

outbreak that began in 2016. North Carolina and Ohio were not directly affected by those 

outbreaks but have large poultry industries. In 2015, North Carolina ranked among the top 

five U.S. states for turkey and broiler production, while Ohio ranked in the top five for egg 

production. 

8According to USDA guidance on evaluation and improvement planning, after action 

reports summarize key information from exercises and responses. Such a report includes 

feedback, lessons learned, and analysis of a response and is usually developed in 

conjunction with a plan for improvement.
Page 5 GAO-17-360 Avian Influenza

For this sample, we randomly selected actions from each of six 

preparedness and response areas that fit within the scope of our overall 

review and that USDA classified in its database as priority 1 items with a 

status of “closed,” “completed,” or “in progress.”9 We requested and 

reviewed agency documents and information from officials describing the 

steps taken to close, complete, or make progress on the actions in our 

sample. Our review of this sample of actions provides general information 

about the steps USDA has taken related to these 10 actions; however, 

the results from this sample are not generalizable to all corrective actions 

in the database. To assess the overall reliability of the Corrective Action 

Program database for use in our report, we reviewed management 

controls over the information systems that maintain the data and 

interviewed USDA officials who manage the database. We determined 

that the database was sufficiently reliable to describe the general status 

of corrective actions and to provide examples of specific actions identified 

for addressing lessons learned.

To determine what ongoing challenges and associated issues, if any, 

federal agencies face in their efforts to mitigate the potential harmful 

effects of avian influenza, we reviewed our prior findings and 

recommendations on preparing for and responding to animal diseases; 

the views of stakeholders from the six selected states about challenges 

related to federal efforts to mitigate the potential harmful effects of highly 

pathogenic avian influenza; and other sources of information related to 

wildlife surveillance, domestic poultry and swine surveillance, biosecurity 

measures to reduce the risk of disease, depopulation of poultry, disposal 

of poultry carcasses, vaccines for poultry, research on disease 

transmission and prevention, and protecting the egg supply for human 

vaccine production. We selected these categories on the basis of 

preliminary discussions with agency officials and industry representatives 

and our 2007 report on avian influenza. We gathered the views of 

stakeholders through interviews with 6 state veterinarians; 10 state public 

health officials, including public health veterinarians and epidemiologists; 

and 6 poultry industry representatives from the six states selected. We 

also interviewed an official from the Canadian Food Inspection Agency 

(CFIA) about the responses to 2014 and 2015 outbreaks of highly 

pathogenic avian influenza in British Columbia and Ontario that involved 

the same viruses that caused the U.S. outbreaks.

 9USDA defined priority 1 corrective actions as those that would have immediate, critical 

implications for a future outbreak and that could be completed in less than 1 year. 
Page 6 GAO-17-360 Avian Influenza

We conducted this performance audit from March 2016 to March 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

This section provides information on avian influenza viruses; avian 

influenza transmission in and between humans and animals; commercial 

and noncommercial poultry production in the United States; our prior work 

on avian influenza; and the responsibilities that USDA, HHS, and Interior 

have with respect to avian influenza response, research, surveillance, 

and other related activities.

Avian influenza is caused by a “Type A” influenza virus (influenza A). 

Avian-origin influenza viruses are broadly categorized based on a 

combination of two groups of proteins on the surface of the influenza A 

virus: hemagglutinin or “H” proteins, of which there are 16 (H1-H16), and 

neuraminidase or “N” proteins, of which there are 9 (N1-N9). Many 

different combinations of “H” and “N” proteins are possible. Each H and N 

combination is considered a different subtype, and related viruses within 

a subtype may be referred to as a lineage. Avian influenza viruses can be 

divided into two groups based on the specific genetic features and 

severity of the disease they cause in 4- to 8-week old chickens in a 

laboratory setting: low pathogenic and the more severe highly pathogenic. 

Influenza A has the potential to cause human pandemics, regardless of 

its pathogenicity in poultry.

Wild aquatic birds—such as waterfowl, gulls, and shorebirds—are the 

natural hosts for influenza A viruses.10 Direct or indirect contact with 

infected wild birds can expose poultry to avian influenza viruses. 

Similarly, infected poultry may spread avian influenza into wild bird 

populations. Avian influenza viruses can also be moved from place to 

place—including between farms—by people, equipment, vehicles, feed, 

 10Swayne, David E., ed. Animal Influenza, 2nd Ed. (Hoboken, N.J.: John Wiley & Sons,

2017).

Background

Avian Influenza Viruses

Avian Influenza 

Transmission
Page 7 GAO-17-360 Avian Influenza

insects, rodents and other animals, water, and wind-blown dust as shown 

in figure 1. Poultry producers may implement biosecurity measures to 

reduce the risk that diseases such as avian influenza will be transmitted 

to their flocks. For example, producers may disinfect vehicles arriving at 

and leaving a farm or direct employees to disinfect boots and hands 

before entering a poultry barn. During an outbreak in poultry, additional 

biosecurity measures may be used to prevent the disease from further 

spreading. For example, USDA personnel and contractors working to 

control an outbreak would be expected to restrict their movements among 

locations to prevent carrying the virus to an uninfected site.
Page 8 GAO-17-360 Avian Influenza

Figure 1: Ways in Which Avian Influenza Can Spread among Poultry Farms

One form of highly pathogenic avian influenza has become endemic in 

several countries, including China, Indonesia, and Vietnam; this means 

that the virus has become entrenched in poultry populations in those 

countries. USDA considers highly pathogenic avian influenza a “foreign 
Page 9 GAO-17-360 Avian Influenza

animal disease” in the United States, meaning U.S. poultry are normally 

free from the disease. The United States, as a member of the World 

Organisation for Animal Health, has agreed (through USDA), along with 

other member countries, to notify the organization and its members of any 

detection of highly pathogenic avian influenza.11 Member countries also 

agree to report cases of low pathogenic H5 or H7 avian influenza found in 

poultry or other birds because these viruses have the potential to mutate 

to a highly pathogenic form in poultry and may infect other species. When 

a country’s poultry tests positive for “notifiable” avian influenza, its 

international trading partners may restrict trade with that country until the 

partners believe the virus is eradicated—an outcome that can take many 

months to achieve. Therefore, when a flock is infected with notifiable H5 

or H7 avian influenza, the goal of the poultry industry and government 

agencies is to control and eradicate the virus as rapidly as possible in 

order to prevent its spread and regain the confidence of trading partners 

that any future imports of poultry or poultry products will be virus free. To 

this end, USDA and other federal, state, and industry partners aim to act 

quickly in the affected area to, among other things: (1) quarantine 

susceptible animals; (2) implement biosecurity measures; (3) depopulate 

infected and exposed birds; (4) dispose of contaminated and potentially 

contaminated materials, including animal carcasses; and (5) clean and 

disinfect the infected premises. Once the virus is eradicated, USDA, 

states, and the poultry industry resume routine surveillance for notifiable 

avian influenza.

According to USDA’s Economic Research Service, the U.S. poultry 

industry is the world’s largest producer and second-largest exporter of 

poultry. The most recent Census of Agriculture reported 233,770 poultry 

farms in the United States in 2012, but the U.S. poultry industry consists, 

in large part, of a relatively small number of large companies that own all 

aspects of the production process—from the hatchery to the processing 

 11The World Organisation for Animal Health, of which the United States is a member, is an 

intergovernmental organization responsible for improving animal health worldwide and 

ensuring trade. It requires its 180 member countries to report certain diseases to the 

organization and other member countries.

Poultry in the United 

States
Page 10 GAO-17-360 Avian Influenza

facility.12 The most common types of poultry raised commercially are 

chickens for consumption (broilers) and chickens that lay eggs (layers), 

as well as turkeys. There are also poultry that are genetic breeding stock 

and whose main function is to produce offspring that facilitate mass 

production and are economical to raise. Additionally, there are poultry 

raised specifically for producing eggs to make human vaccines. 

Commercial poultry operations typically raise tens of thousands of birds in 

confined poultry houses. Such operations can include multiple houses 

located close to each other. Because of the environment in which 

commercial birds are raised, if one bird becomes infected with a notifiable 

avian influenza, hundreds of thousands of birds can be exposed and will 

need to be depopulated.

In addition to poultry raised commercially, numerous types of birds are 

raised in backyards, with flocks of up to 1,000 birds. These “backyard 

birds” are typically chickens used for personal egg production and 

consumption; they also can include game birds, such as quail and 

pheasant. These birds may roam free or be confined to a poultry house. 

In addition, there are birds in live bird markets—facilities that sell live 

poultry, typically slaughtered on-site, to the general public—and some are 

sold at auctions and swap meets.

In a June 2007 report, we found that USDA had made important strides to 

prepare for highly pathogenic avian influenza outbreaks but that 

incomplete planning and other unresolved issues could slow a 

response.13 There were several unresolved issues at the time that, absent 

advance consideration, could hinder response. For example, we found 

that disposal of carcasses and materials infected with highly pathogenic 

avian influenza could be problematic because operators of landfills were 

reluctant to accept materials infected with even low pathogenic avian 

influenza because of the perceived human health risk. To increase the 

likelihood of rapidly containing a highly pathogenic avian influenza 

outbreak, we made seven recommendations to USDA, including that the 

 12For example, according to a 2014 report by USDA, broiler production and processing is 

carried out within tightly integrated production complexes operated by firms called 

integrators. In 2012, 20 integrators together accounted for 96 percent of all broilers 

produced in the United States, and the top 3 accounted for 50 percent. U.S. Department 

of Agriculture, Economic Research Service, Technology, Organization, and Financial 

Performance in U.S. Broiler Production (Washington, D.C.: June 2014).

13GAO-07-652.

Our Related Prior Work
Page 11 GAO-17-360 Avian Influenza

agency develop a response plan that identifies critical tasks for 

responding to an outbreak and address concerns about antiviral 

medication for humans. USDA generally agreed with our 

recommendations and took action to implement all seven 

recommendations. (A list of prior related GAO work is included at the end 

of this report.)

Multiple organizations within USDA support its animal health mission. 

When notifiable avian influenza outbreaks occur, APHIS is the lead 

agency within USDA for preventing and responding to animal disease 

outbreaks. USDA derives its authority to carry out operations and 

measures to prevent, detect, control, and eradicate notifiable avian 

influenza, among other diseases, from the Animal Health Protection Act.14

The act authorizes the Secretary of Agriculture to hold, seize, quarantine, 

treat, destroy, or dispose of any animal, means of conveyance, or object 

that can harbor the disease, or to restrict their movement in interstate 

commerce. The act also authorizes the Secretary to transfer necessary 

funds from other USDA appropriations or available funds to manage an 

emergency in which a disease of livestock threatens any segment of 

agricultural production in the United States, in order to arrest, control, 

eradicate, or prevent the spread of the disease. USDA’s Wildlife Services, 

a program unit within APHIS, conducts research on wildlife diseases, 

such as avian influenza, that may affect agriculture and human health and 

safety. USDA’s Agricultural Research Service conducts research on, 

among other things, poultry diseases and vaccines for those diseases. 

For example, the agency published a report in 2014 on experts’ analyses 

of gaps in knowledge about influenzas in poultry and other animals and

about effective countermeasures to control and mitigate outbreaks of 

disease.15

HHS is responsible for, among other things, research on human disease, 

disease surveillance, and vaccine production and distribution. Within 

HHS, the Influenza Division of CDC’s National Center for Immunization 

and Respiratory Diseases conducts surveillance of influenza in humans, 

including human infections caused by viruses with animal origins; the 

 14Pub. L, No. 107-171, tit. X, subtit. E, §§ 10401-10418 (codified as amended at (7 U.S.C. 

§§ 8301-8318)).

15U.S. Department of Agriculture, Agricultural Research Service,Animal Influenza 

Viruses: Gap Analysis Workshop Report(Washington, D.C.: 2014).

Federal Agencies’ Roles in 

Avian Influenza Response, 

Research, Surveillance, 

and Other Related 

Activities
Page 12 GAO-17-360 Avian Influenza

division also conducts laboratory studies on influenza viruses of concern 

to characterize them and assess their risks to humans. HHS’s Food and 

Drug Administration (FDA) is responsible for protecting the public health 

by ensuring the safety and efficacy of veterinary drugs and medical 

devices and by licensing biological products that are safe, pure, and 

potent, including vaccines for pandemic influenza. In addition, FDA is 

responsible for ensuring the safety and proper labeling of more than 80 

percent of the U.S. food supply.

In cooperation with USDA’s Wildlife Services program and state 

agencies, Interior participates in the federal government’s surveillance of 

wild migratory birds for the presence of avian influenza and provides 

leadership and support in the area of wildlife disease research and 

diagnostics. Interior’s U.S. Geological Survey maintains the National 

Wildlife Health Center, which identifies, controls, and prevents wildlife 

losses from diseases; conducts research to understand the impact of 

diseases on wildlife populations; and devises methods to more effectively 

manage these disease threats. (See app. I for more detail on the roles of 

federal departments and their component agencies as related to avian 

influenza.)

Avian influenza viruses have harmed global human and animal health 

and the U.S. economy. These viruses rarely infect humans, but some 

viruses may have high rates of mortality when they do. Avian influenza 

outbreaks have led to the deaths of hundreds of millions of domesticated 

poultry in dozens of countries, either directly or through depopulation to 

prevent spread of the disease. The 2014 and 2016 outbreaks among U.S. 

poultry led to costs to the federal government of about $930 million and 

additional costs to the U.S. economy of an estimated $1 billion or more.

As of March 2017, two lineages of avian influenza—Asian H5N1, which 

emerged in 1997, and a new strain of H7N9, which emerged in 2013—

have together infected more than 2,100 humans and killed more than 

900, primarily in Asia and Africa. Neither lineage has developed the 

capacity to be easily transmissible from birds to humans or from person to 

person. However, there have been other instances in which influenza A 

viruses of avian origin have become more easily transmissible and have 

caused global pandemics that led to large numbers of fatalities in the 

United States and around the world. Table 1 summarizes occurrences of 

fatal influenza A infections in humans that are known to have or are 

suspected of having an avian origin. The likelihood that an influenza A 

Avian Influenza Has 

Harmed Human 

Health, Animal 

Health, and the U.S. 

Economy

Avian Influenza Rarely 

Infects Humans, but the 

Mortality Rate for Those 

Infected Has Been 

Relatively High
Page 13 GAO-17-360 Avian Influenza

virus of avian origin will evolve into a form easily transmissible among 

humans is small, according to officials from HHS, but if such a change 

occurs, it could lead to serious disease among humans and possibly 

another pandemic. For example, the World Health Organization has 

expressed concern that the Asian lineage H5N1 and H7N9 viruses that 

have sporadically infected humans in Asia, Northern Africa, and the 

Middle East could evolve to become more easily transmissible to or 

between humans and lead to serious disease or another pandemic.

According to CDC’s website, of the novel influenza A viruses that are of 

special concern to public health, the agency rates the Asian lineage H7N9 

virus as having the greatest potential to cause a pandemic, as well as 

potentially posing the greatest risk to severely impact public health.

Table 1: Occurrences of Influenza A in Humans, from 1918 to March 2017

Years Place of origin Extent Influenza subtypea

Reported number of human 

deaths

Resulted in

a pandemicb

1918 Europe and the 

United States

Worldwide Probable avian influenza 

(H1N1)

50 million-100 million worldwide; 

675,000 in the United States

Yes

1957-58 East Asia Worldwide Avian influenza (H2N2) 1.1 million worldwide, 116,000 

in the United States

Yes

1968-1969 Southeast Asia Worldwide Avian influenza (H3N2) 1 million worldwide, 100,000 in 

the United States 

Yes

1997 Hong Kong China Avian influenza (H5N1) 6 No

2003-Mar. 

2017c

China Asia, Middle East, 

and Africad

Avian influenza (H5N1) 453 No

2009-2010 United States Worldwide Quadruple reassortant 

influenza (H1N1)e

Up to 575,000 worldwide, up to 

18,000 in the United States

Yes

2013-Mar. 

2017c China Asiaf Avian influenza (H7N9) At least 489 No

2014-Mar. 

2017c

China China Avian influenza (H5N6) 6 No

Sources: Centers for Disease Control and Prevention (CDC) and World Health Organization. | GAO-17-360

a

Avian influenza is a Type A influenza. Influenza A can infect animals and humans and can also 

cause pandemics. There are many different subtypes of avian-origin influenza A viruses. These 

subtypes are classified based on a combination of tw o groups of proteins on the surface of the 

influenza A virus: hemagglutinin or “H” proteins, of w hich there are 16 (H1-H16), and neuraminidase 

or “N” proteins, of w hich there are 9 (N1-N9). Many different combinations of “H” and “N” proteins are 

possible. Each combination is considered a subtype, and related viruses w ithin a subtype may be 

referred to as a lineage.

b

An influenza pandemic is a global outbreak of a new influenza A virus in humans, w hile an outbreak 

is the occurrence of cases of disease in excess of what would normally be expected in a defined 

community, geographical area, or season.

c

Data for these occurrences of avian influenza are as of March 16, 2017. 

d

In January 2014, a traveler w ho had recently returned to Canada from China died from H5N1 

infection. That w as the only reported case of H5N1 infection in North America as of Dec. 19, 2016.
Page 14 GAO-17-360 Avian Influenza

e

According to CDC, the 2009 H1N1 influenza is a “quadruple reassortant” virus because while each 

separate gene segment of the virus has been found in pigs, the individual gene segments of the virus 

originated from humans, birds, North American pigs, and Eurasian pigs.

f

Some cases of H7N9 have been reported outside of mainland China, but most of these infections 

have occurred among people w ho had traveled to mainland China before becoming ill.

Avian influenza outbreaks—both highly pathogenic and low pathogenic—

have led to the deaths of hundreds of millions of domesticated poultry in 

dozens of countries, either directly or through depopulation to prevent 

spread of the disease.16 For example, the H5N1 highly pathogenic avian 

influenza outbreak that led to human fatalities in China in 1997 also led to 

the deaths of an estimated 220 million birds in China and Hong Kong.17 In 

the United States, outbreaks of highly pathogenic avian influenza have 

led to the deaths of more than 67 million birds since 1983, with the most 

recent outbreaks beginning in December 2014 and ending in June 2015 

and, in unrelated incidents, in January 2016 and March 2017. (See table 

2 for details of known outbreaks of highly pathogenic avian influenza in 

commercial U.S. poultry.)

 16Swayne, David E., ed. Avian Influenza (Ames, Iowa: Blackwell Publishing, 2008).

17Swayne, Avian Influenza.

Outbreaks of Avian 

Influenza Have Killed 

Millions of Poultry 

Worldwide but Caused 

Few Fatalities in Other 

Species
Page 15 GAO-17-360 Avian Influenza

Table 2: Known Highly Pathogenic Avian Influenza Outbreaks in Commercial U.S. Poultry from 1924 to March 2017

Year(s) of 

outbreak State(s) Origin

Highly 

pathogenic 

avian influenza 

subtype(s)

Reported

number and type

of birds depopulateda

1924-1925 New York, New Jersey, Pennsylvania, 

Connecticut, Illinois, Indiana, Michigan, 

Missouri, and West Virginia

Live bird market H7 Up to 600,000 in

New York City alone

1929 New Jersey Uncertain; possibly 

introduced by imported

European partridges

Uncertain Uncertain, “four flocks.” 

1983-1984 Pennsylvania, Virginia, and New Jersey Live bird marketb H5N2 17 million chickens, 

turkeys, guinea fowl, 

and partridges

2004 Texas Live bird market H5N2 6,600 broilers

2014-2015 Arkansas , California, Idaho, Indiana, Iowa, 

Kansas, Minnesota, Missouri, Montana, 

Nebraska, North Dakota, Oregon, South 

Dakota, Washington, and Wisconsin.

Wild birds H5N2 and H5N8 7.4 million turkeys, 

43 million layers, and 

120,000 from “mixed 

flocks”

2016 Indianac Wild birds H7N8 62,109 turkeys

2017 Tennessee Unknown H7N9 129,000 broiler 

breeders

Sources: GAO analysis of U.S. Department of Agriculture and World Organisation for Animal Health data and D.A. Halvorson, “Prevention and management of avian influenza outbreaks: experiences from 

the United States of America,” Revue scientifique et technique (International Office of Epizootics) vol. 28, no. 1 (2009): 359-369. | GAO-17-360

a

Broilers are chickens raised for consumption. Layers are chickens that lay eggs.

b

A live bird market is any facility—including botanica, poultry store, or custom slaughter—that sells 

live poultry for on-site slaughter or for off-site ritual use. A botanica is an establishment that sells 

supplies and some types of poultry or livestock (or both) for sacrificial religions such as Santería and 

Vodou.

c

The Indiana outbreak w as restricted in size and scope to a single county and 12 premises. This table 

reports on poultry at sites associated with highly pathogenic avian influenza. In all, more than 414,000 

birds w ere affected.
Page 16 GAO-17-360 Avian Influenza

USDA identified the first U.S. cases of the 2014 outbreak of highly 

pathogenic avian influenza H5 viruses in captive wild birds or backyard 

flocks in Washington and Oregon in December 2014 and in Idaho the 

following month. Also in December 2014, USDA identified another 

subtype, H5N8, in Washington and Oregon. By the time USDA and its 

state and industry partners eradicated the diseases in June 2015, the 

related H5N2 and H5N8 viruses had infected poultry flocks on 232 farms 

in 15 states, with the largest number of affected farms being in Minnesota 

(110 farms) and Iowa (77 farms).18 (See fig. 2 for a map showing the 15 

states and the approximate number of birds killed or depopulated as a 

result of the outbreak that began in 2014.)

 18The infected farms included commercial and backyard flocks. 

Highly Pathogenic Avian Influenza in 

Canada

Avian influenza is an extremely infectious and, 

in some circumstances, fatal disease in 

poultry, including chickens and turkeys. Avian 

influenza viruses are classified as either “low 

pathogenic” or “highly pathogenic” based on 

their genetic features and the severity of the 

disease they cause in poultry. Beginning in 

early December 2014, the Canadian Food 

Inspection Agency (CFIA), w hich leads 

responses to avian influenza outbreaks in 

Canada, learned of highly pathogenic avian 

influenza on 13 poultry farms in British 

Columbia; these included turkey and chicken 

farms. To eradicate the virus, CFIA 

depopulated 240,000 birds. Wild birds 

migrating along the Pacific Flyw ay were the 

most likely cause of the outbreak, according 

to CFIA. In April 2015, CFIA identified highly 

pathogenic avian influenza in 1 chicken farm

and 2 turkey farms in Ontario. The agency 

controlled the virus by depopulating 79,700 

birds. According to a CFIA official, two 

characteristics of the Canadian poultry 

industry that facilitate the adopting of 

biosecurity measures in poultry farms helped 

limit the size of the 2014 and 2015 Canadian 

outbreaks. First, poultry farms in Canada are 

relatively small compared w ith those in the 

United States, w hich reduces the number of 

birds infected and the chance that influenza 

w ill replicate and spread. Second, Canadian 

poultry companies are not heavily integrated; 

therefore there is little movement of birds, 

feed, equipment, and people that could carry 

the virus from one farm to another.

Source: GAO analysis of CFIA documents and interview with 

agency official; Map Resources (map). | GAO-17-360
Page 17 GAO-17-360 Avian Influenza

Figure 2: Approximate Number of Birds Killed as a Result of the 2014 Outbreak of Highly Pathogenic Avian Influenza, by State

In January 2016, USDA confirmed the presence of an unrelated highly 

pathogenic avian influenza virus, subtype H7N8, in a commercial turkey 

flock in Indiana. USDA also found the low pathogenic form of the virus at 

8 other nearby commercial turkey farms. About 414,000 birds were 

depopulated as part of the effort to eradicate the viruses. By May 2016, 

the viruses were controlled and all producers were permitted to restock 

(i.e., replace the poultry lost to the disease with new birds). In March 

2017, USDA confirmed the presence of another highly pathogenic avian 

influenza virus, subtype H7N9, in commercial chicken flocks in 

Tennessee. About 129,000 birds were depopulated as part of the effort to 
Page 18 GAO-17-360 Avian Influenza

control the virus. Notably, the influenza virus in Tennessee was not the 

same H7N9 virus that has caused human infections and fatalities in Asia.

While low pathogenic avian influenza may not cause high mortality in 

poultry, flocks that are infected with H5 or H7 subtypes of low pathogenic 

avian influenza are often depopulated because those subtypes have the 

potential to mutate and become highly pathogenic. This happened in the 

2016 outbreak in Indiana, when low pathogenic H7N8 avian influenza 

became highly pathogenic in a commercial turkey flock. Outbreaks of low 

pathogenic avian influenza in U.S. commercial poultry flocks have led to 

the deaths—through depopulation—of more than 6 million birds from 

2002 through March 2017, as shown in table 3. In addition, according to 

USDA officials, the agency has documented low pathogenic H5 and H7 

avian influenza viruses 23 times in live bird markets from 2002 through 

2016.
Page 19 GAO-17-360 Avian Influenza

Table 3: Low Pathogenic Avian Influenza Outbreaks in U.S. Commercial Poultry, from 2002 to March 2017

State(s)

Low pathogenic

avian influenza subtype Year of outbreaka Reported number and type of birds depopulatedb

Virginia/North Carolina/

West Virginia

H7N2 2002 4.7 million turkeys, including breeders, and 

chicken broilers, breeders, and layers

Texas H5N3 2002 Layers

California H5N2 2002 Turkey breeders

Connecticut H7N2 2003 100,000 layers

Rhode Island H7N2 2003 30,000 layers

Delaware H7N2 2004 84,000 broilers

Maryland H7N2 2004 328,000 broilers

Texas H7N3 2004 51,000 breeder chickens

Nebraska H7N9 2007 145,000 turkeys

Virginia H5N1 2007 54,000 turkeys

West Virginia H5N2 2007 25,600 turkeys 

Idaho H5N8 2008 30,300 game birds

Arkansas H7N3 2008 16,000 breeder chickens

Minnesota H7N9 2009 500,000 turkeys

Kentucky H7N9 2009 20,000 broiler breeders

Missouri H7N3 2011 29,000 turkeys

Minnesota H7N9 2011 3,000 turkeys

Arkansas H7N7 2013 9,800 broiler breeders

California H5 2014 95,000 quail and 21,000 Peking ducks

Indianac H7N8 2016 352,114 turkeys and layers

Missouri H5N1 2016 39,000 turkeys

Wisconsin H5N2 2017 84,000 turkeys held in quarantine

Alabama, Georgia, and 

Tennessee

H7N9 2017 100,585 broiler breeders and backyard birds

Kentucky H7N9 2017 24,700 broiler breeders and backyard birds

Sources: U.S. Department of Agriculture and U.S. Animal Health Association. | GAO-17-360

a

We selected 2002 as the starting date for this table because data from the U.S. Department of 

Agriculture w ere readily available from that year forward in proceedings of the U.S. Animal Health 

Association’s annual meetings.

b

Broilers are chickens raised for consumption. Layers are chickens that lay eggs. Breeders produce 

offspring that facilitate mass production. Game birds are those raised for hunting.

c

The Indiana outbreak w as restricted in size and scope to a single county and 12 premises. This table 

reports on poultry at sites associated with low pathogenic avian influenza. In all, more than 414,000 

birds w ere affected.
Page 20 GAO-17-360 Avian Influenza

The effect of avian influenza on the health of other animal species varies. 

Avian influenza generally causes few signs of illness and is rarely fatal 

when it circulates in waterfowl and shorebirds. Because wild birds are 

rarely sickened by the virus, they are able to move it efficiently along 

migratory flyways. Interior officials told us, however, that incidents in 

which wild birds have been killed by highly pathogenic avian influenza 

have become more common; these officials noted in particular incidents 

in Asia involving the H7N9 virus. According to the World Health 

Organization, some mammal species, including swine, can be infected 

with avian influenza but may show few, if any, observable symptoms, and 

others, such as ferrets, may experience high morbidity and mortality.19

Infections in waterfowl and swine are of concern because they can 

spread the virus to poultry and humans, according to the World 

Organisation for Animal Health.20 Swine can also serve as “mixing 

vessels” in which different influenza viruses come into contact, exchange 

genetic material, and possibly produce a new virus that is more easily 

transmissible to or between humans.21 The H1N1 virus that emerged in 

2009 contained gene segments from swine, avian, and human influenza 

viruses. According to the World Health Organization, the virus caused a 

global pandemic with up to 550,000 human deaths worldwide from April 

2009 to April 2010; the CDC estimates that up to 18,000 of those human 

deaths occurred in the United States.22 In addition, a 1976 outbreak of 

H1N1 swine influenza at Fort Dix, New Jersey, infected up to 230 humans 

and killed 1 person. More recently, according to CDC documents, more 

than 360 people in the United States were infected with influenza A 

(H3N2) variant influenza from August 2011 through September 2016, with 

one fatality.23 Also according to CDC, these infections have mostly been 

associated with prolonged exposure to pigs at agricultural fairs.

 19Other species known to be susceptible to avian influenza include whales, horses, seals, 

dogs, cats, tigers, skunks, rats, mice, and weasels. 

20World Organisation for Animal Health, “Avian Influenza,” 

http://www.oie.int/fileadmin/home/eng/media_center/docs/pdf/disease_cards/ai-en.pdf, 

downloaded Oct. 12, 2016.

21Shinde, et al., “Triple-ReassortantSwine Influenza A (H1) in Humans in the United 

States, 2005-2009,” New England Journal of Medicine, vol. 360, no. 25 (June 18, 2009).

22Shinde, et al., “Triple-Reassortant Swine Influenza A (H1) in Humans in the United 

States, 2005-2009.” 

23Influenza viruses that normally circulate in pigs are called “variant” viruses when they 

are found in people.

Cats Infected with Avian Influenza in New 

York City Animal Shelters

According to the Centers for Disease Control 

and Prevention (CDC), in November 2016, a 

low pathogenic avian influenza A (H7N2) virus 

infected cats in New York City animal 

shelters. Some affected cats showed mild flulike symptoms such as sneezing or runny 

noses, and 450 w ere quarantined until they 

no longer show ed symptoms of infection. A 

veterinarian collecting respiratory samples 

from exposed cats contracted the virus and 

subsequently recovered. According to CDC’s 

w ebsite, known human infections with H7N2 

are uncommon and have not led to deaths. 

How ever, the agency noted that finding avian 

influenza virus in an unexpected animal, such 

as a cat, is alw ays concerning because it 

means the virus has changed in a w ay that 

may pose a new health threat.

Source: CDC. Cosmic Photography (photo). | GAO-17-360
Page 21 GAO-17-360 Avian Influenza

Outbreaks of avian influenza in poultry in the United States in 2014 and 

2016 cost the federal government about $930 million, according to USDA 

documents, and the 2014 outbreak cost the economy from $1 billion to 

$3.3 billion, according to two studies by USDA and a private firm. 

According to USDA budget documents for fiscal years 2015 and 2016, 

the agency obligated a total of about $869 million for the responses to the 

2014 outbreak in 15 states, the January 2016 outbreak in Indiana, and a 

May 2016 outbreak of low pathogenic avian influenza in Missouri. As 

shown in table 4, the largest portion of these obligations was for response 

operations, including depopulation, disposal, composting, and cleaning 

and disinfection. Indemnity payments to poultry producers were another 

large category of obligations. Nearly all of the funds were transferred from 

the Commodity Credit Corporation.24

Table 4: U.S. Department of Agriculture (USDA) Obligations for Responses to Avian Influenza Outbreaks from 2014 to 2016

Type of obligation

Obligations

through June 30, 2016

(in millions of dollars)

Response operations: depopulation, disposal, composting, cleaning and disinfection, biosecurity, and 

site management

626.7

Indemnity payments to poultry producers 206.4

Responders’ salaries 25.4

Diagnostic tests and surveillance 3.4

State cooperative agreementsa 7.4

TOTAL $869.3

Source: U.S. Department of Agriculture | GAO-17-360

a

USDA provides cooperative agreement funding to states, tribal nations, and others for surveillance, 

monitoring, and prevention and control activities.

In addition, USDA obligated about $60 million in funds transferred from 

the Commodity Credit Corporation in fiscal year 2015 on fixed costs—

such as salaries, benefits, and supplies—and other activities related to 

preparing for the possible return of the virus in the fall of 2015, such as 

wild bird surveillance and vaccine research.

 24The Commodity Credit Corporation is a government-owned and operated entity that was 

created to stabilize, support, and protect farm income and prices. The entity also helps 

maintain balanced and adequate supplies of agricultural commodities and aids in their 

orderly distribution.

Recent Outbreaks Have 

Cost the Federal 

Government and the U.S. 

Economy Billions of 

Dollars
Page 22 GAO-17-360 Avian Influenza

With respect to the U.S. economy, two separate analyses have examined 

and produced national estimates of the economic impacts from the highly 

pathogenic avian influenza outbreak that began in 2014.25 A national 

analysis conducted by USDA economists measured the 2014 outbreak’s 

impact to U.S. livestock and feed sectors, including poultry and poultry 

products, at $1 billion.26 The estimates in the analysis take into 

consideration producer and consumer behavior as prices and production 

changed in response to the reduction in production and the trade 

embargoes linked to the outbreak. The effects were measured throughout 

the course of the outbreak, allowing for estimates based on changes over 

time. According to this analysis, U.S. turkey producers lost an estimated 

$214 million in sales (a decline of 6.8 percent from 2014 levels), and 

broiler producers lost $276 million (a decline of 1.5 percent from 2014).27

While broilers were only negligibly affected by the virus, as separately 

reported by APHIS, the sector still suffered losses because of large 

decreases in demand from countries that extended full or partial bans on 

poultry and poultry products, including broilers, from the United States. In 

addition, because crops (e.g., corn and soybeans) are essential to the 

poultry sector, those commodities also experienced losses estimated at 

$373 million because of the reduction in number of birds fed. On the other 

hand, the reduced egg supply caused by the outbreak raised the price of 

eggs for consumers and, according to the analysis, led to an increase of 

$53 million in sales for U.S. egg and layer producers (an increase of 26.7 

percent from 2015 levels).28

 25For the purpose of our review, we did not include studies that did not estimate the 

national impact of the highly pathogenic avian influenza outbreaks. 

26Johansson, Robert C. et al., “Government Spending to Control Highly Pathogenic Avian 

Influenza,” Choices, vol. 31, no. 2 (2nd Quarter 2016); and Seitzinger, Ann Hillberg, and 

Philip L. Paarlberg, “Regionalization of the 2014 and 2015 Highly Pathogenic Avian 

Influenza Outbreaks,” Choices, vol. 31, no. 2 (2nd Quarter 2016). The analysis used a 

quarterly partial equilibrium economic model of the U.S. feed and livestock agricultural 

sector. For more information on estimating the economic impacts of disease outbreaks, 

see Paarlberg, P.L., et al., Economic Impacts of Foreign Animal Disease, Economic 

Research Report 57 (Washington, D.C.: U.S. Department of Agriculture, Economic 

Research Service, May 2008).

27The analysis also estimated losses of $45.9 million in value added throughout the turkey 

sector and losses of $150.3 million in value added throughout the broiler sector. Valueadded losses refer to losses to participants in the sector other than the producers.

28The analysis also estimated a gain of $16.2 million in value added throughout the egg 

sector. 
Page 23 GAO-17-360 Avian Influenza

The second national analysis contained a preliminary estimate of $3.3 

billion in total economy-wide losses through June 29, 2015, from the 2014 

outbreak of highly pathogenic avian influenza.29 This included direct 

losses to the turkey and egg processing sectors of $1.6 billion, with 

losses of $530 million for turkeys and $1.04 billion for laying hens. The 

$3.3 billion estimate included macroeconomic impacts due to losses to 

other indirect sectors, such as retail and foodservice, but did not include 

activities such as clean-up, restocking, or future lost production while the 

producer prepares to resume production at a pre-disease level.30 Also, 

unlike the first analysis noted above, this analysis did not include 

consumer or producer responses to changes in prices or production, such 

as increases in egg prices due to production losses.

Starting from the beginning of the avian influenza outbreak in December 

2014, 18 trading partner nations imposed bans on all shipments of U.S. 

poultry and products, and 38 trading partners imposed partial, or regional, 

bans on shipments from states or parts of states experiencing outbreaks. 

According to USDA officials, as of January 2017, China, Kyrgyzstan, 

Russia, and Thailand continued to impose national bans on U.S. poultry 

imports that were attributed to concerns about highly pathogenic avian 

influenza, and Jamaica had imposed a state ban on U.S. poultry imports 

from several Midwestern states. Total U.S. poultry and product exports 

declined in value from about $6.4 billion in 2014 to $4.9 billion in 2015.31

The largest of these declines was from the U.S. broiler meat industry, 

which fell from $4.1 billion to $3.0 billion over that period. While a USDA 

report attributed part of this decline in exports to a strong U.S. dollar, the 

report also noted that the avian influenza outbreak that began in 2014 

caused the poultry industry to lose market share to other poultry exporters 

such as Brazil.32 According to a September 2016 USDA report, export 

levels of broiler chickens—the largest poultry export sector—were 

 29Elam, Thomas E., “Economic Losses from the 2015 Highly Pathogenic Avian Flu 

Outbreak,” FarmEcon LLC (June 29, 2015).

30The author applied a multiplier of 2.1, from the University of Minnesota, to the estimated 

$1.6 billion in direct losses to turkey and egg processing sectors to arrive at the estimate

of $3.3 billion in losses to the economy. 

31Foreign Agriculture Service, Global Agricultural Trade System Online, Standard Query 

of all poultry and product exports from the U.S. to the world, 

https://apps.fas.usda.gov/gats/default.aspx. February 2017.

32U.S. Department of Agriculture, Foreign Agricultural Service, Livestock & Poultry: World 

Markets and Trade (Washington, D.C.: April 2016).
Page 24 GAO-17-360 Avian Influenza

modestly rebounding in 2016 from the levels that followed the end of the 

highly pathogenic avian influenza outbreak in 2015, although these 2016 

levels were still at their lowest since 2011.33 In addition, according to the 

USDA report, turkey exports remained weak compared to the pre-avian 

influenza trends, and egg exports in July 2016 were 6 percent lower than 

the previous year. USDA noted that some major importing countries had 

lifted trade bans since the 2014 outbreak and that other factors, such as 

the strength of the dollar, have also affected exports. USDA officials 

involved in the response also said that the negative effect on U.S. poultry 

exports was partially mitigated by the fact that some countries imposed 

regional, rather than national, bans on U.S. poultry products. In addition, 

the agency’s implementation of secure food supply plans allowed poultry 

producers to move non-infected products during the outbreaks.34 A goal 

of these plans is to continue business operations from locations that are 

not infected with disease.

After the March 2017 detections of highly pathogenic H7N9 avian 

influenza in two commercial flocks in Lincoln County, Tennessee, 

numerous countries imposed trade restrictions on U.S. poultry exports. 

For example, the Republic of Congo (Brazzaville) imposed restrictions on 

poultry imports from the entire United States. Some countries, such as 

South Africa, Taiwan, and Uruguay, placed restrictions on poultry imports 

from the entire state of Tennessee while others, such as Jamaica and the 

European Union, imposed restrictions on certain geographic areas or 

counties. Similarly, after detections of low pathogenic avian influenza in 

March 2017, countries placed restrictions on imported poultry from all or 

parts of Alabama, Georgia, Kentucky, and Wisconsin.

 33U.S. Department of Agriculture, Economic Research Service, Livestock, Dairy, and 

Poultry Outlook (Washington, D.C.: Sept. 16, 2016).

34Secure food supply plans are guidance documents that describe the requirements and 

processes by which non-infected producers can qualify for a permit to move non-infected 

animal products within, out of, and into animal disease outbreak control areas. These 

plans exist in final or draft forms for the broiler, egg, and turkey sectors. The plans were 

developed through a collaborative effort among USDA and other federal and state 

agencies, industry, and academia. For example, the Egg Sector Working Group 

participated in a private-public-academic partnership to develop practical and 

implementable solutions for market continuity during an outbreak of highly pathogenic 

avian influenza.
Page 25 GAO-17-360 Avian Influenza

USDA identified lessons learned from its responses to the 2014 and 2016 

highly pathogenic avian influenza outbreaks and has taken numerous 

corrective actions to address them. However, USDA does not have plans 

for evaluating the extent to which the corrective actions have helped 

resolve the problems that they were intended to address.

After the outbreaks of highly pathogenic avian influenza in 2014 and 

2016, USDA identified lessons learned related to its response activities 

and has taken numerous corrective actions to address those lessons 

learned.35 To identify the lessons learned from both the widespread 

outbreak that began in 2014 and the limited 2016 outbreak in Indiana, 

USDA proactively collected feedback about its performance during and 

after the outbreaks from federal and state animal health officials and from 

industry representatives involved in the responses. The agency then 

summarized this feedback into after action reports that included 

observations about strengths and weaknesses in the responses. The 

identified lessons learned covered a wide range of response areas, 

including the depopulation of infected birds, disposal of bird carcasses, 

and surveillance of flocks for infection. For example, according to USDA 

documents, rapid depopulation is critical to help prevent or mitigate the 

spread of the disease by eliminating infected, exposed, or potentially 

exposed animals. However, USDA noted that during the 2014 outbreak, 

there were substantial delays in completing depopulation, with producers 

reporting that it took as long as 11 days to begin depopulation on many 

premises.

USDA developed a corrective action program to identify, prioritize, and 

implement corrective actions that are intended to address the root causes 

of the lessons learned. The agency identified 308 corrective actions 

across 15 response areas and created a corrective action database to 

track the actions (see table 5 for the list of 15 response areas and 

 35According to Homeland Security Exercise and Evaluation Program guidance, corrective 

actions are concrete, actionable steps that are intended to resolve gaps and shortcomings 

experienced during emergency response exercises and real-world incidents. 

USDA Has Taken 

Corrective Actions to 

Address Lessons 

Learned but Does Not 

Have Plans to 

Evaluate Their 

Effectiveness

USDA Has Identified 

Lessons Learned from the 

2014 and 2016 Outbreaks 

and Taken Numerous 

Corrective Actions
Page 26 GAO-17-360 Avian Influenza

examples of lessons learned and corrective actions associated with each 

area.)

Table 5: Examples of Lessons Learned and Corrective Actions U.S. Department of Agriculture (USDA) Identified after Its 

Responses to the 2014 and 2016 Outbreaks of Highly Pathogenic Avian Influenza

Example

Response area

Number of 

corrective

actions under

response area Lesson learned 

Corrective action to address 

lesson learned 

Status of 

corrective 

action, 

according to 

USDA’s 

database, as of 

January 2017a

Appraisal and 

compensation 

8 Indemnity calculators did not capture 

all costs accurately. 

Update indemnity calculators. Complete/ongoing

Biosecurity 23 Producers reported biosecurity 

infractions by contracted response 

teams, potentially leading to further 

disease spread.

Develop biosecurity training 

materials for contracted response 

teams and post on USDA 

website. 

Complete

Communication 54 USDA responders did not have 

established relationships with local 

officials in some response areas, 

leading to coordination or logistics 

issues. 

Develop a protocol for contacting 

and meeting local officials to 

address any concerns, ideally 

before response operations 

begin. 

In progress

Continuity of 

businessb 5 Collaboration has been lacking between industry and agricultural 

policy leaders regarding ways to 

mitigate disruptions to the domestic 

animal food supply during a disease 

outbreak. 

Consider assisting with 

development of secure food 

supply plans for all segments of 

the poultry industry and 

coordinating the updates of 

existing plans based on 

experiences from the outbreaks.c

Complete

Diagnostics 9 Some laboratories did not have the 

capability to make diagnostic test 

results available electronically, leading 

to delays in reporting results. 

Increase electronic messaging 

capabilities at laboratories. 

In progress

Disposal 10 Available guidance for composting 

dead bird carcasses was insufficient, 

leading USDA to contract with external 

composting experts who were 

sometimes unfamiliar with composting 

large quantities of bird carcasses.

Identify and train USDA 

personnel as composting experts 

to advise producers in the event 

of an outbreak. 

Complete

Epidemiological 

investigation and 

tracingd 

5 Better epidemiological information 

gathering at the outset of the incident 

would have improved operational 

decision making. 

Hone initial information-gathering 

instruments by developing a 

mini-questionnaire to collect and 

communicate epidemiological 

information. 

Complete
Page 27 GAO-17-360 Avian Influenza

Example

Response area

Number of 

corrective

actions under

response area Lesson learned 

Corrective action to address 

lesson learned 

Status of 

corrective 

action, 

according to 

USDA’s 

database, as of 

January 2017a

Finance 8 Better defined roles and 

responsibilities for cost control and 

contract management are needed to 

ensure that funding or finance issues 

are resolved.

Develop a standard operating 

procedure on the reporting of the 

status of funds and finalize a 

finance coordination plan.

In progress

Health and safety 

and personal 

protective 

equipment 

14 Safety officers were not always notified 

of safety and health hazards in a timely 

manner. 

Develop a consistent procedure 

for reporting all safety and health 

hazards and incidents to the site 

supervisor and then to the safety 

officer as soon as practicably 

possible.

In progress

Incident 

managemente

81 Transitions between response teams 

in states with prolonged response 

operations were difficult due to nonstandardized positions and protocols. 

Institute a 2-day transfer period 

for rotating response teams. 

Complete

Information 

management 

36 Some responders were unfamiliar with 

USDA’s electronic record-keeping 

system for animal disease outbreaks, 

resulting in incorrect use or underuse 

of the system. 

Develop standard reports and 

maps for use by responders. 

Complete

Logistics 36 There was not a standardized 

approach for USDA response teams to 

track equipment and personnel, 

leading to risk of miscounting or not 

deploying resources.

Develop a job aid that describes 

check-in and check-out 

procedures for equipment and 

personnel. 

In progress

Mass 

depopulation and 

euthanasia 

13 There were not enough skilled 

personnel available for depopulation of 

infected domesticated poultry, leading 

to delays in depopulation and possible 

increased disease transmission.

Encourage states to form 

depopulation teams that can be 

deployed in an outbreak by 

providing guidance and training. 

Complete

Surveillance 3 Surveillance sampling of commercial 

flocks did not always identify infected 

birds prior to widespread illness. 

Collaborate with industry to 

evaluate and improve existing 

sampling procedures.

In progress

Vaccination 3 A national vaccination strategy that 

outlines how and when USDA would 

use vaccines needs to be further 

defined. 

Develop clear and simple 

messages about the use of 

vaccines and implications for 

food safety and human health. 

Complete

Total 308 — — —

Source: GAO summary of U.S. Department of Agriculture corrective action program database. | GAO-17-360

Note: For the response areas, USDA identified multiple lessons learned and corrective actions to 

address those lessons learned. This table provides examples of lessons learned and corrective 
Page 28 GAO-17-360 Avian Influenza

actions for each response area. We selected examples of lessons learned and corrective actions that 

w e believe clearly illustrate the nature of the response area.

a

The status of “complete” indicates that a corrective action w as completed by some action. “Closed” 

indicates USDA determined that a corrective action was not applicable or advisable, w as duplicative, 

or w as subsumed in another lesson learned and no longer requires action. “Complete/ongoing” 

indicates that an initial task has been satisfied but that activities related to the recommendation w ill be 

ongoing, according to USDA officials.

b

Continuity of business involves managing non-infected poultry operations and products during an 

outbreak to help the agriculture and food industries maintain typical business or return to business 

during and after a disease response.

c

Secure food supply plans are guidance documents that describe the requirements and processes by 

w hich non-infected producers can qualify for a permit to move non-infected animal products w ithin, 

out of, and into animal disease outbreak control areas. These plans exist or are under development 

for certain sectors of the poultry sector, such as the broiler, turkey, and egg sectors. The plans w ere 

developed through a collaborative effort among USDA and other federal and state agencies, industry, 

and academia.

d

Epidemiological investigation and tracing involves examining the spread of disease by time, place, 

and animal, as w ell as the mode of transmission and source of entry of disease. In particular, it 

involves conducting outbreak investigations on the premises w here the disease is detected and 

identifying patterns of geographic distribution to determine factors associated with the onset and 

spread of disease.

e

Incident management involves the overall coordination and organization of the response, such as 

establishing and maintaining response teams in the field and nationw ide.

USDA prioritized the corrective actions according to their implications for 

future outbreaks and, for the highest priority actions, their time frame for 

completion. Specifically, USDA defined priority 1 corrective actions as 

those that would have immediate, critical implications for a future 

outbreak and that could be completed in less than 1 year; priority 2 

actions as those that would have positive implications for a future 

outbreak or would have immediate, important implications but that may 

not be completed within 1 year; and priority 3 actions as those that are 

under consideration or that would have less critical implications for a 

future outbreak.

According to our review and summary of USDA’s corrective action 

database, the agency has marked as completed about 70 percent of its 

corrective actions, including about 86 percent of the priority 1 actions (see 
Page 29 GAO-17-360 Avian Influenza

table 6).36 As of January 2017, USDA did not have time frames for 

completing about 82 percent of the uncompleted priority 2 and priority 3 

corrective actions. For example, USDA has not established a time frame 

for completing a priority 2 corrective action related to depopulation that 

calls for the agency to develop training materials for contracted 

responders to help ensure there are enough skilled personnel available 

for depopulation. This action is marked as “in progress” in the database. 

When we raised this issue during the course of our review, USDA officials 

responsible for the database said they are working with the groups in 

charge of taking corrective actions to identify time frames for the 

remaining priority 2 and priority 3 actions, but they said that it is complex 

and difficult to do so in light of other agency disease response activities. 

For example, they said that responding to an outbreak of New World 

screwworm in Florida in fall 2016 had caused the agency to pause some 

of its efforts to address corrective actions from the highly pathogenic 

avian influenza outbreaks.37 Nonetheless, agency officials acknowledged 

that time frames are important and said they will continue to develop 

them.

 36We are defining completed actions as those in USDA’s corrective action database with a 

status of “complete,” which indicates that a corrective action was completed by some 

action; “closed,” which indicates USDA determined that a corrective action was not 

applicable or advisable, was duplicative, or was subsumed in another lesson learned and 

no longer requires action; and “complete/ongoing,” which indicates that an initial task has 

been satisfied but that activities related to the recommendation will be ongoing, according 

to USDA officials. Examples of these activities include training, biosecurity messaging, 

and investigating alternative depopulation methods, according to USDA officials. 

According to the corrective action database, as of January 2017, about 47 percent of the 

corrective actions were marked as “complete,” about 16 percent were marked as “closed,” 

and about 7 percent were marked as “complete/ongoing.” In addition, about 28 percent 

were marked as “in progress” and 1 percent as “not initiated.” (The total does not add to 

100 percent due to rounding).

37According to a USDA fact sheet, New World screwworms (Cochliomyia hominivorax) 

are fly larvae (maggots) that can infest livestock and other warm-blooded animals, 

including humans. They most often enter an animal through an open wound and feed on 

the animal’s living flesh. If not treated, infestations can be fatal. While New World 

screwworm has not been widely present in the United States since the 1960s, it is still 

found in most of South America and in five Caribbean countries. If this pest became 

established in the United States again, it could cause more than $1 billion in losses for the 

country’s livestock industry. 
Page 30 GAO-17-360 Avian Influenza

Table 6: Number of Corrective Actions U.S. Department of Agriculture (USDA) Identified Based on Lessons Learned From Its 

Responses to the 2014 and 2016 Outbreaks of Highly Pathogenic Avian Influenza, and Percent Completed

Priority Number of corrective actions Percent marked as completed, as of January 2017a

1 121 86

2 141 55

3 46 78

Total 308 —

Source: U.S. Department of Agriculture corrective action program database. | GAO-17-360

Note: USDA defined priority 1 corrective actions as those that w ould have immediate, critical 

implications for a future outbreak and that could be completed in less than 1 year; priority 2 actions as 

those that w ould have positive implications for a future outbreak or w ould have immediate, important 

implications but that may not be completed w ithin 1 year; and priority 3 actions as those that are 

under consideration or that w ould have less critical implications for a future outbreak.

a

We are defining completed actions as those in USDA’s corrective action database w ith a status of 

“complete,” w hich indicates that a corrective action w as completed by some action; “closed,” which 

indicates USDA determined that a corrective action was not applicable or advisable, w as duplicative, 

or w as subsumed in another lesson learned and no longer requires action; and “complete/ongoing,” 

w hich indicates that an individual recommendation has been satisfied but that activities related to the 

recommendation w ill be ongoing, according to USDA officials.

USDA has taken steps to implement corrective actions, but it does not 

have plans to evaluate the extent to which completed corrective actions 

have effectively helped to resolve the problems the agency identified in its 

responses to the recent outbreaks. We have previously found that 

agencies may use evaluations to ascertain the success of corrective 

actions, and that a well-developed plan for conducting evaluations can 

help ensure that agencies obtain the information necessary to make 

effective program and policy decisions.38 An evaluation plan should 

include, among other things, evaluative criteria or comparisons, or how or 

on what basis program performance will be judged or evaluated. We also 

found that one approach agencies can use to evaluate changes in events 

that occur infrequently and unpredictably, such as disease outbreaks, is 

to conduct simulations or exercises to assess how well an agency’s plans 

anticipate the nature of its threats and vulnerabilities. Homeland Security 

Exercise and Evaluation Program guidance, which USDA officials told us 

they used in developing the corrective action program, states that 

agencies should put in place a system to test and validate corrective 

 38GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: Jan. 31, 

2012) and Tax Administration: IRS Needs to Strengthen Its Approach for Evaluating the 

SRFMI Data-Sharing Pilot Program, GAO-09-45 (Washington, D.C.: Nov. 7, 2008). 

USDA Does Not Have 

Plans to Evaluate the 

Effectiveness of its 

Corrective Actions
Page 31 GAO-17-360 Avian Influenza

actions that have been implemented.39 This guidance states that 

agencies can identify the corrective actions that require validation and 

then conduct exercises to test whether those corrective actions have led 

to improvements.40

In our review of a nongeneralizable sample of 10 completed corrective 

actions designated as priority 1, it was unclear to what extent such 

actions were effective because, while USDA marked in its database that it 

had completed the corrective actions, it had not evaluated the extent to 

which these actions achieved the desired outcome. For example, one 

lesson learned that USDA identified was that many producers lack a 

strong culture of biosecurity. However, although USDA completed 

corrective actions associated with that lesson—creating a joint biosecurity 

website with the U.S. Poultry and Egg Association and putting greater 

emphasis on biosecurity in conferences with producers—it did not 

evaluate to what extent taking these actions created a strong culture of 

biosecurity among producers. In another lesson learned, USDA identified 

that states and producers encountered impediments in transporting bird 

carcasses to landfills, such as federal and state rules restricting the 

movement of bird carcasses along transportation routes in close proximity 

to other producers. USDA completed corrective actions associated with 

that lesson—providing guidance, training, and encouragement to states 

and producers to develop disposal plans—but did not evaluate to what 

extent taking these actions helped overcome the impediments observed. 

In addition, depopulation experts we interviewed raised concerns about 

whether USDA’s planned and completed corrective actions will effectively 

address the challenges with depopulation experienced during the 2014 

and 2016 outbreaks. For example, these experts questioned whether a 

sufficient number of federal employees and contracted responders have 

been trained in using depopulation equipment to address a lesson 

 39The Homeland Security Exercise and Evaluation Program provides a set of guiding 

principles for national preparedness exercises, including principles for exercise evaluation 

and improvement planning. The Department of Homeland Security’s Federal Emergency 

Management Agency issued guidance for the program in 2013. The Department of 

Homeland Security, Homeland Security Exercise and Evaluation Program (HSEEP) 

(Washington, D.C.: April 2013). 

40According to the Homeland Security Exercise and Evaluation Program guidance, 

exercises are instruments to train for, assess, practice, and improve performance in 

prevention, mitigation, response, and recovery capabilities in a risk-free environment. 

Exercises can be used for testing and validating policies, plans, procedures, training, 

equipment, and interagency agreements, among other things. 
Page 32 GAO-17-360 Avian Influenza

learned that there were not enough skilled personnel available for 

depopulation during recent outbreaks.

USDA documents state that the 2016 outbreak provided an opportunity to 

see that some of the corrective actions taken following the 2014 outbreak 

resulted in an improved response. For example, according to USDA’s 

after action report on the 2016 outbreak, the changes that USDA made to 

the process for compensating poultry producers for losses after the 2014 

outbreak resulted in a faster and more efficient process during the 2016 

outbreak. Nonetheless, USDA officials acknowledged that they are not 

certain whether completing other corrective actions will be sufficient to 

address the lessons learned from both outbreaks. They acknowledged 

the importance of evaluating corrective actions to determine whether 

additional steps are needed but said that the agency does not yet have 

plans to do so. Agency officials also told us that evaluating the 

effectiveness of these corrective actions will need to be a continuous 

process and should be considered within the broader context of USDA’s 

emergency preparedness for disease response. For example, USDA 

officials told us they intend to incorporate lessons learned and corrective 

actions from the agency’s response to the 2016 New World screwworm 

outbreak into the corrective action database for highly pathogenic avian 

influenza, so that the database becomes a broader tool that the agency 

can use to track corrective actions related to its overall disease response 

efforts. By developing a plan for evaluating completed corrective actions 

and, as part of this plan, considering whether any completed corrective 

actions require validation through simulations or exercises, USDA could 

better determine the effectiveness of these actions.

On the basis of stakeholders’ views and our analysis of federal efforts to 

respond to outbreaks, we identified ongoing challenges and associated 

issues that federal agencies face in mitigating the potential harmful 

effects of avian influenza. These challenges are in protecting 

domesticated poultry from the threat of avian influenza that circulates 

naturally in wild birds and in relying on voluntary actions by a wide range 

of poultry producers to prevent poultry flocks from becoming infected. 

Federal agencies also face other issues associated with mitigating the 

potential harmful effects of avian influenza: the virus could infect poultry 

needed to produce eggs used in manufacturing critical human vaccines 

against pandemic influenza, and federal funding will soon be exhausted 

for a voluntary surveillance program that gathers information about the 

presence of influenza viruses in swine that could pose a threat to human 

health.

Federal Agencies 

Face Ongoing 

Challenges and 

Associated Issues in 

Their Efforts to 

Mitigate the Potential 

Harmful Effects of 

Avian Influenza
Page 33 GAO-17-360 Avian Influenza

We identified two ongoing challenges that federal agencies face in 

mitigating the potential harmful effects of avian influenza. First, federal 

agencies are challenged in protecting domesticated poultry from avian 

influenza because the disease naturally circulates in migratory birds, 

which may spread the disease. Second, federal efforts to prevent poultry 

flocks from infection are challenged because these efforts rely on 

voluntary biosecurity measures by poultry producers.

Federal agencies face an ongoing challenge in protecting domesticated 

poultry from avian influenza because the disease naturally circulates in 

migratory birds, such as ducks and geese, which are hard to control and 

which may come into contact with poultry. Because of their migratory 

behavior, wild birds infected with avian influenza can spread the disease 

across long distances, including from as far away as Asia. Federal 

agencies and others are authorized under the Migratory Bird Treaty Act to 

sample ducks, geese, and other migratory birds to confirm the presence 

of an infectious disease, including influenza.41 According to Interior 

officials, the Act also provides agencies the authority to control migratory 

birds infected with avian influenza, but the officials noted that experience 

has shown that such efforts are ineffective. As reported in a text on avian 

influenza, humans have had and will continue to have minimal impact on 

control of low pathogenic avian influenza viruses in wild bird 

populations.42

 41Migratory Bird Treaty Act, ch. 128, 40 Stat. 755 (1918) (codified as amended at 16 

U.S.C. §§ 703-712). The Act prohibits, among other things, the selling, transporting, or 

importing of migratory birds, their eggs, parts, and nests, except when specifically 

authorized by regulation.

42Swayne, Avian Influenza.

Ongoing Challenges that 

Federal Agencies Face in 

Mitigating the Potential 

Harmful Effects of Avian 

Influenza

Protecting Domesticated 

Poultry from the Threat of 

Avian Influenza Carried by 

Wild Birds Is a Challenge
Page 34 GAO-17-360 Avian Influenza

Although federal agencies are unlikely to control avian influenza viruses 

in wild birds, they can monitor the viruses circulating in this population. 

Specifically, USDA, Interior’s U.S. Geological Survey and U.S. Fish and 

Wildlife Service, and state and tribal agencies collaborated on a national 

program for wild bird surveillance that sampled more than 283,000 wild 

birds from April 2006 through March 2011, when the program ended.43

The federal effort resumed in December 2014 in response to the 

outbreaks of highly pathogenic avian influenza on the West Coast of 

North America. In response to the outbreaks, personnel from USDA and 

Interior re-convened the Interagency Wild Bird Avian Influenza Steering 

Committee in January 2015. The Steering Committee developed a wild 

bird surveillance plan for avian influenzas that may pose a threat to 

human health or domestic poultry.44 The plan encourages federal and 

state agencies and others to use a variety of sampling methods to test 

live and dead wild birds for avian influenza. According to data recorded as 

of March 24, 2017, the surveillance program had collected test results 

from more than 88,000 wild birds since December 2014. The data for that 

time period show that the program detected 102 cases (about 0.12 

percent) of highly pathogenic avian influenza from the same lineage that 

caused the 2014 and 2016 outbreaks in the United States (see app. II for 

details on the results of this surveillance program). On the other hand, 

monthly detection rates for low pathogenic avian influenza A viruses in 

wild birds were often above 10 percent for those tested. According to 

USDA and Interior officials, continued monitoring of wild birds will help 

identify the presence of avian influenza subtypes and help agencies to 

mitigate the persistent challenge that wild birds pose to domesticated 

poultry. The state veterinarians we interviewed from California, Indiana, 

Iowa, Minnesota, North Carolina, and Ohio generally agreed with the 

need for wildlife surveillance.

 43Bevins, Sarah N., et al. “Large-Scale Avian Influenza Surveillance in Wild Birds 

throughout the United States,” PLoS ONE, vol. 9, no. 8: e104360 (August 12, 2014). 

doi:10.1371/journal.pone.0104360.

44The Interagency Steering Committee for Surveillance for Highly Pathogenic Avian 

Influenza in Wild Birds, Early Detection and Monitoring for Avian Influenzas of Significance 

in Wild Birds: A U.S. Interagency Strategic Plan (Washington, D.C.: June 2015).

Use of Vaccines to Eradicate Avian 

Influenza

According to the U.S. Department of 

Agriculture (USDA), poultry vaccination has 

been part of control or eradication programs 

for avian influenza viruses in a number of 

countries. Effective vaccination can decrease 

transmission betw een animals by decreasing 

their susceptibility to infection and reducing 

the amount of virus an infected animal may 

shed. Vaccination has been used in some 

successful eradication campaigns for low 

pathogenic avian influenza outbreaks in the 

United States but never for highly pathogenic 

avian influenza outbreaks such as those that 

occurred in 2014 and 2016, according to 

USDA.

Stakeholders w e interviewed characterized 

the decision to use poultry vaccines to control 

and eradicate the 2014 and 2016 outbreaks 

as having both scientific and economic 

components. From a scientific perspective, a 

vaccine needs to be able to protect against a 

specific influenza virus to be effective and 

merit use. In June 2015, USDA announced 

that the vaccines available at the time w ere 

not w ell matched to the virus that w as 

infecting poultry in numerous states. As an 

example of the economic implications of 

vaccines, USDA also announced in June 

2015 that significant trading partners had 

indicated that, if USDA began vaccinating, 

they w ould ban all U.S. poultry and egg 

exports until they could complete a risk 

assessment. For these and other reasons, 

USDA decided against using vaccines. 

USDA’s Agricultural Research Service 

continues to develop enhanced vaccines for 

use in poultry against avian influenza. A 2014 

USDA report concluded the poultry industry 

needs highly effective vaccines that can 

prevent transmission and that can be massdelivered in w ater, in eggs, or in feed.

Source: GAO analysis of USDA documents and interviews 

with stakeholders. | GAO-17-360
Page 35 GAO-17-360 Avian Influenza

Federal efforts to ensure routine biosecurity and prevent poultry flocks 

from becoming infected with avian influenza face an ongoing challenge 

because these efforts depend on voluntary actions by a wide range of 

poultry producers. While USDA’s approach to addressing this challenge 

varies for different types of poultry producers, such as those who manage 

large commercial operations and those who manage small backyard 

flocks, the approach primarily relies on using incentives and education to 

promote voluntary actions.

According to USDA officials, state stakeholders, and poultry industry 

representatives we interviewed, sound biosecurity practices are important 

for all types of poultry facilities. This is also evident from the 2014 and 

2016 outbreaks of highly pathogenic avian influenza, which affected large 

commercial and small backyard flocks, including turkeys, laying hens, and 

ducks. USDA found that lapses in routine preventative biosecurity allowed 

the initial introduction of disease and enabled it to spread from farm to 

farm. To gather information on biosecurity practices, USDA analyzed selfassessments completed by 850 poultry producers on the status of their 

biosecurity practices. While large producers generally indicated more 

frequently than small producers that they had certain practices in place, 

the nongeneralizable data showed that important practices were not 

consistently in place. For example, less than 60 percent of respondents 

had biosecurity officers or training in place. According to USDA’s selfassessment document, biosecurity officers and training could help reduce 

the threat of infection by improving biosecurity practices. Similarly, less 

than 60 percent of respondents had delineated lines of separation in their 

facilities to reduce the risk of contamination. Lines of separation are 

intended to reduce the risk that contaminated materials come into contact 

with poultry. In addition, less than 60 percent of respondents said that 

they had practices in place for personnel to shower or change into clean 

clothes immediately prior to arriving at a poultry site, or upon arrival, to 

reduce the risk of introducing an avian influenza virus.

While USDA can impose biosecurity measures during its response to an 

emergency, the agency does not have the authority to require producers 

to routinely employ preventative biosecurity measures. Instead, USDA 

relies on producers to take voluntary action to prevent the introduction of 

avian influenza and other diseases. Toward that end, USDA recently 

initiated two interrelated efforts—independent of the corrective action 

program described above—that may help overcome this challenge 

among commercial farms. In addition, USDA has continued its efforts, 

through public education and outreach, to encourage backyard poultry 

farmers to practice biosecurity.

Reliance on Voluntary Actions 

by a Wide Range of Poultry 

Producers to Prevent Flocks 

from Avian Influenza Infections 

Is a Challenge
Page 36 GAO-17-360 Avian Influenza

USDA’s first initiative to improve biosecurity involves linking producers’ 

eligibility for indemnity payments to a biosecurity plan. Specifically, USDA 

issued an interim rule in February 2016 requiring large poultry producers 

seeking indemnity payments in the future to provide a statement that, at 

the time highly pathogenic avian influenza was detected in their facilities, 

they had in place and were following a written biosecurity plan to address 

the potential spread of the virus.45 According to USDA officials, this 

regulatory change provides a strong incentive to members of the poultry 

industry to have a biosecurity plan in place. As of February 2017, USDA 

continues to operate under the interim rule issued in February 2016.

The second and related initiative concerns changes to the National 

Poultry Improvement Plan. According to USDA officials, poultry industry 

representatives who commented on the interim indemnity rulemaking 

suggested that the agency use the National Poultry Improvement Plan to 

promote biosecurity. The improvement plan is a voluntary program 

administered by USDA under which participating commercial poultry 

flocks are tested to ensure they are free from diseases, including H5 and 

H7 subtypes of avian influenza. If a flock tests negative for avian 

influenza, USDA certifies to trading partners and others that the flock is 

free of the disease. In September 2016, delegates to the program—who 

included poultry industry representatives—gave interim approval to add a 

set of 14 biosecurity principles to the plan’s national program standards.46

The biosecurity principles call for, among other things, training poultry 

producers about biosecurity; taking steps to protect against infection from 

wild birds, rodents, and insects; cleaning vehicles and equipment to 

reduce risk; and managing manure and litter to prevent the exposure of 

susceptible poultry to disease agents. Those principles would apply to the 

poultry producers who participate in the program; according to USDA 

officials, most commercial poultry producers participate. According to 

USDA officials, these initiatives will encourage commercial producers to 

adopt preventative biosecurity measures.

 4581 Fed. Reg. 6745, (Feb. 9, 2016).

46The National Poultry Improvement Plan delegates are elected by a representative group 

of participating industry members and are certified by the state agency. It is recommended 

that the delegates be plan participants. Each cooperating state is entitled to one official 

delegate for each of several types of poultry production in which the state has at least one 

participant. The types of poultry production include egg-type chickens, meat-type 

chickens, turkeys, other types of poultry, waterfowl, game birds, and others. 
Page 37 GAO-17-360 Avian Influenza

Commercial poultry flocks may also be raised outdoors and thus are at 

greater risk of contact with wild birds infected with avian influenza. For 

example, turkeys and chickens must have access to outdoor space to be 

certified by USDA as organically raised.47 Organically raised poultry are a 

rapidly growing segment of the industry, according to USDA documents.48

Stakeholders told us that they were concerned that producers of 

organically raised poultry do not have to follow the same biosecurity 

principle—namely, keeping birds indoors—that producers of conventional 

poultry are encouraged to follow. USDA has acknowledged that 

organically raised birds are at a greater risk than birds raised indoors. 

USDA’s policy is that if it is determined that temporary confinement of 

birds is needed to protect the health, safety, and welfare of organic flocks, 

then producers and certifiers may work together to determine an 

appropriate method and duration of confinement of such flocks without a 

loss of organic certification.

Stakeholders we interviewed told us backyard poultry flocks are a 

concern for contracting and spreading avian influenzas to commercial 

poultry because these flocks are raised outdoors and are more likely to 

come into contact with wild birds.49 According to USDA’s website, raising 

backyard poultry is a growing trend across the United States. USDA 

manages the “Biosecurity for Birds” campaign to help raise awareness 

among backyard, hobby, and pet bird owners about the risks of avian 

influenza. The biosecurity principles that USDA promotes to backyard 

poultry producers include separating the domesticated flock from other 

birds, including game birds and wild waterfowl, because the latter can 

carry disease. According to an agency document, USDA works

cooperatively with state animal health officials and the poultry industry to 

look for disease in breeding flocks, in backyard poultry, and at live bird 

 4782 Fed. Reg. 7042, (Jan. 19, 2017). Subsequent to the publication of this final rule, 

USDA announced a 60-day delay of the rule’s effective date, consistent with the 

memorandum of January 20, 2017, from the Assistant to the President and Chief of Staff, 

entitled, Regulatory Freeze Pending Review. 82 Fed. Reg. 9967, (Feb. 9, 2017).

48According to USDA’s April 2016 Federal Register announcement of proposed 

amendments to the National Organic Program, data from the Organic Trade Association 

indicate that U.S. sales of organic eggs reached $514 million in 2014, an increase of 17 

percent over the previous year. 81 Fed. Reg. 21956 (Apr. 13, 2016). In 2014, U.S. organic 

poultry sales grew nearly 13 percent, to $453 million. USDA stated that there were an 

estimated 722 organic egg producers and 245 organic broiler operations in the United 

States.

49Our 2007 report on avian influenza also noted concerns about backyard flocks being a 

source of infection in commercial flocks. See GAO-07-652. 
Page 38 GAO-17-360 Avian Influenza

markets, livestock auctions, poultry dealer locations, and small bird sales, 

fairs, and shows.

We identified two other issues that federal agencies face associated with 

mitigating the potential harmful effects of avian influenza. First, outbreaks

of the disease threaten the poultry that produce the eggs used in the 

production of human pandemic influenza vaccine. Second, funding for a 

voluntary surveillance program that gathers data on influenza A viruses in 

swine that could pose a threat to human health will be exhausted in fiscal 

year 2017.

Protecting the chickens that lay the eggs needed to produce human 

pandemic influenza vaccines is an issue for federal agencies because 

these birds, like others, are susceptible to avian influenza. HHS has an 

obligation under the National Strategy for Pandemic Influenza to promote 

capabilities that assure a pandemic vaccine can be produced at a U.S.-

licensed influenza vaccine facility at any time of the year, without 

limitations imposed by the availability of essential supplies. Pandemic 

influenza vaccines may be manufactured using several technologies. To 

date, the most commonly used technology has relied on fertilized eggs as 

a raw material.50 According to HHS officials, 90 to 95 percent of the 

current national stockpile of pandemic influenza vaccines is derived from 

eggs. According to an HHS official, the agency has a stockpile of eggbased and cell-based pre-pandemic influenza vaccines supplied by four 

companies. Of the four companies, however, only one has an egg-based 

vaccine manufacturing facility in the United States. If an influenza 

pandemic is declared, according to this official, the U.S. government may 

not be able to rely on foreign countries to allow exports of pandemic 

vaccine because each country will likely prioritize those vaccines for its 

own population. Therefore, the U.S. government considers the one U.S.-

based company as the only dependable manufacturer for producing eggbased vaccine for rapid pandemic mitigation.

This company contracts with suppliers to provide it with the necessary 

egg supply. HHS officials and company representatives told us that the 

company has an egg production network that includes flocks located on 

numerous farms. According to company officials, protecting the 

 50Making influenza vaccine using egg-based technology—typically used to produce both 

seasonal and pandemic influenza vaccines for the U.S. market—involves growing virus 

cultures in fertilized chicken eggs.

Federal Agencies Face 

Other Issues Associated 

with Mitigating the 

Potential Harmful Effects 

of Avian Influenza

Poultry Used to Produce 

Critical Human Vaccine Are 

Susceptible to Influenza 

Outbreaks
Page 39 GAO-17-360 Avian Influenza

company’s current network of egg suppliers is critical because the 

company cannot rely on other suppliers for eggs if its own network is 

compromised; the officials told us the company would not be able to 

make vaccine with eggs raised outside its control.

According to HHS officials, the agency recognizes that avian influenza 

poses a risk to the production of pandemic influenza vaccines. To 

address that risk, HHS has contracted with the company to protect the 

egg supply chain and ensure a year-round supply of vaccine-quality 

fertilized eggs for the company to use in its vaccine manufacturing 

process. HHS awarded the current 3-year, $42 million contract for a yearround supply of eggs in September 2014. The contract requires that the 

company have a risk management plan; the company’s plan contains 

both a physical security program and a biosecurity program to provide 

protection against man-made and natural threats.

HHS officials said they are confident that the company’s biosecurity 

program is sound. According to company representatives, the company 

mitigates risks by limiting the density of the birds on each farm and by 

using farms that are not in close proximity. In addition, company 

employees routinely audit the flocks and incubation facilities, and the 

company periodically tests the flocks of layer hens for avian influenza 

using USDA’s National Poultry Improvement Plan testing procedures. 

Furthermore, according to HHS officials, the agency conducts annual 

security audits of a portion of the facilities in the company’s network.

According to company representatives, the company has standard 

operating procedures for biosecurity in its network of egg suppliers that 

are based on state department of agriculture guidelines. Company 

representatives said that because the company contracts with its 

suppliers and can require specific conditions, it has more control over 

what is done on the farms and in the incubation facilities than it does with 

farms that only comply with either USDA or state agriculture department 

requirements. While the 2014 and 2016 outbreaks did not affect this egg 

supply, a previous outbreak of highly pathogenic avian influenza caused 

the deaths of laying hens and reduced the supply of eggs used to 

produce human vaccines by about 50 percent.

HHS has sought to diversify vaccine production through technologies that 

are not egg-based. Specifically, HHS has promoted technologies known 
Page 40 GAO-17-360 Avian Influenza

as cell-based and recombinant technologies to produce vaccine.51

According to agency officials, these technologies will help offset the risk 

avian influenza poses to vaccine production. We have reported 

separately on federal efforts to diversify the pandemic vaccine supply.52

According to HHS’s website, three Centers for Innovation in Advanced 

Development and Manufacturing—in Maryland, North Carolina, and 

Texas—will provide a significant domestic infrastructure in the United 

States capable of producing medical countermeasures to protect 

Americans from the health impacts of bioterrorism as well as pandemic 

influenza and other diseases.53 However, the centers are not yet able to 

manufacture the contracted quantity of pandemic influenza vaccine. 

According to HHS’s Office of the Assistant Secretary for Preparedness 

and Response, as of February 2017, it was yet to be determined when 

the three CIADMs would be fully operational, but contractor officials 

indicated that one of the three is expected to become fully operational in 

2017.

 51Cell-based technology uses cells other than eggs, such as those originally derived from 

the kidney cells of monkeys or canines, infected with influenza virus for the production of 

the vaccine. Recombinant technology uses specific protein(s) or genes from the influenza 

virus instead of the entire virus as the antigen for the vaccine. This technology can use 

cells from mammals as the medium for producing the influenza vaccine as well as cells 

from other sources, such as from bacteria, yeast, insects, or plants. For more information 

on cell-based and recombinant technologies, see GAO, Influenza Vaccine: Federal 

Investments in Alternative Technologies and Challenges to Development and Licensure, 

GAO-11-435 (Washington, D.C.: June 27, 2011).

52GAO, National Preparedness: HHS Has Funded Flexible Manufacturing Activities for 

Medical Countermeasures, but It Is Too Soon to Assess Their Effect, GAO-14-329 

(Washington, D.C.: Mar. 31, 2014). 

53According to HHS’s website (https://www.medicalcountermeasures.gov/barda/coreservices/ciadm.aspx), these centers also address concerns raised by the President's 

Council of Advisors on Science and Technology in the August 2010 Report to the 

President on Reengineering the Influenza Vaccine Production Enterprise to Meet the 

Challenges of Pandemic Influenza, which called for flexible, nimble, and modern vaccine 

manufacturing technologies. Among the findings of the President’s Council was that 

“current influenza vaccines are prepared from materials grown in chicken eggs, a 

cumbersome method that appears outmoded in a world dominated by production of many 

viral vaccines in cell culture or by new vaccines designed with recombinant DNA 

methods.” However, the council’s report did not comment on the threat that avian 

influenza could pose to the egg supply. 
Page 41 GAO-17-360 Avian Influenza

USDA and HHS have collaborated to monitor swine for influenza A 

viruses because swine may act as a “mixing vessel” in which influenza

viruses recombine to pose new threats to human health. However, the 

agencies face the issue that funding for a voluntary surveillance program 

will be exhausted in fiscal year 2017. According to HHS officials, this 

surveillance program is the only federal source of data for understanding 

the types of influenza circulating in swine. Because influenza is endemic 

in swine worldwide, swine producers are not required to report the 

disease to USDA, and USDA is not required to report swine influenza to 

the World Organisation for Animal Health. However, since 2009, when 

H1N1 swine-origin influenza caused a global human pandemic, USDA 

has used funding from HHS to collect voluntary data from the U.S. swine 

industry on the incidence of swine influenza.54 As we reported in May 

2013, there are limitations in the reliability of the data collected by this 

voluntary program; in particular, it may not accurately represent all of the 

conditions circulating across the country.55 Nevertheless, this program 

has provided useful data on the presence of various subtypes of influenza 

virus in swine herds, according to HHS and USDA officials. Moreover, 

representatives from the pork industry we interviewed stated the 

surveillance data are beneficial to both public and animal health. 

However, according to USDA officials, funding for the swine surveillance 

program is expected to be fully expended in fiscal year 2017. USDA 

officials said that the agency will once again seek additional funding for 

the program in fiscal year 2018 and beyond, through appropriated 

funding, but that funding beyond fiscal year 2017 is uncertain. In addition, 

the U.S. Animal Health Association provided support for the program’s 

continuation through a 2016 resolution asking Congress to appropriate 

funding for the swine surveillance program; furthermore, according to its 

representative, the National Pork Producers Council has advocated for 

continued funding for the program. According to HHS officials, the agency 

will continue to be supportive of USDA’s efforts to continue the program. 

It is too early to say whether USDA will continue to gather data on 

influenza in swine beyond fiscal year 2017.

 54According to a USDA document, HHS transferred $25.75 million to APHIS to support the 

surveillance program.

55For more information, see GAO, Homeland Security: An Overall Strategy Is Needed to 

Strengthen Disease Surveillance in Livestock and Poultry, GAO-13-424 (Washington, 

D.C.: May 21, 2013).

Funding for a Federal Effort to 

Monitor Swine for Influenza 

That Could Threaten Human 

Health Will Run Out in Fiscal 

Year 2017
Page 42 GAO-17-360 Avian Influenza

The federal government has taken important steps to mitigate the 

significant risks posed by avian influenza to the health of humans, 

animals, and the economy. However, experience in the United States and 

around the world has shown that it is challenging to protect domesticated 

poultry from infection and control the disease when it does strike. USDA 

proactively identified numerous lessons learned, across a wide range of 

response areas, from the 2014 and 2016 outbreaks of avian influenza, 

and it identified more than 300 associated corrective actions. USDA has 

marked as completed about 70 percent of these actions, but it does not 

have plans for evaluating the extent to which its completed corrective 

actions have effectively helped to resolve the problems the agency 

identified in its responses to the 2014 and 2016 outbreaks. By developing 

a plan for evaluating completed corrective actions and, as part of this 

plan, considering whether any completed corrective actions require 

validation through simulations or exercises, USDA could better assess 

the effectiveness of these actions. This is particularly important in light of 

new outbreaks among commercial poultry in 2017 that continue to 

challenge the nation’s efforts to control this devastating disease.

We recommend that the Secretary of Agriculture direct the Administrator 

of the Animal and Plant Health Inspection Service to develop a plan for 

evaluating completed corrective actions to determine their effectiveness 

and, as appropriate, consider whether any completed corrective actions 

require validation through simulations or exercises.

We provided a draft of this report to USDA, HHS, and Interior for review 

and comment. USDA provided written comments on the draft, which are 

presented in appendix III, and provided technical comments, which we 

incorporated as appropriate. USDA agreed with our recommendation. 

HHS and Interior did not provide written comments but provided technical 

comments, which we incorporated as appropriate.

In its written comments, USDA said that APHIS agreed with our 

recommendation to develop a plan for evaluating completed corrective 

actions to determine their effectiveness. Further, USDA said that APHIS 

will incorporate simulations and exercises in its plan and that, in the event 

of an actual outbreak, APHIS will evaluate the effectiveness of the 

response through an after action report. Finally, USDA said that APHIS 

will continually review the criteria and hierarchy of corrective actions, both 

completed and ongoing, with respect to avian influenza policies, 

Conclusions

Recommendation for 

Executive Action

Agency Comments
Page 43 GAO-17-360 Avian Influenza

emergency management activities, and critical communications with 

states, tribes, poultry producers, and poultry industry partners. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of Agriculture, the Secretary of 

Health and Human Services, the Secretary of the Interior, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.

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

contact me at (202) 512-3841 or morriss@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 key contributions to this 

report are listed in appendix IV.

Steve D. Morris

Director, Natural Resources and Environment
Appendix I: Selected Agencies with 

Responsibilities Related to Avian Influenza

Page 44 GAO-17-360 Avian Influenza

Numerous federal agencies have responsibilities related to reducing the 

risks posed by avian influenza to human health, animal health, and the 

economy. Table 7 provides a summary of those responsibilities for 

agencies within the U.S. Department of Agriculture, the Department of 

Health and Human Services, and the Department of the Interior.

Table 7: Selected Agencies with Responsibilities Related to Avian Influenza and Its Effects on Human and Animal Health

Department Component agency Summary of relevant responsibilities

U.S. Department of 

Agriculture (USDA)

Animal and Plant Health 

Inspection Service (APHIS) 

Supports USDA’s overall mission, including protecting and promoting U.S. 

agricultural health.

Within APHIS, Veterinary Services protects and improves the health, quality, 

and marketability of our nation’s animals and animal products by preventing, 

controlling, and eliminating animal diseases, and by monitoring and 

promoting animal health and productivity.

Within Veterinary Services,Surveillance, Preparedness and Response

Services focuses on animal health needs and carries out functions ranging 

from early awareness and surveillance to the development and field 

implementation of animal health programs and emergency response; 

National Import Export Services conducts import and export activities, from 

policy setting to inspection at ports of entry; and Science, Technology and 

Analysis Services brings together the following science centers to support 

Veterinary Services in meeting its mission responsibilities:

• The Center for Epidemiology and Animal Health explores and 

analyzes animal health and related agricultural issues to facilitate 

informed decision making in government and industry. The group also 

partners with the World Organisation for Animal Health to improve 

international disease surveillance and analytic methods supporting trade 

decisions.a

• The Center for Veterinary Biologics ensures that veterinary biologics—

products of biological origin such as vaccines and diagnostic kits—for the 

diagnosis, prevention, and treatment of animal diseases maintain purity 

and potency and are safe and effective.

• National Veterinary Services Laboratories ensures that timely and 

accurate laboratory support is provided by their nationwide animal health 

diagnostic system by providing diagnostic services, reagents, and 

training in world-class facilities, among other things.

The National Animal Health Laboratory Network is organized under the 

National Veterinary Services Laboratories. It is a multifaceted network 

composed of sets of laboratories that focus on different diseases, using 

common testing methods and software platforms to process diagnostic 

requests and share information. It is a cooperative effort between two USDA 

agencies—APHIS and the National Institute of Food and Agriculture—and the 

American Association of Veterinary Laboratory Diagnosticians.

Wildlife Services, through its operational program and the National Wildlife 

Research Center, employs veterinarians, biologists, and epidemiologists to 

research and mitigate damage caused by wildlife to public health and safety, 

agriculture, and natural resources, including diseases in wildlife.

Appendix I: Selected Agencies with 

Responsibilities Related to Avian Influenza
Appendix I: Selected Agencies with 

Responsibilities Related to Avian Influenza

Page 45 GAO-17-360 Avian Influenza

Department Component agency Summary of relevant responsibilities

Agricultural Research 

Service

Veterinarians and scientists in the Agricultural Research Service do research 

to support diagnostic testing, vaccines, disease management systems, and 

farm biosecurity measures, among other tools, to help national efforts to 

detect, control, and eradicate animal diseases of national priority.

Economic Research Service Conducts a research program to inform public and private decision making on 

economic and policy issues involving food, farming, natural resources, and 

rural development.

National Institute of Food 

and Agriculture

Advances knowledge of agriculture, the environment, human health and wellbeing, and communities by supporting research, education, and extension 

programs in the Land-Grant University System and other organizations.

Department of Health 

and Human Services 

(HHS)

Office of the Assistant 

Secretary for Preparedness 

and Response 

Within the Office of the Assistant Secretary for Preparedness and Response, 

the Biomedical Advanced Research and Development Authority—

established by the Pandemic and All-Hazards Preparedness Actb

—

coordinates advanced research and development, manufacturing, and initial 

procurement of medical countermeasures for chemical, biological, 

radiological, and nuclear threats, pandemic influenza, and emerging 

infectious diseases into the Strategic National Stockpile, which is the national 

repository for medications, medical supplies, and equipment for use in a 

public health emergency. As part of these responsibilities, the Authority 

oversees HHS’s efforts to develop flexible manufacturing capabilities for 

medical countermeasures to respond to public health emergencies.

Centers for Disease Control 

and Prevention (CDC)

CDC develops strategies for conducting surveillance of diseases in humans, 

including collaborating with USDA and other agencies to monitor zoonotic 

diseases. CDC conducts laboratory studies of influenza viruses with 

pandemic potential to assess their potential risks to humans and to inform 

pre-pandemic vaccine stockpile decision making.

The Influenza Division of the CDC National Center for Immunization and 

Respiratory Diseases conducts surveillance of influenza in humans, 

including human infections of influenza of animal origin. Researchers use 

surveillance information to monitor influenza trends and improve rapid 

reporting and identification of novel influenzas of animal origin to which 

humans might not have immunity.

Researchers also use surveillance to guide the development of diagnostic 

tests and vaccines.

Food and Drug 

Administration (FDA)

FDA is responsible for protecting the public health by ensuring the safety and 

efficacy of veterinary drugs and medical devices and by licensing biological 

products that are safe, pure, and potent, including vaccines for pandemic 

influenza. In addition, FDA is responsible for ensuring the safety and proper 

labeling of more than 80 percent of the U.S. food supply. FDA’s role includes 

assessing emerging infectious disease threats that may require FDA to take 

action. FDA works with industry partners and other stakeholders to speed the 

development, availability, and timely access to critical medical products, e.g., 

increasing vaccine production if a particularly virulent strain of influenza 

begins to spread.
Appendix I: Selected Agencies with 

Responsibilities Related to Avian Influenza

Page 46 GAO-17-360 Avian Influenza

Department Component agency Summary of relevant responsibilities

Department of the 

Interior

United States Fish and 

Wildlife Service

The Fish and Wildlife Service assists with collecting samples for testing birds 

and hunter-captured animals in its refuges. The Fish and Wildlife Service 

works with other federal and state agencies to monitor bird populations for the 

earliest possible detection of the avian influenza virus if it enters this country.

United States Geological 

Survey

Interior coordinates the federal government’s surveillance of wild migratory 

birds for the presence of highly pathogenic avian influenza virus, coordinates 

federal surveillance with related surveillance activities of state fish and wildlife 

agencies, and provides leadership and support in the area of wildlife disease 

research and diagnostics to federal and state natural resource agencies. 

Interior’s U.S. Geological Survey maintains the National Wildlife Health 

Center, which identifies, controls, and prevents wildlife losses from diseases 

as well as conducts research to understand the impact of diseases on wildlife 

populations; the center also devises methods to more effectively manage 

these disease threats. The National Wildlife Health Center works with 

department bureaus, as well as state, tribal, and other federal entities, on 

wildlife disease investigations, providing the best available science and 

technical support for issues related to wildlife health and disease.

Source: GAO, Interior, HHS, and USDA documents.| GAO-17-360

a

The World Organisation for Animal Health, of w hich the United States is a member, is an 

intergovernmental organization responsible for improving animal health w orldwide. It requires its 180 

member countries to report certain diseases to the organization and other member countries.

b

Pub. L. No. 109-417 § 401(c), 120 Stat. 2831, 2865 (codified as amended at 42 U.S.C. § 247d7e(c)).
Appendix II: Results of Surveillance of Wild 

Birds for Avian Influenza, December 2014 

through March 2017

Page 47 GAO-17-360 Avian Influenza

In response to the outbreak of highly pathogenic avian influenza in 

December 2014, personnel from the U.S. Department of Agriculture 

(USDA) and the Department of the Interior re-convened the Interagency 

Wild Bird Avian Influenza Steering Committee in January 2015.1 The 

steering committee developed a wild bird surveillance plan for avian 

influenzas that may pose a threat to human health or domestic poultry.2

The plan encourages federal and state agencies and others to use a 

variety of sampling methods to test live and dead wild birds to detect both 

low pathogenic and highly pathogenic avian influenza. According to data 

recorded as of March 24, 2017, the surveillance program had collected 

test results from more than 88,000 wild birds since December 2014. The 

number of monthly highly pathogenic avian influenza detections was 

highest during the period from December 2014 through June 2015 before 

declining during the period from July 2015 through March 24, 2017, 

despite an increase in testing over this period of time. In total, the 

program detected highly pathogenic avian influenza in 102 birds, or 0.12 

percent of those tested. (See table 8 for a summary of the monitoring 

data.) The surveillance program also detected low pathogenic influenza A 

virus in some wild birds; program data show that the percentage of wild 

duck samples that tested positive for low pathogenic influenza A virus in 

each month ranged from about 7 percent to about 30 percent in 2015 and 

2016 (data not shown in table 8).3 The state veterinarians we interviewed 

from six states (California, Indiana, Iowa, Minnesota, North Carolina, and 

Ohio) generally agreed with the need for wildlife surveillance. At the same 

time, while monitoring can serve as an early warning system to alert 

poultry owners and public health agencies, among others, of the 

presence of influenza A viruses in wild birds, it cannot eliminate wild birds 

as potential sources of the virus.

 1According to its charter, the Interagency Wild Bird Avian Influenza Steering Committee is 

comprised of representatives from the USDA Animal and Plant Health Inspection Service; 

the U.S. Geological Survey; the U.S. Fish and Wildlife Service; the Centers for Disease 

Control and Prevention; the Association of Fish and Wildlife Agencies; the National Flyway 

Council; and other agencies or organizations, as mutually determined by the membership. 

2Early Detection and Monitoring for Avian Influenzas of Significance in Wild Birds: A U.S. 

Interagency Strategic Plan, Interagency Wild Bird Avian Influenza Steering Committee 

(June 2015).

3Detections of Type A low pathogenic avian influenza virus include a range of subtypes. 

Detections of H5 and H7 subtypes, which are reportable to the World Organisation for 

Animal Health, in wild ducks have ranged from less than 1 percent to about 4 percent per 

month.

Appendix II: Results of Surveillance of Wild 

Birds for Avian Influenza, December 2014 

through March 2017
Appendix II: Results of Surveillance of Wild 

Birds for Avian Influenza, December 2014 

through March 2017

Page 48 GAO-17-360 Avian Influenza

Table 8: Detections of Highly Pathogenic Avian Influenza in Wild Birds in the United States from December 2014 to March 

2017

Period of testing (by year and month) Total positive cases

Subtypes detected and number of cases

(EA = Eurasian; AM=North American)

December 2014 19 • EA/AM H5N2 (9)

• EA H5N8 (9)

• EA/AM H5N1 (1)

January 2015 55 • EA/HM H5N2 (17)

• EA H5N8 (14)

• EA/AM H5N1 (2)

• EA H5 (22)

February 2015 1 • EA H5 (1)

March 2015 7 • EA/HM H5N2 (6)

• EA H5 (1)

April 2015 2 • EA/AM H5N2 (2)

May 2015 1 • EA H5 (1) 

June 2015 13 • EA/AM H5N2 (5)

• EA H5 (8)

July 2015 1 • EA H5 (1)

August 2015 0 N/A

September 2015 0 N/A

October 2015 0 N/A

November 2015 1 • EA H5 (1)

December 2015 0 N/A

January 2016 0 N/A

February 2016 0 N/A

March 2016 0 N/A

April 2016 0 N/A

May 2016 0 N/A

June 2016 0 N/A

July 2016 0 N/A

August 2016 1 • EA/AM H5N2 (1)

September 2016 0 N/A

October 2016 0 N/A

November 2016 0 N/A

December 2016 1 • EA/AM H5N2 (1)

January 2017 0 N/A
Appendix II: Results of Surveillance of Wild 

Birds for Avian Influenza, December 2014 

through March 2017

Page 49 GAO-17-360 Avian Influenza

Period of testing (by year and month) Total positive cases

Subtypes detected and number of cases

(EA = Eurasian; AM=North American)

February 2017 0 N/A

March 2017 0 N/A

TOTAL BIRDS SAMPLED: 88,167 102

Source: GAO analysis of National Wild Bird Avian Influenza Surveillance Program data. | GAO-17-360

Notes: Data are through March 24, 2017. Avian H5 influenza (H5N8) originating from Eurasia spread 

rapidly along w ild bird migratory pathw ays during 2014. Introduction of this virus into the Pacific 

Flyw ay sometime during 2014 has allow ed mixing w ith North American-origin viruses and generated 

new (novel) combinations w ith genes of both Eurasian and North American origin (or “reassortant” 

viruses). In some cases, testing did not identify the specific subtype of avian influenza. N/A = “not 

applicable” because no detections w ere made that month.
Appendix III: Comments from the U.S. 

Department of Agriculture

Page 50 GAO-17-360 Avian Influenza

Appendix III: Comments from the U.S. 

Department of Agriculture
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 51 GAO-17-360 Avian Influenza

Steve D. Morris, (202) 512-3841 or Morriss@gao.gov

In addition to the individual named above, Mary Denigan-Macauley 

(Assistant Director), Kevin Bray, Ross Campbell, Barbara El Osta, Kevin 

R. Fish, Katherine Killebrew, Erik Kjeldgaard, Cynthia Norris, and Amber 

Sinclair made key contributions to this report. Ashley Grant, Sara 

Sullivan, Kiki Theodoropoulos, and Rajneesh Kumar Verma also made 

important contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

acknowledgments
Related GAO Products

Page 52 GAO-17-360 Avian Influenza

Biodefense: The Nation Faces Multiple Challenges in Building and 

Maintaining Biodefense and Biosurveillance. GAO-16-547T. Washington, 

D.C: April 14, 2016.

Emerging Animal Diseases: Actions Needed to Better Position USDA to 

Address Future Risks. GAO-16-132. Washington, D.C.: December 15, 

2015.

Biosurveillance: Challenges and Options for the National Biosurveillance 

Integration Center. GAO-15-793. Washington, D.C: September 24, 2015.

National Preparedness: HHS Has Funded Flexible Manufacturing 

Activities for Medical Countermeasures, but It Is Too Soon to Assess 

Their Effect. GAO-14-329. Washington, D.C.: March 31, 2014.

National Preparedness: HHS is Monitoring the Progress of Its Medical 

Countermeasure Efforts but Has Not Provided Previously Recommended 

Spending Estimates. GAO-14-90. Washington, D.C.: December 27, 2013.

Homeland Security: An Overall Strategy Is Needed to Strengthen Disease 

Surveillance in Livestock and Poultry. GAO-13-424. Washington, D.C.: 

May 21, 2013.

Influenza: Progress Made in Responding to Seasonal and Pandemic 

Outbreaks. GAO-13-374T. Washington, D.C.: February 13, 2013.

National Preparedness: Improvements Needed for Acquiring Medical 

Countermeasures to Threats from Terrorism and Other Sources. 

GAO-12-121. Washington, D.C.: October 26, 2011.

Influenza Pandemic: Lessons from the H1N1 Pandemic Should Be 

Incorporated into Future Planning. GAO-11-632. Washington, D.C.: June 

27, 2011.

Influenza Vaccine: Federal Investments in Alternative Technologies and 

Challenges to Development and Licensure. GAO-11-435. Washington, 

D.C.: June 27, 2011.

National Preparedness: DHS and HHS Can Further Strengthen 

Coordination for Chemical, Biological, Radiological, and Nuclear Risk 

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Page 53 GAO-17-360 Avian Influenza

Public Health Preparedness: Developing and Acquiring Medical 

Countermeasures Against Chemical, Biological, Radiological, and 

Nuclear Agents. GAO-11-567T. Washington, D.C.: April 13, 2011.

Influenza Pandemic: Monitoring and Assessing the Status of the National 

Pandemic Implementation Plan Needs Improvement. GAO-10-73. 

Washington, D.C.: November 24, 2009.

Influenza Pandemic: Sustaining Focus on the Nation’s Planning and 

Preparedness Efforts. GAO-09-334. Washington, D.C.: February 26, 

2009.

Avian Influenza: USDA Has Taken Important Steps to Prepare for 

Outbreaks, but Better Planning Could Improve Response. GAO-07-652. 

Washington, D.C.: June 11, 2007.

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