a

GAO

United States Government Accountability Office

Report to Congressional Committees

June 2007 AVIAN INFLUENZA

USDA Has Taken 

Important Steps to 

Prepare for Outbreaks, 

but Better Planning 

Could Improve 

Response

GAO-07-652
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2007

AVIAN INFLUENZA

USDA Has Taken Important Steps to 

Prepare for Outbreaks, but Better 

Planning Could Improve Response 

Highlights of GAO-07-652, a report to 

congressional committees 

A highly pathogenic strain of avian 

influenza (AI) has spread to nearly

60 countries over the past few 

years, killing millions of birds and 

more than 170 humans. Controlling 

the virus in poultry is key to

reducing the risk of a human 

pandemic. The Department of 

Agriculture (USDA) is responsible 

for planning for AI outbreaks in 

poultry, with states’ assistance. The 

Department of Homeland Security

(DHS) is responsible for

coordinating the federal response 

for certain emergencies and 

developing policy documents that

serve as a basis for national

emergency planning. GAO

described the steps USDA is taking

to prepare for highly pathogenic AI

and identified key challenges. GAO 

reviewed response plans, statutes, 

and regulations; visited poultry

operations; interviewed federal, 

state, and industry officials in five

states that experienced outbreaks;

and reviewed 19 state plans.

What GAO Recommends

GAO recommends that USDA and

DHS develop a memorandum of

understanding to clarify their roles 

during certain emergencies, and 

USDA should take several steps to 

improve its planning and that of the 

states. USDA agreed with all

recommendations except for the 

use of a memorandum of

understanding to clarify roles. DHS 

agreed further clarification of roles

is needed. 

USDA is taking important steps to prepare for highly pathogenic AI. For 

example, the department has established mechanisms to prevent infected 

poultry (see photo) and products from being imported and has developed 

several surveillance programs to detect AI. In addition, USDA is developing 

response plans specific to highly pathogenic AI and has begun conducting 

exercises to test these plans. Moreover, USDA is building a National 

Veterinary Stockpile to maintain critical supplies, including equipment to 

protect responders. Finally, USDA has launched various AI research 

projects, including one to explore why the virus causes disease and death in 

some domestic poultry and wild birds but not in others. 

While USDA has made important strides, incomplete planning at the federal 

and state levels, as well as several unresolved issues, could slow response. 

First, USDA is not planning for the lead coordinating role that DHS would 

assume if an outbreak among poultry occurred that is sufficient in scope to 

warrant various federal disaster declarations. GAO’s prior work has shown 

that roles and responsibilities must be clearly defined and understood to 

facilitate rapid and effective decision making. Moreover, USDA response 

plans do not identify the capabilities needed to carry out the critical tasks 

associated with an outbreak scenario—that is, the entities responsible for 

carrying them out, the resources needed, and the provider of those 

resources. Furthermore, some state plans lack important components that 

could facilitate rapid AI containment, which is problematic because states

typically lead initial response efforts. Finally, there are several unresolved 

issues that, absent advance consideration, could hinder response. For 

example, controlling an outbreak among birds raised in backyards, such as 

for hobby, remains particularly difficult because federal and state officials 

generally do not know the numbers and locations of these birds. In addition, 

USDA has not estimated the amount of antiviral medication that it would 

need during an outbreak or resolved how to provide such supplies in a 

timely manner. According to federal guidance, poultry workers responding 

to an outbreak of highly pathogenic AI should take antiviral medication to 

protect them from infection. 

A Chicken Infected with Avian Influenza 

Source: USDA.

www.gao.gov/cgi-bin/getrpt?GAO-07-652.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Daniel Bertoni 

at (202) 512-3841 or bertonid@gao.gov. 
Page i GAO-07-652 Avian Influenza

Contents

Letter 1

Results in Brief 4

Background 6

USDA Is Implementing Important Measures to Help the Nation 

Prepare for Outbreaks of Highly Pathogenic Avian Influenza 16

Federal and State Response Plans Are Incomplete, and Several 

Issues Are Unresolved 25

Conclusions 41

Recommendations for Executive Action 42

Agency Comments and Our Evaluation 43

Appendixes

Appendix I: Scope and Methodology 46

Appendix II: Comments from the Department of Agriculture 48

GAO Comments 53

Appendix III: Comments from the Department of Homeland Security 54

Appendix IV: GAO Contact and Staff Acknowledgments 55

Tables Table 1: States That Have Experienced Outbreaks of Avian 

Influenza in Commercial Poultry Since 2002 11

Table 2: Gaps Identified in State Plans 29

Figures Figure 1: Common Types of Commercial Poultry Operations 8

Figure 2: Percentages of Poultry Types Produced in the United 

States, 2005 8

Figure 3: Value of Poultry Products in the United States, 2005 9

Figure 4: How Disease Spreads Among Commercial Poultry 10

Figure 5: Identifying Capabilities Needed for Highly Pathogenic 

AI 27

Figure 6: Methods of Poultry Disposal 36
Contents

Page ii GAO-07-652 Avian Influenza

Abbreviations

AI avian influenza

APHIS Animal and Plant Health Inspection Service

DHS Department of Homeland Security

USDA Department of Agriculture

HHS Department of Health and Human Services

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-07-652 Avian Influenza

United States Government Accountability Office

Washington, D.C. 20548

A

June 11, 2007 Letr

Congressional Committees:

A highly pathogenic strain of H5N1 avian influenza has, over the past few 

years, spread to nearly 60 countries, resulting in the death and destruction 

of millions of wild and domestic birds throughout Asia, Europe, Africa, and 

the Middle East. Serious concerns exist that it could reach North America 

at any time via migrating birds or smuggled imports of diseased birds and 

bird products. Although primarily an avian disease, this virus has also 

infected 291 humans—most of whom had close contact with infected 

poultry—and more than half of them have died.1

 Health experts are 

concerned that should highly pathogenic H5N1 (or another subtype), to 

which humans have no immunity, develop the capacity to spread easily 

from person to person, a pandemic could occur. According to the World 

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

reduce opportunities for human infection and, therefore, reduce 

opportunities for a pandemic to emerge. 

Avian influenza (AI) 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. Most AI viruses are low pathogenic and 

usually result in mild or asymptomatic infections in birds. In the United 

States, these viruses are common in wild waterfowl and shorebirds. Highly 

pathogenic AI viruses are associated with high morbidity and mortality in 

poultry and are considered foreign animal diseases because they rarely 

occur in the United States. Despite the relative mildness of low pathogenic 

AI, some of these strains are worrisome because they have the potential to 

mutate into highly pathogenic AI. This happened most recently in 2004 in 

British Columbia, Canada, resulting in the death of 17 million birds.

The Department of Agriculture (USDA) is responsible for acting to prevent, 

control, and eradicate foreign animal diseases in domestic livestock and 

poultry, in coordination with a number of other entities. For example, 

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. If humans become infected, the 

Department of Health and Human Services (HHS) leads the federal medical 

1

These numbers are based on statistics reported by the World Health Organization as of 

April 11, 2007.
Page 2 GAO-07-652 Avian Influenza

response. In the event of an outbreak serious enough for the President to 

declare an emergency2 or major disaster3 or for the Secretary of Homeland 

Security to declare an Incident of National Significance,4 the Secretary of 

Homeland Security assumes responsibility for coordinating the federal 

response. In addition, the Department of Homeland Security (DHS) has 

been charged with developing policy documents that provide the 

foundation for emergency planning for all levels of government. 

A well-planned, coordinated emergency response is essential when dealing 

with highly pathogenic AI in order to mitigate financial losses to the $28 

billion U.S. poultry industry. The United States is the world’s largest 

producer and second largest exporter of poultry meat, accounting for 

nearly 35 percent of global trade valued at more than $2 billion annually. 

Once certain strains of low pathogenic AI or any strain of highly pathogenic 

AI are found in domestic poultry in the United States, trading partners are 

notified, and exports of poultry and poultry products from within the 

affected area are halted. To control the spread of the disease and to 

ultimately resume trade, USDA, often with assistance from states and the 

poultry industry, typically destroys—depopulates—exposed and infected 

birds, including those raised in commercial operations and in backyards.5

2

The Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288, 88 

Stat. 143 (1974) (codified as amended at 42 U.S.C. §§ 5121 et seq.), defines an emergency as 

“any occasion or instance for which, in the determination of the President, Federal 

assistance is needed to supplement State and local efforts and capabilities to save lives and 

to protect property and public health and safety, or to lessen or avert the threat of a 

catastrophe in any part of the United States.” 42 U.S.C. §5122(1).

3

The Stafford Act defines a major disaster as “any natural catastrophe (including any 

hurricane, tornado, storm, high water, winddriven water, tidal wave, tsunami, earthquake, 

volcanic eruption, landslide, mudslide, snowstorm or drought), or, regardless of cause, any 

fire, flood, or explosion, in any part of the United States, which in the determination of the 

President causes damage of sufficient severity and magnitude to warrant major disaster 

assistance under [the Act] to supplement the efforts and available resources of States, local 

governments, and disaster relief organizations in alleviating the damage, loss, hardship, or 

suffering caused thereby.” 42 U.S.C. §5122(2).

4

According to the National Response Plan, an Incident of National Significance is “an actual 

or potential high-impact event that requires a coordinated and effective response by an 

appropriate combination of Federal, State, local, tribal, nongovernmental, and/or privatesector entities in order to save lives and minimize damage, and provide the basis for longterm community recovery and mitigation activities.” 

5

Backyard birds are those raised, for example, for cockfighting or personal consumption. 
Page 3 GAO-07-652 Avian Influenza

USDA provides compensation to owners—indemnifies them—for losses 

incurred when USDA depopulates birds.6

USDA has had some experience working with states and the poultry 

industry to eradicate highly pathogenic AI. For example, USDA worked 

with Pennsylvania to control an outbreak of highly pathogenic AI in 1983, 

leading to the depopulation of 17 million birds. However, the agency has 

never confronted the challenge of an AI strain with the unique 

characteristics of highly pathogenic H5N1: the unprecedented speed with 

which it has spread, its human health implications, and the extensive 

scrutiny it has received as a result of coverage in the world media. 

Moreover, the possibility exists that terrorists could introduce highly 

pathogenic AI at multiple locations, instilling fear in the public about the 

safety of the food supply and disrupting the economy. 

Given the intense global concern about highly pathogenic AI, we (1) 

described the steps USDA has taken to prepare for highly pathogenic AI in 

domestic poultry and (2) identified any challenges that could affect USDA’s 

ability to prepare for highly pathogenic AI. A list of congressional 

committees that requested this report appears on the last page of this letter.

To describe the steps USDA has taken to prepare for outbreaks of highly 

pathogenic AI in domestic poultry, we reviewed presidential directives and 

national emergency planning documents, relevant statutes and regulations, 

and USDA documents and programs related to AI. To identify any 

challenges that could affect USDA’s ability to prepare for outbreaks of 

highly pathogenic AI, we conducted structured interviews with federal, 

state, and industry officials in California, Delaware, Maryland, Texas, and 

Virginia. We selected these states because they have experience responding 

to an outbreak of AI or another highly infectious avian disease in the past 5 

years and because of their varying poultry demographics. We also 

interviewed USDA emergency management and industry officials, 

including those personnel specifically charged with helping states develop 

AI response plans, to identify strengths and weaknesses in state plans and 

to characterize their state’s level of readiness for an outbreak. In addition, 

we performed our own review and assessment of 19 state plans to 

corroborate identified strengths and weaknesses from the interviews. 

Furthermore, we attended a USDA and state AI training exercise and 

6

In addition, USDA may, under certain circumstances, indemnify owners when states and 

industry depopulate birds.
Page 4 GAO-07-652 Avian Influenza

visited live bird markets and numerous types of poultry operations. Finally, 

we interviewed DHS officials to discuss emergency planning and DHS’ role 

in outbreaks of AI. Additional details about our scope and methodology are 

presented in appendix I. We conducted our review between May 2006 and 

June 2007 in accordance with generally accepted government auditing 

standards.

Results in Brief USDA is taking many important measures to help the nation prepare for 

outbreaks of highly pathogenic AI. For example, USDA has put 

mechanisms in place to prevent the importation of poultry and poultry 

products contaminated with highly pathogenic AI. It also has developed 

several surveillance programs to detect AI, including a long-standing 

voluntary program that systematically tests samples of birds from 

participating poultry operators’ flocks for the virus. In addition, USDA is 

developing response plans specific to highly pathogenic AI, and the 

department has begun preliminary exercises with other federal agencies, 

states, and industry to test preparedness. Moreover, USDA has begun 

creating a National Veterinary Stockpile containing, among other things, 

personal protective equipment such as goggles and respirators to protect 

responders against foreign animal diseases. Furthermore, USDA recently 

expanded its indemnification regulations and has developed 

communication strategies to inform the public and instill confidence that 

USDA is taking steps to quickly address any potential AI outbreak. Finally, 

USDA has critical AI research under way. For example, it is conducting 

experiments to better understand how the virus causes disease and death 

in some domestic poultry and wild birds but not in others.

While USDA has made important strides, incomplete planning at the 

federal and state levels, as well as several unresolved issues, could slow 

response and delay recovery from an outbreak. First, USDA is not planning 

for DHS to assume the lead coordinating role if an outbreak among poultry 

occurs that is sufficient in scope to warrant a presidential declaration of an 

emergency or major disaster, or a DHS declaration of an Incident of 

National Significance. USDA officials told us that DHS involvement would 

likely be unnecessary unless there are multiple outbreaks, an agroterrorism 

event is suspected, or the virus causes a human pandemic. Moreover, in the 

view of USDA officials, it is not clear that a presidential declaration of an 

emergency or major disaster would even apply to a highly pathogenic AI 

outbreak. However, the decision to involve DHS is not USDA’s to make. It is 

the President who declares an emergency or major disaster when he 

determines that an outbreak is sufficient in scope to warrant federal 
Page 5 GAO-07-652 Avian Influenza

assistance. Furthermore, DHS officials told us that it is possible that an 

Incident of National Significance would be declared by the Secretary of 

Homeland Security depending on the severity, magnitude, or complexity of 

the outbreak. In the event of a presidential declaration of an emergency or 

major disaster, or a declaration of an Incident of National Significance, the 

Secretary of Homeland Security assumes responsibility for directing the 

federal response. DHS officials told us they should be involved in planning 

for such an event. Our prior work has shown that roles and responsibilities 

for those responding to major incidents must be clearly defined and 

understood to facilitate rapid and effective decision making. Because this 

DHS/USDA coordination is absent from USDA planning, the federal 

response may be slowed as these agencies resolve their roles and 

responsibilities following the onset of a significant outbreak. Second, 

USDA response plans do not identify the capabilities needed to carry out 

the tasks associated with an outbreak scenario—that is, the entities 

responsible for carrying them out, the resources needed, and the source of 

those resources. Planning of this nature is essential for an effective 

emergency response. 

Furthermore, 14 of 19 state plans that we reviewed lack important 

components that could facilitate rapid containment of the virus. For 

example, some lack time frames for accomplishing response activities that 

would enable the states to determine the extent to which they were being 

successful in controlling the outbreak. USDA and state officials told us that 

state-level plans are incomplete for several reasons, including the lack of 

established federal criteria for what a response plan for highly pathogenic 

AI should include. In the absence of such criteria, USDA and state officials 

we interviewed told us they are relying, among other things, on experience 

from previous outbreaks. These planning gaps are particularly problematic 

because states typically lead initial response efforts, when rapid action is 

essential to limiting the spread of disease. 

Finally, several unresolved issues could affect response. For example, 

federal and state officials generally do not know the numbers and locations 

of backyard birds so controlling an outbreak among these birds remains 

particularly difficult. A recent California outbreak of exotic Newcastle 

disease—a highly infectious foreign animal disease in birds—illustrates 

this point. This virus originated in backyard flocks in California and spread 

to two neighboring states. Controlling the disease was impeded because 

responders had to go door-to-door to locate potentially infected birds. A 

second issue is that the disposal of carcasses and materials infected with AI 

may be more problematic than in the past. State officials told us that in 
Page 6 GAO-07-652 Avian Influenza

light of highly pathogenic H5N1, operators of landfills have become 

reluctant to accept materials infected with even low pathogenic AI because 

of the perceived human health risk. Furthermore, USDA has not estimated 

the amount of antiviral medication that it would need in the event of an 

outbreak or resolved how to provide such supplies within the first 24 hours 

of an outbreak. According to federal guidance, workers responding to an 

outbreak of highly pathogenic AI should take antiviral medication daily at 

the site of an outbreak and each day for 7 days after leaving the site to 

protect them from infection. 

To increase the likelihood that an outbreak of highly pathogenic AI is 

rapidly contained so efforts can focus on recovery, we are making several 

recommendations. For example, we are recommending that the Secretaries 

of Agriculture and Homeland Security develop a memorandum of 

understanding that describes how USDA and DHS will work together in the 

event of a declared presidential emergency or major disaster, or an Incident 

of National Significance, and test the effectiveness of this coordination 

during exercises. In addition, we are recommending that the Secretary of 

Agriculture identify and test the capabilities necessary to respond to a 

probable outbreak scenario(s); develop standard criteria for the 

components of state response plans; focus additional work with states on 

how to overcome potential problems associated with unresolved issues; 

and address concerns about antiviral medication. 

In commenting on a draft of this report, USDA agreed with all but one of 

our recommendations. USDA stated that it does not believe a 

memorandum of understanding is the best vehicle for clarifying and 

defining the roles of USDA and DHS in the event of a declared presidential 

emergency or major disaster, or an Incident of National Significance. 

Nevertheless, USDA accepted the need to clarify the roles during such an 

event and further supported the need to test this coordination in formal 

exercises. DHS agreed that USDA and DHS roles need further clarification 

and suggested that a concept of operation plan could be used to define this 

relationship. DHS further supported the need to test this coordination 

through exercises. 

Background In November 2005, the President of the United States released the 

Homeland Security Council’s National Strategy for Pandemic Influenza to 

guide the country’s overall effort to address the threat that highly 

pathogenic AI could create a human pandemic influenza. The strategy 

identified four lead agencies, each responsible for developing a plan to 
Page 7 GAO-07-652 Avian Influenza

implement a component of the strategy: USDA is responsible for the 

veterinary response, HHS is responsible for the medical response, the 

Department of State is responsible for international activities, and DHS is 

responsible for overall domestic incident management and federal 

coordination. In May 2006, the Implementation Plan for the National 

Strategy for Pandemic Influenza was issued to describe how the strategy 

would be implemented. Specifically, this implementation plan describes 

more than 300 critical actions that the appropriate federal agencies must 

carry out to address the threat of pandemic influenza. The department has 

responsibility for nearly 100 of these critical actions.7

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 facility. The most common 

types of poultry raised commercially are chickens for consumption (called 

broilers) and chickens that lay eggs (called layers), as well as turkeys (see 

fig. 1). Broilers represent 93 percent of poultry produced in the United 

States (see fig. 2) and almost three-quarters of poultry and poultry products 

by value sold to consumers (see fig. 3). There are also commercial birds 

that are genetic breeding stock whose main function is to produce 

offspring that facilitate mass production and are economical to raise. 

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 highly 

pathogenic AI, hundreds of thousands of birds can be exposed and need to 

be depopulated. 

7

According to USDA, the department is responsible for leading 57 of these critical actions 

and supporting 41 more. 
Page 8 GAO-07-652 Avian Influenza

Figure 1: Common Types of Commercial Poultry Operations

Figure 2: Percentages of Poultry Types Produced in the United States, 2005

Source: GAO.

Broilers Turkeys Layers

3% 

Turkeys

4% 

Layers

93%

Broilers

Source: GAO presentation of USDA data.
Page 9 GAO-07-652 Avian Influenza

Figure 3: Value of Poultry Products in the United States, 2005

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

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

are typically chickens used for personal egg production and consumption; 

game fowl used for fighting; and game birds, such as quail and pheasant. 

These birds may run loose or be confined to a poultry house. In addition, 

there are birds in live bird markets—facilities that sell live poultry, which is 

often slaughtered on-site, to the general public—and some are sold at 

auctions and swap meets. 

When poultry become infected with AI, it may be spread by the movement 

of contaminated people and equipment to and from a site where the 

infected birds are located (see fig. 4). For example, a poultry worker enters 

one bird house containing birds infected with AI but does not disinfect 

boots or change clothing before entering another house, carrying the virus 

and causing the disease to spread. As a precaution, commercial producers 

often implement biosecurity measures. For example, the number of people 

entering a bird house is restricted, and these people must dress in special, 

sometimes disposable, clothing. Moreover, vehicles arriving at a farm are 

usually required to be disinfected upon entry and exit. The workers’ boots 

and hands are also disinfected. For highly valuable birds, such as genetic 

$3.2 billion

Turkeys

$4 billion

Eggs

74%

Source: GAO presentation of USDA data.

$21 billion

Broilers

14%

12% 
Page 10 GAO-07-652 Avian Influenza

breeding stock, biosecurity may be higher—for example, visitors may be 

required to shower before entering and leaving the facility. 

Figure 4: How Disease Spreads Among Commercial Poultry

Chickens Live Grocery

Livestock and

Bird Market

Farm 1

Farm 4

Farm 2

Farm 3

Poultry equipment

• Filler flats

• Hauling crates/coops

• Feeder, waterers

People

• Boots

• Clothing

• Handling

Vehicle/equipment

• Manure spreader

• Tractor

• Trucks

• Front end loader

Bird-to-bird

• Carcasses

• Manure

• Litter/debris

• Feathers

Vehicles

Source: USDA and GAO.
Page 11 GAO-07-652 Avian Influenza

Despite biosecurity measures, outbreaks among commercial poultry have 

recently occurred (see table 1). For example, in 2002, Virginia experienced 

an outbreak of low pathogenic AI that resulted in the depopulation of 

nearly 5 million birds in order to control the disease.8

 In 2003, Connecticut 

had an outbreak of low pathogenic AI that affected more than 3 million 

commercial laying hens.9

 While low pathogenic AI is detected from time to 

time in domestic poultry, highly pathogenic AI is known to have occurred 

only three times in the United States: in 1924, 1983, and 2004. It is believed 

that all three of these highly pathogenic outbreaks originated in live bird 

markets. The Pennsylvania outbreak in 1983 began as a low pathogenic AI 

virus but mutated into a highly pathogenic strain, leading to the 

depopulation of 17 million birds. Although diagnostic testing confirmed 

that a virus in Texas in 2004 was technically highly pathogenic, the virus did 

not cause high mortality in the infected birds, as would be typical with 

highly pathogenic AI. 

Table 1: States That Have Experienced Outbreaks of Avian Influenza in Commercial Poultry Since 2002

Source: GAO. 

a

On March 31, 2007, USDA confirmed the presence of an H5N2 AI virus in turkeys located on a farm in 

West Virginia. USDA reported that this virus is consistent with low pathogenic strains of AI. The turkeys 

showed no signs of illness, and there was no mortality. USDA plans to run sequencing and 

pathogenicity tests to further identify the virus.

8

Poultry in North Carolina and West Virginia were also affected.

9

In this instance, vaccines were used in conjunction with depopulation to control the 

outbreak. 

State Avian disease

Year of 

outbreak Origin

Number/type of birds 

depopulated

Time taken to 

eradicate

Virginia/North 

Carolina/West Virginia

Low pathogenic AI 2002 Unconfirmed; live bird 

market suspected

4.7 million birds 4 months

Connecticut Low pathogenic AI 2003 Unconfirmed; wildfowl 

suspected

100,000 laying hens; 

millions more 

vaccinated

Over 1 year

Delaware/Maryland Low pathogenic AI 2004 Live bird market More than 400,000 

commercial broilers

2 months

Texas Highly pathogenic AI 2004 Live bird market 6,600 commercial 

broilers 

Less than 2 

months

West Virginiaa Low pathogenic AI 

suspected 

2007 Unknown at this time 25,000 turkeys 

(unconfirmed)

Unknown at this 

time
Page 12 GAO-07-652 Avian Influenza

An outbreak of AI can have serious trade repercussions. The World 

Organization for Animal Health is an international animal health group 

with 167 member countries, including the United States. Members agree to 

notify the organization of outbreaks in domestic poultry of all highly 

pathogenic AI and some low pathogenic strains—those with H5 and H7 

proteins—because they have the capacity to mutate into highly pathogenic 

AI.10 Consequently, when a country’s poultry tests positive for “notifiable” 

AI, its international trading partners are likely to restrict trade with that 

country until the partners believe the virus is eradicated—an outcome that 

can take many months to achieve. For example, when a single farm in 

Texas was infected with highly pathogenic AI in 2004, more than 50 

countries instituted complete or partial bans on U.S. poultry; Mexico has 

yet to lift its ban. Therefore, when a flock is infected with AI, the goal 

becomes controlling and eradicating the disease as rapidly as possible in 

order to prevent the spread of the disease and to regain the confidence of 

U.S. trading partners that any future imports will be disease free. This is 

accomplished by acting 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 disease is 

eradicated, USDA, states, and the poultry industry continue to test birds to 

monitor for AI. 

USDA derives its authority to carry out operations and measures to 

prevent, detect, control, and eradicate AI from the Animal Health 

Protection Act.11 The act authorizes the Secretary of Agriculture to hold, 

seize, treat, destroy, or dispose of any animal, vehicle, or object that can 

harbor the disease, or to restrict their movement in interstate commerce. 

The act also authorizes the Secretary to transfer 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 addition, the act authorizes the Secretary to declare 

an “extraordinary emergency” when it has been determined that a state’s 

actions are inadequate to control or eradicate a livestock disease that 

threatens domestic livestock. Under this declaration, the Secretary’s 

10The World Organization for Animal Health defines notifiable AI as an infection of poultry 

caused by any influenza A virus of the H5 or H7 subtypes or by any AI virus with an 

intravenous pathogenicity index greater than 1.2, or with at least 75 percent mortality. 

117 U.S.C. §§ 8301-8321.

Biosecurity Measures on the Farm

Source: GAO.

To prevent the introduction of highly pathogenic AI 

into flocks, USDA recommends that poultry 

producers strengthen biosecurity practices. For 

example: 

• Protect poultry flocks from coming into contact 

with wild or migratory birds and any source of water 

that may have been contaminated by wild birds.

• Permit only essential workers and vehicles to 

enter the farm.

• Thoroughly clean and disinfect equipment and 

vehicles entering and leaving the farm.

• Do not loan equipment or vehicles to, or borrow 

from, other farms.

• Avoid visiting other poultry farms. If you do visit 

another farm or live bird market, change footwear 

and clothing before working with your own flock.

• Do not bring birds from slaughter channels, 

especially live bird markets, back to the farm.

Source: GAO.
Page 13 GAO-07-652 Avian Influenza

authority to regulate includes any animal, vehicle, or object that can harbor 

the disease in intrastate, as well as interstate commerce. 

Within USDA, a number of agencies have responsibility for protecting U.S. 

poultry from AI. The Animal and Plant Health Inspection Service (APHIS) 

operates the National Veterinary Services Laboratories, the only laboratory 

in the United States recognized by the World Organization for Animal 

Health to perform confirmatory testing for AI. Also, APHIS’ Smuggling, 

Interdiction, and Trade Compliance unit conducts activities to prevent 

smuggled and prohibited agricultural goods from entering and being 

distributed throughout the country. In addition, the Agricultural Research 

Service conducts research on endemic and exotic poultry diseases, 

including highly pathogenic AI; the Food Safety and Inspection Service 

works to ensure that the nation's commercial supply of meat, poultry, and 

egg products is safe for human consumption; the Office of 

Communications coordinates public information from USDA program 

agencies.

In the past few years, USDA’s total obligations for AI preparedness efforts 

have increased from approximately $3.2 million in fiscal year 2004 to $74.1 

million in fiscal year 2006. In 2005, USDA received $91.35 million from the 

2-year Emergency Supplemental Appropriation to Address Pandemic 

Influenza.12 The bulk of USDA’s supplemental funding ($80.3 million) was 

allocated to APHIS, which in turn obligated $43 million for AI surveillance 

of domestic wildlife, commercial poultry, and live bird markets in fiscal 

year 2006.13 In addition, USDA obligated portions of the remaining 

emergency supplemental funding to areas such as AI research and public 

communications. According to USDA officials, the department is 

requesting $82 million for fiscal year 2008 to support its ongoing AI 

programs. 

While USDA has for many years been responsible for protecting livestock 

and poultry from foreign animal diseases, it now does so under new 

authorities and has additional roles and responsibilities. Following the 

terrorist attacks of 2001, the Congress passed the Homeland Security Act of 

12Pub. L. No. 109-148, div. B, tit. II, 119 Stat. 2782 (2005).

13The $80.3 million allocated to APHIS consisted of $71.5 million from the 2-year emergency 

supplemental and, according to USDA officials, $8.8 million from supplemental funds 

appropriated to the Office of the Secretary. 
Page 14 GAO-07-652 Avian Influenza

2002,14 establishing DHS as the chief coordinating agency for efforts to 

protect the United States from terrorist acts and disasters, including those 

that affect the agriculture sector. As such, DHS undertook major policy 

initiatives to promote emergency preparedness, including developing the 

National Incident Management System, the National Response Plan, and 

the National Preparedness Goal. 

The National Incident Management System is intended to provide a 

consistent framework for incident management at all jurisdictional levels 

regardless of cause, size, or complexity of the situation and to define the 

roles and responsibilities of federal, state, and local governments during an 

emergency event. A key component of this system is the Incident 

Command System, designed to coordinate the communications, personnel, 

and procedures of different agencies and levels of government within a 

common organizational structure during an emergency. 

The National Response Plan is an all-hazards plan built on the template of 

the National Incident Management System. It established a single, 

comprehensive approach to domestic incident management to prevent, 

prepare for, respond to, and recover from terrorist attacks, major disasters, 

and other emergencies. The National Response Plan is stated to always be 

in effect. Under the National Response Plan, resources are grouped into 

Emergency Support Functions that would most likely be needed during a 

domestic incident. Under Emergency Support Function #11, which 

addresses the protection of agriculture, APHIS is responsible for 

implementing an integrated federal, state, tribal, and local response to an 

outbreak of a highly contagious or economically devastating animal 

disease, such as highly pathogenic AI. A fundamental principle of the 

National Response Plan is that incidents are first handled at the lowest 

possible level of government. If an incident overwhelms local and state 

capabilities, a state may request resources from other states through 

mutual aid agreements, or may request federal assistance. The Robert T. 

Stafford Disaster Relief and Emergency Assistance Act 15 established the 

process for states to request supplemental resources from the federal 

government when state and local resources have been or will be 

overwhelmed. The President invokes a federal response under the Stafford 

Act by declaring an “emergency” or a “major disaster.”

14Homeland Security Act of 2002, Pub. L. No. 107-296, 116 Stat. 2135.

15Pub. L. No. 93-288, 88 Stat. 143 (1974) (codified as amended at 42 U.S.C. §§ 5121 et seq.).
Page 15 GAO-07-652 Avian Influenza

Homeland Security Presidential Directive 8 required the Secretary of 

Homeland Security to coordinate the development of a national domestic 

all-hazards preparedness goal to establish measurable readiness priorities 

and targets that appropriately balance the potential threat and magnitude 

of terrorist attacks and major disasters with the resources required to 

prevent, respond to, and recover from them. The goal was to include 

standards for preparedness assessments and strategies and a system for 

assessing the nation’s overall preparedness to respond to major events. To 

implement this directive, DHS developed the National Preparedness Goal 

using 15 emergency event scenarios16 whose purpose was to form the basis 

for identifying the capabilities needed to respond to a wide range of 

emergency events.17 One of the defined scenarios was an outbreak of a 

foreign animal disease.

Finally, Homeland Security Presidential Directive 9 established a national 

policy to defend the agriculture and food system against terrorist attacks, 

major disasters, and other emergencies. Specifically, it directs the 

Secretary of Agriculture, in coordination with the Secretary of Homeland 

Security, and in consultation with the Secretary of Health and Human 

Services and the Administrator of the Environmental Protection Agency,18

to work with state and local governments and the private sector to develop 

a National Veterinary Stockpile containing sufficient amounts of animal 

vaccine, antiviral, or therapeutic products to appropriately respond to the 

most damaging animal diseases affecting human health and the economy 

within 24 hours of an outbreak. 

16The 15 scenarios are (1) improvised nuclear device attack, (2) aerosol anthrax attack, (3) 

pandemic influenza, (4) biological attack with plague, (5) chemical attack with blister agent, 

(6) chemical attack with toxic chemical agent, (7) chemical attack with nerve agent, (8) 

chemical attack resulting in chlorine tank explosion, (9) major earthquake, (10) major 

hurricane, (11) radiological attack with dispersal device, (12) improvised explosive device 

attack, (13) biological attack with food contamination, (14) biological attack with foreign 

animal disease, and (15) cyber attack.

17Capabilities—the ability to carry out specific tasks under particular conditions with 

desired results—are built upon the appropriate combination of people, skills, processes, 

and assets.

18The mission of the Environmental Protection Agency is to protect human health and the 

environment.
Page 16 GAO-07-652 Avian Influenza

USDA Is Implementing 

Important Measures to 

Help the Nation 

Prepare for Outbreaks 

of Highly Pathogenic 

Avian Influenza

USDA has taken important steps to prepare for highly pathogenic AI. For 

example, the department has put mechanisms in place to prevent the 

importation of infected poultry and poultry products. In addition, it has 

developed several surveillance programs to detect AI. Moreover, in the 

event outbreaks do occur, USDA is developing written response plans and 

has begun preliminary exercises to test aspects of these plans with federal, 

state, local, and industry partners. USDA has also begun creating a National 

Veterinary Stockpile to augment state and local resources during 

outbreaks. Finally, the department has recently expanded its 

indemnification coverage for AI, developed public service messages to 

provide accurate information during outbreaks, and has undertaken critical 

AI research.

Import and Smuggling 

Control 

Trade in live poultry and its products and the smuggling of birds and bird 

products have played a large role in the spread of highly pathogenic 

H5N1.19 To counteract these threats, USDA has mechanisms in place to 

prevent the importation of infected poultry and poultry products. For 

example, APHIS maintains trade restrictions on the importation of poultry 

and its products originating from regions where highly pathogenic AI has 

been detected. APHIS also requires that all live birds imported into the 

United States, with the exception of those from Canada, spend 30 days at a 

USDA quarantine facility where they are tested for AI. If found positive for 

the virus, the bird is destroyed. 

In addition, APHIS’ Smuggling, Interdiction, and Trade Compliance unit has 

increased its monitoring for smuggled poultry and products through an 

antismuggling program in coordination with DHS.20 Specifically, during 

fiscal year 2006 and the first 2 months of 2007, it conducted a total of 54 

special AI operations. For example, at the Port of Los Angeles/Long Beach, 

this unit conducted an operation that targeted poultry and associated 

products that were being brought into the United States for the Asian New 

19Report of the Second FAO/OIE Regional Meeting on Avian Influenza Control in Asia, in 

collaboration with: Government of Viet Nam (Ministry of Agriculture and Rural 

Development) and World Health Organization, February 23-25, 2005. 

20Coordination with DHS is necessary because the Homeland Security Act of 2002, Pub. L. 

No. 107-296, 116 Stat. 2135, transferred most of USDA’s responsibility for conducting 

agricultural import inspections to DHS. (See GAO, Homeland Security: Much Is Being 

Done to Protect Agriculture from a Terrorist Attack, but Important Challenges Remain,

GAO-05-214 (Washington D.C.: Mar. 8, 2005).
Page 17 GAO-07-652 Avian Influenza

Year, when Asian imports typically increase. A total of 15 cargo inspections 

were conducted, and 4,324 kilograms of prohibited poultry products 

(including products from China and Japan, which were experiencing 

outbreaks of highly pathogenic H5N1 at the time of this report) were 

discovered. USDA has recently hired more than 20 field officers and eight 

analysts that specialize in AI to enhance surveillance and target potential AI 

shipments. Furthermore, in the spring of 2007, USDA officials told us that it 

will launch a national public awareness campaign to raise awareness 

among importers, distributors, wholesalers, and other key stakeholders 

about the threat of AI in smuggled poultry.
Page 18 GAO-07-652 Avian Influenza

Surveillance USDA has several surveillance programs intended to rapidly detect and 

prevent the spread of AI. These programs augment USDA’s veterinary 

infrastructure—an infrastructure that provides the foundation for USDA 

foreign animal disease monitoring. For example, APHIS’ long-standing 

voluntary program, the National Poultry Improvement Plan, tests 

participating commercial poultry flocks to ensure they are free from 

diseases, including AI. If flocks test negative for AI, USDA provides 

certification that the flock is free of the disease,21 thereby assisting with 

interstate and international trade, which provides an incentive for 

commercial industry participation. Forty-eight states participate in this 

program. In addition, APHIS’ Biosecurity for the Birds program 

encourages, among other things,22 surveillance of backyard birds. APHIS 

works closely with state departments of agriculture, USDA’s Cooperative 

Extension Service, and private veterinarians to make information available 

to backyard bird owners on the risks and signs of disease and good 

biosecurity practices. While this program does not include a testing 

component, APHIS offers the public a toll-free number to notify authorities 

when backyard birds become sick and die. USDA is also expanding its 

surveillance programs as required in the Implementation Plan for the 

National Strategy for Pandemic Influenza. For example, among other 

efforts, APHIS is working with the Department of the Interior,23 state 

wildlife agencies, and others to increase surveillance of wild birds in 

Alaska and the 48 continental states. Moreover, USDA is working with 

states and industry to conduct surveillance of birds at auctions, swap 

meets, flea markets, and public exhibitions. Furthermore, in 2002, USDA 

established the National Animal Health Laboratory Network as part of a 

national strategy to coordinate and link the testing capacities of the federal 

veterinary diagnostic laboratories with the extensive infrastructure of state 

and university capabilities. This network now includes 51 approved 

Highly Pathogenic AI Clinical Signs

Source: USDA’s APHIS.

Highly pathogenic AI is an extremely infectious and 

fatal form of the disease for chickens. The virus can 

strike poultry quickly without any infection warning 

signs. Once established, the disease can spread 

rapidly from flock to flock. Clinical signs include 

sudden death; lack of energy and appetite; 

decreased egg production; soft–shelled or 

misshapen eggs; swelling of the head, eyelids, 

comb, wattles, and hocks; purple discoloration of 

the wattles, combs, and legs; nasal discharge; 

coughing and sneezing; lack of coordination; and 

diarrhea.

Source: USDA’s APHIS.

21The certification USDA provides indicates that breeder flocks are “AI clean” and that 

production flocks are “AI monitored.”

22For example, this educational program also encourages good biosecurity practices among 

backyard bird owners. 

23The Department of Interior is responsible for managing healthy wildlife populations.
Page 19 GAO-07-652 Avian Influenza

laboratories that partner to conduct enhanced AI surveillance efforts.24

Finally, APHIS recently formed the National Avian Influenza Surveillance 

System, designed to link existing AI surveillance data from USDA, other 

federal and state agencies, and industry. 

Response Plans APHIS is currently drafting response plans for highly pathogenic AI.25 For 

example, its draft Summary of the National Highly Pathogenic Avian 

Influenza Response Plan describes the activities that are necessary to 

respond to an outbreak.26 In addition, USDA is working with the White 

House Homeland Security Council and other key federal agencies to 

produce an “interagency playbook”27 intended to clarify how primary 

federal responders would initially interact to respond to six scenarios: 

detection of highly pathogenic H5N1 (1) in wild birds, (2) in a commercial 

poultry flock, (3) in multiple commercial poultry flocks within the United 

States, (4) in a live bird market, (5) along a contiguous border, and (6) 

involving a single case of poultry-to-human infection. According to the 

interagency playbook, although USDA is the federal department primarily 

responsible for controlling the disease in poultry (or other livestock), it 

would work with other federal partners. For example, HHS would ensure 

that systems were in place to detect and monitor infection in humans. In 

addition, the Environmental Protection Agency would provide expertise on 

disinfecting and disposing of materials; the Department of Labor,28 in 

24For more information on the National Animal Health Laboratory Network, see GAO, 

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

but Important Challenges Remain, GAO-05-214 (Washington D.C.: Mar. 8, 2005).

25According to USDA, these draft AI documents have undergone intense development and 

would be used as a basis for activities that the department would undertake in the event of 

an outbreak of highly pathogenic AI.

26This plan summarizes APHIS’ National Highly Pathogenic Avian Influenza Preparedness 

and Response Plan, which the agency describes as a strategic plan for rapidly detecting and 

responding to highly pathogenic AI. The summary and the original plan are based on APHIS’ 

National Animal Health Emergency Management System, which provides guidance on 

mitigating, preparing for, responding to, and recovering from major animal health 

emergencies. Among other things, the system contains guidance for responding to highly 

contagious foreign animal diseases and uses foot-and-mouth disease as its example.

27The playbook is entitled the Interagency Playbook for Domestic Response to a Detection 

of Highly Pathogenic Avian Influenza H5N1 in Birds.

28Within the Department of Labor, the Occupational Safety and Health Administration 

assures the safety and health of America’s employees. 
Page 20 GAO-07-652 Avian Influenza

conjunction with HHS, would provide guidance on how to protect workers, 

including the use of personal protective equipment; and DHS would 

monitor outbreak and intelligence information to determine if an outbreak 

was bioterrorism-related. 

Exercising Response Plans USDA has begun conducting preliminary tabletop exercises29 on aspects of 

response plans with other federal agencies, as well as states and private 

industry, to gain a greater understanding of preparedness for highly 

pathogenic AI. For example, APHIS conducted tabletop exercises with two 

large poultry producing states to help identify the type and level of personal 

protective equipment necessary to respond to an outbreak. Industry 

officials were also present at these exercises, since the selected scenarios 

identified outbreaks in commercial operations in both states. In addition, 

USDA’s Food Safety Inspection Service conducted five tabletop exercises 

with state and local public health and emergency response officials to test 

the operability and efficacy of its response procedures against deliberate 

contamination of the food supply, as well as against an AI outbreak. 

Moreover, the Food Safety Inspection Service and APHIS conducted a joint 

tabletop exercise that simulated an outbreak of highly pathogenic H5N1 in 

commercial poultry, backyard flocks, live bird markets, and wild bird 

populations. Other participants included officials from DHS and HHS; 

officials from four states; representatives from the National Association of 

County and City Health Officials,30 the National Association of State 

Departments of Agriculture,31 and the Association of State and Territorial 

Health Officials32; representatives of consumer groups and industry 

officials; and representatives from the Canadian Food Inspection Agency. 

29A tabletop exercise is a group discussion guided by a scenario-based, simulated disaster. 

30The National Association of County and City Health Officials is the national organization 

representing local health departments. 

31The National Association of State Departments of Agriculture’s mission is to represent the 

state departments of agriculture in the development, implementation, and communication 

of sound public policy and programs that support and promote the American agricultural 

industry, while protecting consumers and the environment.

32The Association of State and Territorial Health Officials is a national nonprofit 

organization representing the state and territorial public health agencies of the United 

States, the U.S. territories, and the District of Columbia. 
Page 21 GAO-07-652 Avian Influenza

Moving forward, APHIS is contracting with the Center for Naval Analysis to 

develop and implement up to 60 additional tabletop exercises of state 

response plans in the coming year. Once these exercises are conducted, the 

agency intends to analyze the outcomes and identify areas that need further 

improvement. 

National Veterinary 

Stockpile

In coordination with DHS and others, APHIS has begun creating a National 

Veterinary Stockpile. This stockpile is intended to be the nation's 

repository of animal vaccines, personal protective equipment, and other 

critical veterinary products to respond to the most dangerous foreign 

animal diseases. The National Veterinary Stockpile’s goal is to acquire 

countermeasures against the 10 animal diseases that pose the greatest 

threat, including highly pathogenic AI, within 5 years, and against an 

additional 7 of these diseases within 10 years.33 To accomplish this task, 

National Veterinary Stockpile officials have begun building an 

infrastructure to identify, acquire, store, maintain, manage, and deploy this 

critical inventory within 24 hours of a foreign animal disease outbreak, as 

required by the directive.34 The stockpile currently owns material sufficient 

to produce 140 million doses35 of H5 and H7 AI vaccine to protect older 

birds.36 According to USDA officials, the current inventory also includes 31 

“push packs”—that is, ready-to-ship containers stocked with a variety of 

personal protective equipment and veterinary supplies, such as 

disinfectants; protective clothing (e.g., respirators, face masks, and 

protective body suits); and ancillary supplies (e.g., decontamination fluid 

for responders to clean their boots). Each push pack contains enough 

33The 17 critical animal diseases were selected based on the following factors: whether or 

not the disease-causing organism is highly contagious; the extent of its ability to rapidly 

spread and infect many species; the extent of its ability to cause disease in humans; and its 

economic impact both domestically and on trade. 

34Homeland Security Presidential Directive 9, at § 18.

35This exceeds the target in the Implementation Plan for the National Strategy for 

Pandemic Influenza.

36Stockpile officials evaluated the feasibility of acquiring ready-to-use vaccine(s); costs of 

purchasing them; and other life-cycle costs, such as storage, expiration, replacement, and 

disposal. As a result, the National Veterinary Stockpile has adopted a strategy of maintaining 

a limited supply of vaccine on hand but has purchased guaranteed access to larger amounts. 

For example, the stockpile also has access to 500 million doses of vaccine to protect 

younger chickens 1 to 7 days old. The stockpile has guaranteed access to 25 million doses 

within 24 hours, with the remainder to follow, if necessary.
Page 22 GAO-07-652 Avian Influenza

materials to support 10 outbreak responders for 10 days.37According to 

USDA officials, the National Veterinary Stockpile successfully tested its 

capability to deploy its critical inventory by sending push packs to West 

Virginia for the suspected low pathogenic AI outbreak that occurred in 

March of 2007. 

Indemnification USDA recently decided to provide compensation for losses incurred as a 

result of low pathogenic strains of H5 and H7 because of their potential to 

mutate to highly pathogenic AI. Indemnification is provided, in part, to 

encourage the early reporting of outbreaks and participation in response 

efforts. For many years, USDA provided compensation for losses incurred 

when birds were destroyed because of AI only when they were infected 

with or exposed to a highly pathogenic strain.38 Under the new indemnity 

regulations for H5/H7 low pathogenic AI, 39 large commercial poultry 

facilities must participate in USDA’s National Poultry Improvement Plan’s 

AI surveillance program,40 through a cooperating state agency, in order to 

be eligible to receive 100 percent indemnity for destroyed birds.41 Large 

commercial facilities that do not participate in the surveillance program 

37This acquisition of push packs was based, in part, on available funds, rather than a 

calculation based on outbreak scenarios. The National Veterinary Stockpile is in the process 

of acquiring additional personal protective equipment (enough to support 1,500 responders 

changing five times per day for 40 days). 

38Foot-and-Mouth Disease, Pleuropneumonia, Rinderpest, and Certain Other Communicable 

Diseases of Livestock or Poultry, 9 C.F.R. pt. 53. Indemnification has been provided under 

these regulations when the affected states had entered into cooperative agreements with 

USDA. Although these regulations do not generally provide indemnity for low pathogenic 

strains, on two occasions, USDA did so by amending the regulations. 

39For complete low pathogenic AI indemnity rules and regulations, see Low Pathogenic 

Avian Influenza; Voluntary Control Program and Payment of Indemnity, 71 Fed. Reg. 56,302 

(Sept. 26, 2006) (codified at 9 C.F.R. pt. 56).

40In addition, the states in which the facilities participate must conduct passive surveillance 

and have an initial state response and containment plan.

41For commercial poultry, a participating flock or slaughter plant is required to participate in 

the active surveillance program only if they are larger than a certain size standard. For tableegg layer flocks, the standard is 75,000 birds. For meat-type chicken slaughter plants, the 

standard is slaughtering 200,000 meat-type chickens in an operating week, while for meattype turkey slaughter plants, the standard is slaughtering 2 million meat-type turkeys in a 12-

month period. 
Page 23 GAO-07-652 Avian Influenza

may receive only 25 percent indemnity.42 These new regulations also 

explicitly allow greater flexibility than the regulations for highly pathogenic 

AI, which, for example, state that a USDA official must appraise the value 

of destroyed poultry.43 Under the new regulations, this requirement may be 

waived in order to expedite response to large outbreaks when USDA 

appraisers may be in short supply. Under these circumstances, USDA may 

allow USDA-authorized state appraisers, in addition to USDA appraisers, to 

conduct appraisals.44 In addition, USDA has included revised and very 

broad indemnity guidelines within its draft summary response plan to allow 

for a more flexible indemnification process during a highly pathogenic AI 

outbreak.

Communications USDA’s Office of Communications has developed risk communication 

messages about highly pathogenic AI.45 According to USDA officials, the 

goal of these messages is to provide accurate, timely, and consistent 

information during an outbreak; minimize public panic and fear; and instill 

public confidence in the government’s ability to respond to an outbreak. 

Specifically, USDA, in partnership with HHS, the Department of the 

Interior, and DHS, developed three scenarios for the detection of highly 

pathogenic AI in the United States: (1) a highly pathogenic AI detection in 

the United States other than H5N1, (2) highly pathogenic H5N1 in wild 

birds, and (3) highly pathogenic H5N1 in commercial poultry. Each of these 

scenarios contains a series of key questions and answers about animal 

health and guidance for the public, as well as a summary of the actions 

42Backyard birds are eligible for 100 percent indemnification without participating in the 

National Poultry Improvement Plan surveillance program because, according to USDA 

officials, participation would be too burdensome; it is more important that there be an 

incentive for these owners to report sick birds. 

439 C.F.R. § 53.3.

44Officials at USDA’s Office of General Counsel told us that the Secretary of Agriculture, 

under the authority of the Animal Health Protection Act, also retains this flexibility for 

indemnification procedures for highly pathogenic AI. Under the Animal Health Protection 

Act, the Secretary may authorize the destruction or disposal of certain animals he has 

reason to believe may carry, have carried, have been affected, or have been exposed to an 

animal disease. 7 U.S.C. § 8306(a), (b). The Secretary is further authorized to compensate 

the owner for any animals that he requires to be destroyed. 7 U.S.C. § 8306(d).

45These messages were created in response to the Implementation Plan for the National 

Strategy for Pandemic Influenza, which identified their development as a critical action 

item.
Page 24 GAO-07-652 Avian Influenza

USDA would take. USDA has placed these messages, as well as key fact 

sheets on its Web site for public viewing. The agency has also developed 

public service announcements for television and radio and, according to 

USDA, these messages have reached 175 markets and have been broadcast 

over 1,100 times. 

Research USDA is concentrating its AI research efforts on areas it considers critical 

to prepare for outbreaks of highly pathogenic AI.46 For example, the 

Agricultural Research Service is testing currently available poultry AI 

vaccines to determine if they are protective against highly pathogenic 

H5N1; developing new vaccines to protect against AI viruses that can be 

efficiently administered to large number of birds at once, such as through 

aerosol; enhancing diagnostic tools47 to allow for rapid testing of wild bird 

samples; sequencing the genomes—a complete set of hereditary factors—

of 1,000 AI viruses in order to better understand the epidemiology, or 

causes, of the diseases; and conducting experiments in birds to better 

understand how the virus causes disease and death in some domestic 

poultry and wild birds but not in others. 

In addition, the Agricultural Research Service is collaborating with several 

other federal agencies on AI research. For example, it worked with USDA’s 

Food Safety and Inspection Service to develop a test to determine the 

presence of highly pathogenic AI in poultry meat. It has also been working 

with the Environmental Protection Agency to research the ability of 

residual chlorine in drinking water to deactivate the highly pathogenic 

H5N1 virus. In addition, the Agricultural Research Service has been 

assisting HHS with the development of a vaccine for use during a human 

outbreak. 

USDA’s AI research efforts also focus on swine. For example, the 

Agricultural Research Service is supporting DHS in determining how highly 

pathogenic H5N1 viruses transmit to poultry and mammalian models. This 

is important because, although highly pathogenic H5N1 is predominantly a 

disease in poultry and wild birds, dogs, cats, and swine have also become 

46Many of these items are tasks identified in the Implementation Plan for the National 

Strategy of Pandemic Influenza.

47These are reverse transcription polymerase chain reaction diagnostic tests.
Page 25 GAO-07-652 Avian Influenza

infected.48 Swine are particularly worrisome because they can become 

infected with not only swine influenza viruses but also human and avian 

influenza viruses as well. The World Health Organization cautions that pigs 

could play a role in the potential emergence of a pandemic virus. 

Federal and State 

Response Plans Are 

Incomplete, and 

Several Issues Are 

Unresolved 

Despite actions taken by USDA, incomplete plans and unresolved issues 

could slow outbreak response. Currently, USDA is not planning for the lead 

coordinating role that DHS would assume in certain outbreak emergencies. 

In addition, USDA’s response plans do not identify the capabilities needed 

to carry out critical tasks for controlling highly pathogenic AI outbreaks. 

Furthermore, state plans are lacking key components for facilitating a 

rapid response. Finally, several unresolved issues could further delay 

response.

USDA Has Not Planned for 

DHS’ Lead Coordination 

Role 

USDA is not planning for DHS to assume the lead coordinating role if an 

outbreak among poultry occurs that warrants a presidential declaration of 

an emergency or major disaster, or a DHS declaration of an Incident of 

National Significance. USDA officials told us that DHS will not likely be 

needed to perform this coordinating role unless there are multiple 

outbreaks, an agroterrorism event is suspected, or the virus causes a 

human pandemic. However, USDA’s draft interagency playbook includes a 

scenario involving multiple outbreaks without addressing this DHS 

coordinating role. USDA officials also cite years of experience eradicating 

foreign animal diseases as the reason for not needing DHS involvement. 

Moreover, some officials told us that many within the agency are 

concerned that DHS officials at the operational level of response would not 

limit DHS involvement to that detailed in the National Response Plan but 

would instead take over the veterinary response as well. Our prior work49

has shown that roles and responsibilities at all levels of government must 

be clearly defined, effectively communicated, and well understood to 

facilitate rapid and effective decision making during an emergency. If this is 

48According to the Food and Agriculture Organization of the United Nations, all carnivores 

could become infected through eating infected poultry or infected wild birds.

49GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability 

Controls Will Improve the Effectiveness of the Nation’s Preparedness, Response, and 

Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006).
Page 26 GAO-07-652 Avian Influenza

not the case, problems such as those that plagued response during past 

disasters could result. 

Although USDA believes the need for DHS coordination is unlikely, the 

decision to involve DHS is not USDA’s to make. Specifically, a presidential 

declaration of an emergency or major disaster is made by the President of 

the United States at the request of state governors via the Stafford Act, and 

such declarations require the Secretary of Homeland Security to assume 

responsibility for directing the federal response. State officials told us that 

their governors would consider making such a request. For example, in 

2000, a presidential declaration of emergency was declared for the West 

Nile virus outbreak in New York state.50 DHS lawyers are in the process of 

determining the applicability of a declaration to an outbreak of highly 

pathogenic AI; therefore, this possibility should not be disregarded.

Moreover, the Secretary of Homeland Security has the discretion to declare 

an Incident of National Significance. The National Response Plan states 

that the Secretary of Homeland Security, in consultation with other 

departments and agencies, and the White House, as appropriate, may make 

such a declaration on the basis of criteria noted in Homeland Security 

Presidential Directive 5,51 including in the event of a presidential 

declaration under the Stafford Act. However, the Secretary is not limited to 

these criteria and may consider other factors when making this decision. 

The determining factor is whether the incident is of such severity, 

magnitude, or complexity that it requires the Secretary of Homeland 

Security to manage the federal response. DHS officials told us that if highly 

pathogenic H5N1 arrived in the United States, the Secretary of Homeland 

Security would, in consultation with the White House and cabinet 

members, consider declaring an Incident of National Significance if its 

50West Nile virus is usually spread by the bite of an infected mosquito. Mosquitoes become 

infected when they feed on infected birds. Infected mosquitoes can then spread the virus to 

humans and other animals. The presidential declaration of emergency declared for West 

Nile virus authorized funding so that local governments could be reimbursed for the cost of 

fighting the disease. 

51The criteria set out in Homeland Security Presidential Directive 5 are (1) a federal 

department or agency acting under its own authority has requested the assistance of the 

Secretary of Homeland Security; (2) the resources of state and local authorities are 

overwhelmed and federal assistance has been requested by the appropriate state and local 

authorities, for example, under the Stafford Act; (3) more than one federal department or 

agency has become substantially involved in responding to an incident; or (4) the Secretary 

of Homeland Security has been directed by the President to assume responsibility for 

managing a domestic incident. 
Page 27 GAO-07-652 Avian Influenza

impact warranted one. DHS officials further noted that the economic 

impact to the agriculture industry would be huge if the virus spread across 

multiple states, making it imperative to prevent this from happening. DHS 

officials told us that they hope that USDA will have the ability to contain 

the disease if an outbreak occurs. Nevertheless, DHS officials told us that 

this does not obviate the need to plan for such an event. Moreover, past 

experience has demonstrated that, despite USDA efforts, quickly 

controlling a disease has not always been possible. The exotic Newcastle 

disease outbreak that originated in California in 2002 is a case in point: it 

spread to two neighboring states over the course of a year despite vigorous 

USDA and state efforts.52

USDA Has Not Identified 

Response Capabilities for 

Highly Pathogenic AI 

DHS and state officials have expressed concern that USDA’s plans for 

highly pathogenic AI do not identify the capabilities needed to carry out the 

tasks associated with an outbreak scenario—that is, the entities 

responsible for carrying out the tasks, the specific resources needed, and 

the source of those resources (as described in fig. 5). Although USDA’s 

draft summary response plan identifies various tasks, such as mass 

depopulation, it does not address the capabilities needed to carry out the 

tasks under a particular scenario. 

Figure 5: Identifying Capabilities Needed for Highly Pathogenic AI

52This highly contagious and fatal poultry disease cost the states and federal government 

more than $170 million to eradicate, and it cost an unknown number of bird owners their 

livelihoods and, in some cases, their pets. 

Scenario Critical tasks Capabilities

Source: GAO.

Select a likely scenario 

for highly pathogenic AI, 

highlighting the scope, 

magnitude, and 

complexity of the 

outbreak.

Identify a list of critical 

tasks for preventing, 

protecting, responding to, 

and recovering from the 

scenario outbreak.

Identify the resources

necessary to carry out 

the critical tasks and who 

is responsible for 

developing and 

maintaining these 

resources.
Page 28 GAO-07-652 Avian Influenza

While we recognize that identifying capabilities is complex because it 

involves input from all responding entities and the capabilities required will 

change according to the outbreak scenario, it is important to provide a 

benchmark for planning purposes, particularly in the face of uncertainty. 

Moreover, Homeland Security Presidential Directive 8 calls for a national 

preparedness goal that uses capabilities-based planning. According to DHS, 

such planning helps determine how prepared we are as a nation, how 

prepared we need to be, and how to prioritize efforts to effectively respond 

to an emergency.53

In response to this directive, USDA has, with assistance from other federal 

agencies and entities, begun identifying capabilities in advance for an 

outbreak of foot-and-mouth disease. Although some of the capabilities 

associated with foot-and-mouth disease could translate to responding to an 

outbreak of highly pathogenic AI, there are differences between addressing 

disease outbreaks in livestock and in poultry. In addition, unlike foot-andmouth disease, highly pathogenic AI can infect humans, so capabilities 

must be identified in advance for protecting human health. USDA has also 

started planning for various scenarios with its draft interagency playbook. 

However, this playbook does not identify the capabilities for the various 

tasks, and it excludes key players, including state and industry officials. 

Moreover, USDA officials told us that the playbook was never intended to 

be shared with states. 

According to DHS officials, once capabilities are identified, they should be 

incorporated into a response plan that can be used to track progress. Such 

a plan—known as a concept of operation plan—is central to emergency 

management. The plan should list the critical tasks for responding to the 

selected outbreak scenario and, for each task, the responsible entities and 

the location of resources needed. In addition, the plan should specify time 

frames and completion status for each critical task. DHS officials told us 

that a plan of this nature is essential to identify gaps in capabilities. As we 

reported in 2006,54 emergency preparedness and response should be 

53On December 17, 2003, the President issued Homeland Security Presidential Directive 8 to 

establish policies to strengthen the preparedness of the United States to prevent and 

respond to threatened or actual domestic terrorist attacks, major disasters, and other 

emergencies by requiring national domestic all-hazards preparedness “Goal.” The Goal 

utilizes a capabilities-based planning approach.

54GAO, Emergency Preparedness and Response: Some Issues and Challenges Associated 

with Major Emergency Incidents, GAO-06-467T (Washington D.C.: Feb. 23, 2006).
Page 29 GAO-07-652 Avian Influenza

characterized by measurable goals and effective efforts to identify key gaps 

between those goals and current capabilities, with a clear plan for closing 

those gaps. However, a plan alone is not sufficient to ensure effective 

response. Conducting exercises is critical for developing skills and 

identifying what works well and what needs further improvement. 

Incomplete State Plans 

Could Slow Response 

USDA officials told us, and our own review corroborated, that some state 

plans for addressing outbreaks of highly pathogenic AI are lacking 

important components that could facilitate rapid containment of the virus 

(see table 2). Our review of 19 state plans55 found that 5 plans at least 

partially addressed all of the AI planning components that we identified as 

important in managing an AI outbreak. However, 14 plans did not address 

one or more critical planning components. The states reviewed account for 

51 percent of total U.S. poultry production and 7 of the top 10 poultry 

producing states.56

Table 2: Gaps Identified in State Plans

Source: GAO.

55USDA officials responsible for helping states develop response plans provided us with 19 

plans, which the states made available to them during the course of our review. 

56These numbers are based on USDA’s 2002 Census of Agriculture.

Planning component

Number of plans we reviewed 

that did not address component

Incident Command System 7 of 19

Time frames 4 of 19

Depopulation 4 of 19

Disposal 2 of 19

Response among backyard birds 3 of 19

Biosecurity 1 of 19

Public communications 4 of 19

Public health 5 of 19
Page 30 GAO-07-652 Avian Influenza

The following discussion details some of the gaps we identified: 

• Incident Command System. The Incident Command System is critical 

to ensure that responses to any type of incident are effectively managed, 

yet 7 of the 19 state plans we reviewed—including 3 of the top 10 poultry 

producing states—had no discussions about incident command or its 

importance in AI response. Moreover, all levels of government are 

required to adopt the Incident Command System into their response 

plans. 

• Time frames. To help contain an outbreak, USDA recommends several 

critical actions for the affected state in the early stages of response, 

such as initiating laboratory confirmation procedures and issuing 

quarantine notices; however, 4 of the 19 plans had no discussions about 

initial critical actions. Incident Command System training documents57

and USDA’s highly pathogenic AI response plan,58 respectively, 

recommend establishing immediate response priorities and creating a 

detailed plan for the first 24 hours of response to an incident. 

• Depopulation. Four of the 19 plans did not address depopulation. 

Depopulating birds is the fundamental strategy USDA and states employ 

for controlling outbreaks, as identified in USDA’s highly pathogenic AI 

response plan. 

• Disposal. Two of the 19 plans did not address the disposal of AI infected 

poultry and materials. USDA’s highly pathogenic AI response plan states 

that effective disposal is a key component of highly pathogenic AI 

response and includes issues such as disposal options and the biosecure 

transportation of infected materials. 

• Response among backyard birds. Three of the 19 plans did not include a 

discussion about response activities for backyard birds. USDA officials 

told us that the development of some state plans was heavily influenced 

by the poultry industry, which may be the reason this response 

component was omitted. This is troublesome because an outbreak must 

57“Incident Command System Review Materials” from the Federal Emergency Management 

Agency’s ICS Resource Center Contents Web site, 

http://training.fema.gov/EMIWeb/IS/ICSResource/index.htm.

58The response plan we refer to is APHIS’ National Highly Pathogenic Avian Influenza 

Response Plan. 
Page 31 GAO-07-652 Avian Influenza

be contained among backyard birds, as well as in commercial 

operations. In addition, a recent USDA survey estimates that about 40 

percent of backyard birds are located within 1 mile of at least four 

commercial poultry facilities.59 This close proximity could allow the 

virus, if not quickly contained, to spread from backyard birds to 

commercial operations—as has occurred in previous poultry disease 

outbreaks. 

• Biosecurity. We found that one state plan had no discussion about 

biosecurity. USDA recommends implementing biosecurity measures to 

keep flocks free from disease during an outbreak.60 In addition, our site 

visits to commercial and backyard facilities found varying levels of 

biosecurity—from very stringent to very lax. Further, a recent USDA 

survey found that backyard bird owners do not always implement basic 

biosecurity measures. For example, 89 percent do not require visitors to 

wash their hands before handling birds, and only 40 percent require 

hand washing after handling birds. 

• Public communications. Four of 19 state plans did not address public 

communications. Federal and state officials told us that clear public 

communications are essential during an outbreak to manage the media, 

avoid public confusion, and disseminate a clear public health message. 

In addition, the required Incident Command System calls for a Joint 

Information Center and a Public Information Officer (who is responsible 

for media outreach) to ensure clear and accurate public information, 

none of which were mentioned in these four plans. 

• Public health. Five of the 19 plans did not address the role of local, state, 

or federal public health authorities during an outbreak. USDA’s draft 

summary plan recommends that public health authorities initiate 

appropriate health measures (e.g., identify those potentially exposed 

and in need of antiviral medication) and help ensure accurate public 

communications. 

USDA and state officials told us there are several reasons why planning at 

the state level is not more complete. First, although USDA officials review 

59Poultry ‘04 Part I: Reference of Health and Management of Backyard/Small Production 

Flocks in the United States, 2004; USDA, August 2005. 

60For specifics, see USDA’s National Animal Health Emergency Management System. 
Page 32 GAO-07-652 Avian Influenza

state response plans, the agency does not have the authority to do more 

than offer comments and recommendations. It is up to the state to make 

any changes that USDA recommends. Second, USDA and state officials told 

us that there are no established federal criteria for what a state response 

plan for highly pathogenic AI should include, which has made developing 

and assessing the plans more difficult. In the absence of such criteria, 

USDA and state officials we interviewed told us they are relying on 

experience from past outbreaks or applying criteria from other programs. 

Third, state officials said that state emergency planning resources are 

limited. Despite recognizing the need for such planning, officials said they 

do not have the resources and staff to devote to such a planning effort. 

Similarly, these same officials told us that because APHIS officials who 

assist in planning cover several states simultaneously, their resources are 

also spread too thin to meet each state’s AI planning needs. State officials 

told us that because of these resource limitations and other considerations, 

some states have formed cooperatives in order to pool limited planning 

resources and work together regionally to integrate AI and other foreign 

animal disease emergency planning. 

Unresolved Issues Could 

Delay Response

We have identified several unresolved issues that, if not addressed, could 

hinder response efforts. Moreover, some could pose a particular challenge 

for states that have never encountered an outbreak. These unresolved 

issues are as follows:

• The location and number of backyard birds. According to USDA, state, 

and industry officials from all five states that we visited, containing an 

outbreak among backyard birds remains a challenge because their 

numbers and location are still unknown. For example, a 2002 outbreak 

of exotic Newcastle disease in California took almost a year to contain 

because the disease spread as responders spent valuable time trying to 

locate potentially infected birds in urban areas. State and USDA officials 

told us they were surprised by and unprepared for the large number of 

backyard birds that existed in such areas. This difficulty was 

exacerbated by the heavy automobile traffic, slowing responders’ ability 

to reach each potential bird owner’s home. Further complicating 

matters, many of these birds were expensive game fowl bred for illegal 

cockfighting and, as a result, owners sometimes moved the birds into 

hiding to avoid authorities and prevent the birds from being 

depopulated. This contributed to the spread of the disease. 
Page 33 GAO-07-652 Avian Influenza

While the numbers and locations of backyard birds within the state may 

never be definitively known, state officials told us there are steps that 

can be taken to help mitigate this problem. California formed a group of 

state and USDA officials whose goal is to minimize the risk of disease 

spread through local outreach and education. In addition, the group 

performs regular testing and voluntary surveillance of backyard 

premises, live bird markets, feed stores, pet stores, auction yards, and 

swap meets. 

Other states that have experienced outbreaks are similarly concerned 

because when an outbreak occurs, typical response involves 

conducting an epidemiological investigation—a careful tracking of all 

animals, people, and equipment that are within a certain distance of the 

infected premises. Because it is not known where backyard bird 

owners are located, epidemiological teams must go door-to-door to 

survey surrounding residences. To help overcome this tracking 

problem, Delaware and Maryland—both with dense commercial 

poultry operations—have introduced mandatory registration for all 

poultry owners, including those with backyard flocks. Further, some 

state officials, such as those in Texas, are working with USDA to do 

extensive outreach to game fowl owners. A recent USDA survey shows 

that game fowl represent the third largest population of birds raised in 

backyard environments. Texas officials told us that game fowl are 

particularly prevalent in the state because of its proximity to Mexico, 

Louisiana, and New Mexico. Cockfighting is legal in Louisiana and had 

been legal in New Mexico until March of 2007. Consequently, state 

officials are trying to locate these bird owners to brief them about the 

importance of reporting birds that die or appear diseased with highly 

pathogenic AI. Officials have also briefed these owners on the risks 

highly pathogenic AI poses to game fowl handlers.61

• Diagnostic laboratory response. Officials from all five states we visited 

cautioned that diagnostic laboratory capacity could be quickly 

overwhelmed during an outbreak. In particular, the large number of 

samples that would need to be tested and the limited number of 

laboratory personnel available remain problematic. These tests are 

61State officials familiar with cockfighting told us that handlers resuscitate down birds in the 

middle of a fight by using their mouth to clear congestion in the beak. According to the 

Occupational Safety and Health Administration, exposure of the conjunctival membranes of 

the eyes and/or nasal mucosa to secretions from AI infected birds is the predominant route 

of transmission of these viruses to humans.

Biosecurity Measures at Live Bird Markets

Source: GAO.

To prevent a possible outbreak of highly pathogenic 

AI, USDA recommends that poultry producers and 

dealers use biosecurity precautions at live bird 

markets. Live bird markets operate in many major 

cities. AI can be introduced into these markets if 

they receive infected birds or contaminated crates

and trucks. Once the virus is established in the 

market, the movement of birds, crates, or trucks

from a contaminated market can spread the virus to 

other farms and markets. Therefore, USDA 

recommends the following protective measures

should be taken at live bird markets to prevent the 

possible spread of disease:

• Use plastic instead of wooden crates for easier 

cleaning.

• Keep scales and floors clean of manure, feathers, 

and other debris.

• Clean and disinfect all equipment, crates, and 

vehicles before returning them to the farm.

• Keep incoming poultry separate from unsold birds, 

especially if birds are from different lots.

• Clean and disinfect the marketplace after every 

day of sale.

• Do not return unsold birds to the farm. 

Source: GAO.
Page 34 GAO-07-652 Avian Influenza

necessary to identify the extent of the disease spread, as well as to track 

the success of eradication efforts and prove to trading partners that 

poultry products are safe for export. Laboratory officials told us that 

within days of an outbreak—sometimes even hours—their diagnostic 

laboratories were running at capacity, with exhausted employees 

working overtime, usually for several months, to meet the testing needs 

during the outbreak. To accommodate the increased volume of samples, 

laboratory officials in two states told us they relied on support from 

USDA’s National Veterinary Services Laboratories or neighboring 

laboratories. However, these same laboratory officials told us that while 

USDA was very generous with its support, they are concerned that the 

agency may not be able to provide such support in the event of multiple 

outbreaks. Officials in another state overcame this problem by 

accepting volunteers from various agencies to run samples but noted 

that, because these volunteers were unskilled in laboratory procedures, 

valuable time was lost in training them. 

Another problem encountered during past outbreaks was transporting 

samples to the laboratory in a timely manner, especially in large states. 

For example, in one state, the laboratory running the diagnostic AI tests 

was located 3 hours from the site of the outbreak. Laboratory officials 

told us it was resource-intensive for personnel to drive 3 hours each 

way to collect samples. Moreover, because samples were collected and 

delivered to the laboratory at the end of the day, a bottleneck 

developed, requiring laboratory technicians to work overtime to 

complete tests. The laboratory has since put in place a “pony express” 

system, in which samples will be delivered to and collected from a dropoff point midway between the infected premises and the laboratory. 

Laboratory officials in California that dealt with these challenges 

throughout the yearlong exotic Newcastle disease outbreak advocate 

developing an advance emergency response plan specifically for 

diagnostic laboratory operations that covers, for example, rotating 

work schedules for laboratory workers, protocols for receiving 

samples, and an Incident Command System specific to a laboratory 

setting to facilitate emergency response. 

• Depopulation. Mass depopulation of infected birds is a continuing 

challenge because of the number of workers needed to depopulate a 

commercial poultry house, the time required to do so, and the risk to 

human health as a result of workers’ direct exposure to the virus. State 

and industry officials estimate that it takes 20 to 30 workers to 

depopulate a single commercial broiler house using a common method 
Page 35 GAO-07-652 Avian Influenza

of mass depopulation, carbon dioxide gas. Because of the large number 

of birds involved—tens of thousands in a commercial broiler house—

this process can take several hours. This method, therefore, puts 

workers’ health at risk by exposing them for prolonged periods of time 

to potentially high concentrations of the virus within a confined space. 

Recently, USDA conditionally approved the use of a new water-based 

foam method for mass depopulation that requires only two or three 

workers to administer, thereby minimizing the number of workers 

exposed to the virus. Despite the availability of this new method, there 

are still two issues of concern related to its use. First, USDA’s approval 

of this method is conditional. For example, it cannot be used to 

depopulate many types of poultry, such as ducks, geese, and quail, 

because the necessary testing to prove that the birds are not suffering 

during the depopulation process has yet to be conducted. USDA 

officials told us that they have begun working with the University of 

Delaware and the North Carolina Department of Agriculture and 

Consumer Services to investigate the effects of using foam to 

depopulate these populations. Second, this method cannot be applied in 

all environments, such as in houses where birds are raised in cages, 

which is the most challenging commercial environment to depopulate. 

USDA, state, and industry officials told us that depopulating layers 

raised in cages is a particularly time-consuming process because a 

commercial layer house can contain hundreds of thousands of birds, 

and each bird must be removed from its cage before it can be killed. 

• Disposal. State officials told us that disposal remains a problem for 

three reasons. First, although there are several disposal options—such 

as burial on-site or in a landfill, and incineration (see fig. 6)—the 

feasibility of each option is largely dependent on environmental 

conditions within that state. For example, officials in one state told us 

that while burial is allowed under state law, the existence of shallow 

bedrock in some parts of the state renders that option physically 

impossible. 
Page 36 GAO-07-652 Avian Influenza

Figure 6: Methods of Poultry Disposal

Second, disposal requires coordination among various state agencies, 

including animal health, environment, and transportation to identify 

acceptable locations and methods. For example, during one state 

outbreak, response stood still for several weeks while the state animal 

health agency negotiated with the state environmental quality agency on 

permissible disposal sites. Animal health officials in the state told us 

that they had customarily used on-site burial for disposal, but that 

during the outbreak, the environmental agency prohibited that option 

because residents worried about water contamination. For nearly a 

month, the animal health agency worked to identify major municipal 

landfills that would accept the birds and establish protocols for 

transporting the carcasses there. During this time, they could not 

dispose of any birds, and 40 more flocks became infected, 

overwhelming state and industry resources. 

Third, given the heightened public awareness and concerns about highly 

pathogenic H5N1, disposal options may be limited. Officials in one state 

told us that landfill owners who once accepted AI-infected poultry and 

material are now refusing to accept poultry carcasses infected with 

either low pathogenic or highly pathogenic AI because of public fears 

about the human health risks.62 Officials in another state are beginning 

to experience the same problem. State and USDA officials told us that 

on-site composting is a preferred method because it kills the virus 

Source: Virginia Department of Environmental Quality.

Composting Landfill Incineration

62State officials told us that the general public does not understand the difference between 

low and highly pathogenic AI.
Page 37 GAO-07-652 Avian Influenza

without moving the infected material off the infected premises. But this 

option is not always available because, for example, some poultry 

houses are too small to accommodate the equipment needed to 

compost. State and industry officials also told us that ensuring the 

infected materials are completely composted requires careful attention 

and maintenance. Failure to dispose of infected carcasses in a timely 

manner increases the risk of disease spread and allows the virus to 

remain in the environment.

• Movement of birds through the mail. DHS and some state officials 

remain concerned that birds shipped through the mail or on commercial 

airlines do not all have health certificates to ensure they are free from 

disease. As a result, birds infected with highly pathogenic AI could be 

delivered to unsuspecting owners, causing the disease to spread long 

distances to once healthy flocks. For example, poultry are often moved 

through the U.S. Postal Service for distribution and breeding purposes. 

Most states require that birds brought into the state be health-certified 

via USDA’s National Poultry Improvement Plan63 or accompanied by a 

veterinary health certificate issued in the state of origin. However, 

concerned state officials told us that the U.S. Postal Service does not 

always check for the state-required documentation, and they are 

concerned that many birds are entering states undocumented, illegally, 

and potentially diseased. In 2003, agriculture officials in North Carolina 

tracked shipments of birds at three postal facilities for 9 days. Of the 

5,113 birds entering the state via the U.S. Postal Service, 72 percent, or 

3,127 birds did not have the necessary health documentation certifying 

they were free from disease. In addition, birds without health 

certification were collocated in the same room as birds with health 

clearances, possibly spreading disease from infected to certified healthy 

birds. 

DHS and state officials told us that this problem could affect 

commercial airlines as well. Birds are transported on commercial 

aircraft, but, according to state officials, airlines do not consistently 

check for health certification. In light of this concern, state officials in 

North Carolina interviewed airline representatives and found that 

airline policies for accepting birds varied widely. While some airlines 

required health documentation, others did not. These officials told us 

63States generally require USDA’s National Poultry Improvement Plan certification for 

salmonella, pullorum, and typhoid.
Page 38 GAO-07-652 Avian Influenza

they do not know the extent of this problem because they were 

restricted from entering airline cargo holding areas. 

• Personal protective equipment. State and industry officials who have 

used personal protective equipment in past outbreaks caution that, 

although necessary, equipment to protect workers remains problematic 

and, under various conditions, could encumber and delay response. In 

2006, the Department of Labor’s Occupational Safety and Health 

Administration released updated guidance for protecting poultry 

workers in the event of a suspected or confirmed AI outbreak at a 

poultry facility. 64 Specifically, it recommends that animal health 

responders wear protective clothing, such as an impermeable apron or 

surgical gown with long, cuffed sleeves; disposable protective shoe 

covers or rubber or polyurethane boots that can be cleaned and 

disinfected; safety goggles to protect the mucous membranes of the 

eyes; and, at a minimum, disposable, particulate respirators (e.g., N95). 

Responders who cannot wear a disposable, particulate respirator, 

because of facial hair or other limitations, should wear a loose-fitting 

(i.e., helmeted or hooded) powered air purifying respirator equipped 

with high-efficiency filters. 

State officials told us that in poultry houses that have been sealed to 

prevent the virus from spreading, temperatures can become extreme in 

hot weather, slowing down responders wearing this type of equipment. 

In addition, state officials told us goggles can become fogged, making it 

impossible to see. Moreover, the minimum required disposable 

particulate respirator is difficult to breathe through, yet it is commonly 

used because of its low cost.65 For these reasons, workers have, at 

times, removed the protective equipment while carrying out their 

duties.66 Furthermore, officials told us it is difficult and dangerous for 

64The guidance takes into consideration HHS’ Centers for Disease Control and Prevention 

Interim Guidance for Protection of Persons Involved in U.S. Avian Influenza Outbreak 

Disease Control and Eradication Activities. The recommendations are based on 

precautions that are considered best practices for protecting individuals involved in the 

response to an AI outbreak. 

65The disposable particulate respirator costs about $1 each, depending on the model.

66According to updated guidance from the Occupational Safety and Health Administration 

for protecting employees from AI viruses, in the event of an outbreak, a safety and medical 

adviser should be identified to ensure compliance with procedures. However, according to 

USDA officials, these advisers need not be at the site of the outbreak. 
Page 39 GAO-07-652 Avian Influenza

responders to attempt to climb ladders to reach birds in cages several 

stories high wearing heavy boots, thick gloves, and hooded respirators. 

Finally, federal, state, and industry officials told us that respirators pose 

other challenges. Specifically, the Occupational Safety and Health 

Administration’s standards require that respirators be used in the 

context of a complete respiratory protection program. This program 

involves, among other things, selecting an appropriate respirator, 

conducting medical evaluations to determine an employee’s ability to 

use a respirator, providing training, and checking to ensure that 

respirators fit properly. To be effective, tight-fitting respirators must 

have a proper sealing surface on the wearer's face. USDA officials told 

us that, although they are diligently working to medically evaluate and 

fit responders with respirators at this time, it is expected that some of 

this will still need to occur at the time of an outbreak, slowing down the 

response process. Another concern involves the use of powered air 

purifying respirators. Some state officials told us they are expensive 

and impractical.67 It takes many hours to depopulate a house, but the 

batteries to operate this kind of respirator last only for specified 

periods of time, potentially delaying response.68 These respirators are 

also heavy. One state official told us that, as an alternative, the state 

department of agriculture is planning to use a full-face respirator for a 

variety of reasons. A full-face respirator is lighter and less expensive69

than a powered respirator and, because it does not require batteries, 

there is no time limit for use. Also, it has an advantage over goggles 

because it is less prone to fogging. According to Occupational Safety 

and Health Administration guidelines, all respirators have pros and 

cons. 

• Antiviral medication. USDA has not estimated the amount of antiviral 

medication that it would need in the event of an outbreak of highly 

pathogenic AI or resolved how to provide such supplies within the first 

24 hours of an outbreak. According to Occupational Safety and Health 

Administration guidelines, poultry workers responding to an outbreak 

67Powered air purifying respirators cost about $1,500 each, but price can vary depending on 

model and type of batteries used.

68The length of time depends on the battery. 

69A full-face respirator costs about $130 each, but the price can vary depending on the 

model.
Page 40 GAO-07-652 Avian Influenza

of highly pathogenic AI should take antiviral medication daily while 

working at the site of an outbreak and each day for 7 days after leaving 

the site. Further, the National Veterinary Stockpile is required to contain 

sufficient amount of antiviral medication to respond to the most 

damaging animal diseases that affect human health and the economy, 

and it must be capable of deployment within 24 hours of an outbreak.70

Despite these requirements, stockpile officials have not estimated how 

much antiviral medication would be needed during a particular 

outbreak scenario. In addition, the National Veterinary Stockpile has not 

yet obtained any antiviral medication for highly pathogenic AI. Stockpile 

officials cite several reasons for this. First, since the National Veterinary 

Stockpile is responsible for many animal diseases, not just highly 

pathogenic AI, it faces competing priorities. According to these officials, 

the first priority is to build the infrastructure to acquire, maintain, and 

deliver veterinary supplies for critical animal diseases, including highly 

pathogenic AI. Second, although this infrastructure could be used to 

deliver antiviral medication for highly pathogenic AI, stockpile officials 

told us that, to prevent duplication of efforts and limit costs,71 the best 

strategy would be to gain access to HHS’ Strategic National Stockpile of 

16 million doses of the same antiviral.72 Presidential Directive 9 

emphasizes that the National Veterinary Stockpile should leverage, 

where appropriate, the mechanisms and infrastructure that have been 

developed for the management, storage, and distribution of the 

Strategic National Stockpile. However, HHS officials told National 

Veterinary Stockpile officials that the antiviral medication in the 

Strategic National Stockpile is reserved for use during a human 

pandemic and is not to be used to protect responders to an outbreak of 

AI among poultry. Third, as an alternative, National Veterinary Stockpile 

officials told us they are in the process of contracting with a 

manufacturer of antiviral medication to provide, within 24 hours of an 

70Homeland Security Presidential Directive 9 § 18(a). 

71According to DHS and National Veterinary Stockpile officials we interviewed, the stockpile 

is underfunded. 

72The Strategic National Stockpile’s goal is to have 26 million doses of antiviral medication 

on hand by the end of 2006 and a total of 50 million by the end of 2008. 
Page 41 GAO-07-652 Avian Influenza

outbreak, antiviral medication for 3,000 responders for 6 weeks.73

However, according to stockpile officials, this contract is not yet in 

place. 

Although the National Veterinary Stockpile does not yet have antiviral 

medication on hand, another unit within APHIS—the Safety, Health, and 

Employee Wellness Branch—currently has 34,800 doses and has been 

working to secure more. In fact, the branch recently entered into an 

agreement with HHS’ Federal Occupational Health agency to, among 

other things, provide medical professionals at the site of an outbreak 

who would supply and distribute antiviral medication to responders, as 

well as monitor their health.74 However, the agreement does not specify 

how many doses will be provided or when they will be delivered. 

According to branch officials, delivery can be guaranteed only if APHIS 

purchases a set amount of antiviral medication in advance of an 

outbreak. Given the current situation, Federal Occupational Health will 

supply whatever amount of antiviral medication it has in stock at the 

time of an outbreak, which may or may not be sufficient, and then 

pursue additional doses. In the meantime, according to branch officials, 

the branch will provide responders the 34,800 doses it currently has on 

hand. However, this supply is set to expire at the end of 2007, and the 

branch has no funds to replace it. Branch officials told us they are 

working to extend the shelf life of the antiviral medication, but this 

process can take up to 6 months.75

Conclusions The rapid spread of highly pathogenic H5N1 has heightened worldwide 

awareness of the potential damage AI can inflict on the poultry industry 

and the serious implications it has for human health. Considerable effort is 

being made by USDA and other federal agencies, the states, and the poultry 

industry to ensure a swift and effective response to highly pathogenic AI. 

73National Veterinary Stockpile officials told us that this number reflects, in part, the total 

number of individuals involved during the height of the exotic Newcastle disease outbreak 

in California in 2002. It does not reflect a calculated estimate of those exposed to the virus 

and in need of antiviral medication.

74Branch officials told us they selected Federal Occupational Health for this purpose 

because it has frequently worked with DHS’ Federal Emergency Management Agency to 

ensure worker protection during emergencies.

75Branch officials told us that the process they are using is similar to HHS’ process called the 

Shelf Life Extension Program.
Page 42 GAO-07-652 Avian Influenza

While much has been accomplished already, opportunities remain to 

identify and close gaps and to address shortcomings in the preparations 

that have been made thus far. 

First, unless USDA and DHS work diligently together to ensure roles and 

responsibilities are clearly defined, effectively communicated, and well 

understood in advance of a significant outbreak, delay could occur at the 

federal level as the two agencies attempt to work out their relationship 

during a time of crisis. Second, unless USDA identifies capabilities for a 

defined outbreak scenario, creates a response plan based on this 

information with the appropriate performance measures, and then tests 

this plan, USDA and its response partners will not be well-informed on 

their level of readiness. Third, until USDA develops a standard set of 

criteria that state response plans should contain, state-level plans will 

continue to have shortcomings that could impede efforts to contain future 

outbreaks. Fourth, unless USDA provides additional assistance to states to 

address unresolved issues, USDA and the states will face real-time 

challenges as an outbreak unfolds; a potentially devastating scenario. 

Similarly, until USDA resolves uncertainties regarding antiviral medication, 

the health risks associated with highly pathogenic AI may prevent or delay 

responders from carrying out their duties within a critical and limited 

window of opportunity. 

Recommendations for 

Executive Action

To address challenges that limit the nation’s ability to quickly and 

effectively respond to highly pathogenic AI, we recommend that the 

Secretaries of Agriculture and Homeland Security develop a memorandum 

of understanding that describes how USDA and DHS will work together in 

the event of a declared presidential emergency or major disaster, or an 

Incident of National Significance, and test the effectiveness of this 

coordination during exercises. 

In addition, we recommend that the Secretary of Agriculture take the 

following seven actions: 

• In consultation with other federal agencies, states, and the poultry 

industry, (1) identify the capabilities necessary to respond to a probable 

scenario(s) for an outbreak of highly pathogenic AI; (2) use this 

information to develop a response plan that identifies the critical tasks 

for responding to the selected outbreak scenario and, for each task, 

identifies the responsible entities, the location of resources needed, 
Page 43 GAO-07-652 Avian Influenza

time frames, and completion status; and (3) test these capabilities in 

ongoing exercises to identify gaps and ways to overcome those gaps. 

• Develop standard criteria for the components of state response plans 

for highly pathogenic AI, enabling states to develop more complete 

plans and enabling USDA officials to more effectively review them. 

• Focus additional work with states on how to overcome potential 

problems associated with unresolved issues, such as the difficulty in 

locating backyard birds and disposing of carcasses and materials. 

• Determine (1) the amount of antiviral medication that USDA would 

need in order to protect animal health responders, given various highly 

pathogenic AI scenarios, and (2) how to obtain and provide supplies 

within 24 hours of an outbreak. 

Agency Comments and 

Our Evaluation

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

comment. Also, both departments provided technical comments that we 

incorporated as appropriate. 

USDA agreed with all but one of our recommendations. USDA stated that it 

does not believe a memorandum of understanding is the best vehicle for 

clarifying and defining the roles of DHS and USDA in the event of a 

declared presidential emergency or major disaster, or an Incident of 

National Significance. Nevertheless, USDA accepted the need to clarify 

roles during such an event and further supported the need to test this 

coordination in formal exercises. USDA also stated that it will work with 

DHS, states, and other agencies to identify the best interagency mechanism 

to accomplish this planning. GAO believes that written clarification is 

important and that a memorandum of understanding is an appropriate 

mechanism to accomplish this goal. In fact, the National Response Plan 

anticipates the use of such documents to further clarify agency roles. 

USDA also stated that the report is a comprehensive look at USDA’s efforts 

to prepare for highly pathogenic AI. However, the department noted that 

the report does not highlight several critical components of successful 

foreign animal disease planning, such as USDA’s robust veterinary 

infrastructure and the National Animal Health Laboratory Network. GAO 

recognizes that USDA has important preparations in place to respond to 

foreign animal diseases in general that are also relevant for AI. However, it 

is not possible to include all planning measures. Our report focuses on 
Page 44 GAO-07-652 Avian Influenza

USDA preparations for highly pathogenic AI specifically. USDA’s written 

comments and our evaluation appear in appendix II.

DHS agreed that further coordination between USDA and DHS is needed in 

the event of a declared presidential emergency or major disaster, or an 

Incident of National Significance. In addition, the department supported 

the need to test the effectiveness of this coordination through exercises. 

DHS also suggested that coordination could occur through an interagency 

concept of operation plan. DHS’ written comments appear in appendix III.

As we agreed with your offices, unless you publicly announce the contents 

of this report earlier, we plan no further distribution of it until 15 days from 

the date of this report. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretaries of Agriculture and 

Homeland Security, and other interested parties. We will also make copies 

available upon request. In addition, the report will be available at no charge 

on the GAO Web site at http://www.gao.gov.

If you or your staff has any comments or questions about this report, please 

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

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff who made key contributions to this 

report are listed in appendix IV. 

Daniel Bertoni

Director, Natural Resources and Environment
Page 45 GAO-07-652 Avian Influenza

List of Committees

The Honorable Tom Harkin

Chairman

The Honorable Saxby Chambliss

Ranking Member

Committee on Agriculture, Nutrition and Forestry

United States Senate

The Honorable Joseph Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security 

and Government Affairs

United States Senate

The Honorable Edward M. Kennedy

Chairman

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable Arlen Specter

Ranking Member 

Subcommittee on Labor, Health and Human Services, 

Education, and Related Agencies

Committee on Appropriations

United States Senate 

The Honorable Daniel K. Akaka

Chairman

Subcommittee on Oversight of Government Management, 

the Federal Workforce, and the District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Richard Burr

Ranking Member

Subcommittee on Retirement and Aging

Committee on Health, Education, Labor and Pensions

United States Senate
Page 46 GAO-07-652 Avian Influenza

Appendix I

Scope and Methodology AAppenednxidexiIs

To describe the steps that the Department of Agriculture (USDA) has taken 

to prepare for outbreaks of highly pathogenic avian influenza (AI) in 

domestic poultry, we reviewed statutes, regulations, directives, and 

national planning documents that broadly define USDA’s role in an animal 

health or other national emergency. Specifically, we reviewed the Animal 

Health Protection Act; the Stafford Act; regulations for indemnification 

applicable to highly pathogenic AI, Part 53 of Title 9 of the Code of Federal 

Regulations, and those for low pathogenic AI, Part 56 of Title 9 of the Code 

of Federal Regulations; Homeland Security Presidential Directives 5, 8, and 

9, which respectively address management of domestic incidents, national 

preparedness, and the defense of agriculture and food; the National 

Response Plan with revisions issued in May 2006; and recently developed 

presidential documents, including the National Strategy for Pandemic 

Influenza and the Implementation Plan for the National Strategy for 

Pandemic Influenza. We also reviewed USDA’s National Poultry 

Improvement Plan, documents in the National Animal Health Emergency 

Management System, as well as those being drafted for highly pathogenic 

AI specifically. Furthermore, we interviewed USDA officials from the 

Animal Plant Health Inspection Service (APHIS), the Agricultural Research 

Service, the Food Safety and Inspection Service, as well as officials from 

the offices of the Executive Secretariat, Communications, Budget and 

Program Analysis, and General Counsel. We also interviewed Department 

of Homeland Security (DHS) officials from the Office of the Chief Medical 

Officer, the Federal Emergency Management Agency, and the Preparedness 

Directorate. Moreover, we interviewed officials from the National 

Association of State Departments of Agriculture, the American Veterinary 

Medical Association, the National Turkey Foundation, the National 

Chicken Council, the U.S. Poultry and Egg Association, and the Food and 

Water Watch. We also attended a Highly Pathogenic Avian Influenza 

Workshop that was jointly sponsored by the U.S. Poultry and Egg 

Association and USDA, with attendees from academia, the poultry industry, 

state governments, and the federal government. Finally, we attended a 3-

day AI tabletop exercise involving representatives from USDA, industry, 

and the state of Georgia. 

To identify any challenges that could affect USDA’s ability to protect 

domestic poultry from highly pathogenic AI, in addition to the activities 

described above for objective one, we conducted structured interviews in 

person and via telephone with officials from five states that have 

experienced and responded to an outbreak of AI or a comparable highly 

infectious avian disease in the past 5 years. These states also represent 

varying poultry demographics. Specifically, we interviewed state animal 
Appendix I

Scope and Methodology

Page 47 GAO-07-652 Avian Influenza

health and APHIS officials; poultry industry representatives; and animal 

health diagnostic laboratory personnel in California, Delaware, Maryland, 

Texas, and Virginia. We also visited several commercial and one backyard 

poultry operation, as well as live bird markets that kept animals indoors in 

cages, as well as those markets with animals housed in outdoor pens. We 

also interviewed avian health specialists whom we selected for their 

technical expertise on avian health and emergency avian disease response. 

In particular, we sought to obtain their comments on the virology and 

epidemiology of highly pathogenic AI, including H5N1, as well as current 

research in mass poultry depopulation and disposal methods. 

To better understand challenges associated with planning at the state level, 

we interviewed the officials noted above as well as, at the recommendation 

of DHS, officials from the North Carolina Department of Agriculture and 

Consumer Services and officials representing 21 states from the Multi-State 

Partnership for Security in Agriculture and the Southern Agriculture and 

Animal Disaster Response Alliance. We also conducted structured 

interviews with APHIS’ Regional Directors and Area Emergency 

Coordinators who are responsible for working directly with the states. 

Among other things, we asked the Area Emergency Coordinators, who are 

specifically charged with helping states develop AI response plans, to 

identify strengths and weaknesses in their state plans and to characterize 

their state’s level of readiness for an outbreak.1

 We also performed our own 

review and assessment of 19 state plans to corroborate identified strengths 

and weaknesses from the interviews. Although we requested that USDA’s 

coordinators provide us with AI plans from the 44 states with which they 

work, they provided us with the 19 plans they had available. 

Finally, within GAO, we coordinated our review with GAO teams 

examining the role of federal agencies involved in pandemic influenza 

preparedness, including DHS, the Department of Health and Human 

Services, the Department of State, and the Department of Defense. 

We conducted our review from May 2006 to June 2007 in accordance with 

generally accepted government auditing standards.

1

At the time of our review, there were 16 Area Emergency Coordinators representing 44 

states. 
Page 48 GAO-07-652 Avian Influenza

Appendix II

Comments from the Department of 

Agriculture ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.
Appendix II

Comments from the Department of 

Agriculture

Page 49 GAO-07-652 Avian Influenza

See comment 3.

See comment 4.

See comment 5.
Appendix II

Comments from the Department of 

Agriculture

Page 50 GAO-07-652 Avian Influenza
Appendix II

Comments from the Department of 

Agriculture

Page 51 GAO-07-652 Avian Influenza

See comment 6.
Appendix II

Comments from the Department of 

Agriculture

Page 52 GAO-07-652 Avian Influenza
Appendix II

Comments from the Department of 

Agriculture

Page 53 GAO-07-652 Avian Influenza

The following are GAO’s comments on the Department of Agriculture’s 

letter dated May 21, 2007.

GAO Comments 1. USDA commented that our report does not take into account several 

critical components of successful foreign animal disease planning 

efforts. GAO recognizes that USDA has important preparations in place 

to respond to foreign animal diseases in general that are also relevant 

for AI. For example, USDA calls attention to its veterinary 

infrastructure and its National Animal Health Laboratory Network. We 

agree that these are important for responding to multiple types of 

disease outbreaks. However, it is not possible to include all planning 

measures. The focus of our report is on steps USDA has taken to 

prepare for highly pathogenic AI specifically. 

2. We modified our report to include a statement about the importance of 

veterinary infrastructure to AI surveillance. 

3. The National Response Plan anticipates the use of interagency 

agreements, such as memorandums of understanding, to further clarify 

agency roles. The intent of the recommendation is to further formalize 

how the two departments will coordinate during such an event. 

4. We modified our report to include a statement about USDA’s National 

Animal Health Laboratory Network.

5. During the course of our work, USDA officials specifically requested 

that we refer to these reports as “drafts.” In addition, the summary AI 

response plan is published on USDA’s Web site as a draft document. 

Nevertheless, we modified our report to state that these documents 

would be used in the event of an outbreak. 

6. Our report acknowledges that USDA has a preliminary estimate 

regarding the amount of antiviral medication needed based on the 

exotic Newcastle disease outbreak. However, as our report also states, 

this number does not reflect a calculated estimate of those exposed to 

the virus in need of medication. Furthermore, our report acknowledges 

that National Veterinary Stockpile officials are in the process of 

contracting with a manufacturer of antiviral medication to provide, 

within 24 hours of an outbreak, antiviral medication for 3,000 

responders for 6 weeks. However, as our report also states, this 

contract to supply antiviral medication is not yet in place.
Page 54 GAO-07-652 Avian Influenza

Appendix III

Comments from the Department of Homeland 

Security ApendxiI
Page 55 GAO-07-652 Avian Influenza

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Daniel Bertoni, (202) 512-3841, or bertonid@gao.gov

Staff 

Acknowledgments

In addition to the individual named above, Charles Adams, Assistant 

Director; Kevin Bray; Nancy Crothers; Mary Denigan-Macauley; Jeff 

Jensen; Christopher Lyons; Terry Richardson; and Margaret Vo made key 

contributions to this report. 

Don Cowan, Joyce Evans, Lynn Musser, Katherine Raheb, Jeremy Sebest, 

Daniel Semick, and Cynthia Taylor also made contributions.

(360700)
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