Testimony 

Before the Committee on Governmental 

Affairs, U.S. Senate 

United States General Accounting Office 

GAO

For Release on 

Wednesday 

November 19, 2003 BIOTERRORISM 

A Threat to Agriculture and 

the Food Supply 

Statement for the Record by 

Lawrence J. Dyckman, Director 

Natural Resources and Environment 

GAO-04-259T 
Bioterrorism attacks could be directed at many different targets in the farmto-table food continuum, including crops, livestock, food products in the 

processing and distribution chain, wholesale and retail facilities, storage 

facilities, transportation, and food and agriculture research laboratories. 

Experts believe that terrorists would attack livestock and crops if their 

primary intent was to cause severe economic dislocation. The U.S. 

agriculture sector accounts for about 13 percent of the gross domestic 

product and 18 percent of domestic employment. Terrorists may decide to 

contaminate finished food products if harm to humans was their motive. 

Four recent GAO reports found gaps in federal controls for protecting 

agriculture and the food supply. Thus, the United States would be 

vulnerable to deliberate efforts to undermine its agriculture industries, 

deliberate tampering of food during production, and the release of deadly 

animal diseases, some of which also affect humans. GAO found, for 

example, border inspectors were not provided guidance on foot-and-mouth 

disease prevention activities in response to the 2001 European outbreak, 

inspection resources could not handle the magnitude of international 

passengers and cargo, and new technology used to scan shipments at a bulk 

mail facility was operating only part-time and in only that facility. Such 

careful controls over imported foods can help to prevent pathogens from 

contaminating U.S. cattle with devastating diseases that have struck many 

other countries. GAO also found that federal overseers did not have clear 

authority to impose requirements on food processors to ensure security at 

those facilities. Finally, GAO found security problems at Plum Island—a 

large government-operated animal disease research facility. GAO found that 

scientists from other countries, facility workers, and students had access to 

areas containing high-risk pathogens without having completed background 

checks and the required escorts. 

Following are the four reports discussed in this testimony: 

• Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must 

Remain Vigilant and Resolve Outstanding Issues, U.S. General 

Accounting Office, GAO-02-808 (Washington, D.C.: July 26, 2002).

• Mad Cow Disease: Improvements in the Animal Feed Ban and Other 

Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. 

General Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 

2002). 

• Food-Processing Security: Voluntary Efforts Are Under Way, but 

Federal Agencies Cannot Fully Assess Their Implementation, U.S. 

General Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 

2003). 

• Combating Bioterrorism: Actions Needed to Improve Security at Plum 

Island Animal Disease Center, U.S. General Accounting Office, GAO03-847 (Washington, D.C.: September 19, 2003).

When the President created the 

Department of Homeland Security, 

he included U.S. agriculture and 

food industries in the list of critical 

infrastructures needing protection. 

The Secretaries of Agriculture and 

of Health and Human Services have 

publicly declared that the U.S. food 

supply is susceptible to deliberate 

contamination. GAO was asked to 

provide an overview of the potential 

vulnerabilities of the food supply 

and agriculture sector to deliberate 

contamination and to summarize 

four recent GAO reports that 

identified problems with federal 

oversight that could leave the 

nation’s agriculture and food supply 

vulnerable to deliberate 

contamination. 

The four GAO reports included 

recommendations to (1) the U.S. 

Department of Agriculture and the 

Food and Drug Administration 

(FDA) to strengthen import checks 

for detecting mad cow and foot-andmouth diseases and to address 

security matters at food processors; 

(2) FDA to strengthen enforcement 

of the feed ban; and (3) the 

Department of Homeland Security 

to correct security deficiencies at 

Plum Island. The agencies generally 

agreed with GAO’s recommendations 

and have taken, or are in the process 

of taking, actions to address the 

problems GAO found. 

www.gao.gov/cgi-bin/getrpt?GAO-04-259T

To view the full statement, click on the link 

above. For more information, contact 

Lawrence J. Dyckman at 202-512-3841or 

dyckmanl@gao.gov. 

Highlights of GAO-04-259T, a Statement for 

the Record for the Committee on 

Governmental Affairs, U.S. Senate 

 November 2003 

BIOTERRORISM

A Threat to Agriculture and the Food 

Supply 
Page 2 GAO-04-259T Threats to Agriculture and Food 

Madam Chairman and Members of the Committee: 

I appreciate the opportunity to submit this statement for the record on the 

results of our work on potential threats, vulnerabilities, and risks faced by 

the nation’s agriculture sector and its food supply. As you know, 

protecting the nation’s agriculture industries and food supply has taken on 

increased sense of urgency in the wake of the terrorist attacks of 

September 11, 2001. And there is now broad consensus that American 

farms, food, and agriculture systems, which account for about 13 percent 

of the nation’s gross domestic product, are vulnerable to potential attack 

and deliberate contamination. 

In his October 2001 executive order establishing the Office of Homeland 

Security, the President added agriculture and food industries to the list of 

critical infrastructure sectors needing protection—acknowledging that the 

agriculture sector and the food supply are indeed vulnerable to 

bioterrorism. Both the Secretaries of Agriculture and of Health and Human 

Services have also publicly recognized that the U.S. food supply is 

susceptible to deliberate contamination. Within this backdrop, federal and 

state government agencies; industry; and academic institutions have taken 

steps, such as, assessing the potential threats, risks, and vulnerabilities 

and developing plans to rapidly detect and respond to any attack on the 

nation’s agriculture sector and food supply. 

This statement (1) provides a brief overview of the potential vulnerabilities 

of the food supply and agriculture sector to deliberate contamination and 

(2) summarizes four recent GAO reports identifying a range of problems 

with federal oversight that could leave the nation’s agriculture sector and 

food supply vulnerable to intentional contamination. Included in this 

discussion are our 2002 reports on federal efforts to prevent devastating 

animal diseases—foot-and-mouth and bovine spongiform encephalopathy 

(BSE), also known as mad cow—from entering the United States, and our 

2003 reports on security at food-processing facilities and at the Plum 

Island Animal Disease Center. Plum Island studies serious animal diseases, 

including some that can cause illness and death in humans. The four 

reports are discussed in greater detail in appendix I, which also provides 

the link to each report on GAO’s Web page. 

The U.S. agriculture and food sectors have features that make them 

vulnerable to bioterrorism attacks. These attacks could be directed at 

many different targets in the farm-to-table food continuum—including 

crops, livestock, food products in the processing and distribution chain, 

Summary 
Page 3 GAO-04-259T Threats to Agriculture and Food 

wholesale and retail facilities, storage facilities, transportation, and food 

and agriculture research laboratories. Indeed, chemicals and infectious 

pathogens could be intentionally introduced at various points in that 

continuum. Most experts believe that terrorists would choose to attack 

livestock and crops if their primary intent was to cause severe economic 

dislocation. Such an attack would cause severe disruption—the U.S. 

agriculture sector accounts for about 13 percent of the U.S. gross domestic 

product and 18 percent of domestic employment. On the other hand, 

terrorists would choose to contaminate finished food products if harm to 

humans was their motive. 

Four recently issued GAO reports found gaps in federal controls for 

protecting agriculture and the food supply. As a result of those gaps, the 

United States would be vulnerable to deliberate efforts to undermine its 

agriculture industries, intentional tampering of food during production, 

and the release of deadly animal diseases, some of which also affect 

humans. We found, among other things, that the volume of imported items 

entering the United States made it impossible for border inspectors to 

physically inspect every incoming cargo container or each and every 

international passenger’s luggage—key pathways through which foot-andmouth disease could enter the country. We also found that new equipment 

used to scan shipments at one large import bulk mail facility was operating 

only part-time and in only that bulk mail facility. We also reported that 

discrepancies in the accuracy of documents provided by the importer 

posed a risk that BSE-contaminated food might not be flagged for further 

inspection. Those careful controls over imported foods help prevent 

pathogens from contaminating American cattle with devastating diseases 

that have struck many other countries. In addition, we found that federal 

overseers did not have clear authority to impose requirements on food 

processors to ensure security at those facilities. And finally, we found 

security problems at Plum Island. For example, several scientists from 

other countries, facility workers, and students had access to areas 

containing high-risk pathogens, even though their background checks 

were incomplete and they did not have the required escorts. 
Page 4 GAO-04-259T Threats to Agriculture and Food 

Our current agriculture and food sectors have features that make them 

vulnerable to terrorist attacks. These include the high concentration of our 

livestock industry and the centralized nature of our food-processing 

industry. As a result, chemicals and infectious pathogens can be 

intentionally added at various points along the farm-to-table food 

continuum. Whether terrorists target food products or animals and crops 

for deliberate contamination, serious public health and economic 

consequences are at stake. The mere threat of such an attack would 

seriously undermine consumer confidence in the safety of our food supply 

and destabilize export markets. 

The U.S. agriculture sector and food supply have been largely secure from 

deliberate contamination, except for a few such incidents. In 1984, for 

example, in what federal agencies describe as the first recorded event of 

bioterrorism in the United States, a cult group poisoned salad bars at 

several Oregon restaurants with Salmonella bacteria. As a result, 750 

people became ill. A recent, deliberate food contamination also highlights 

how easily someone intent on causing harm can do so. In January 2003, 

the Centers for Disease Control and Prevention reported that 92 persons 

became ill after purchasing ground beef from a Michigan supermarket that 

was intentionally contaminated with nicotine. An employee of the 

supermarket that sold the contaminated meat has been indicted for 

intentionally poisoning 200 pounds of meat sold in his supermarket. 

Naturally occurring outbreaks of diseases affecting livestock, as well as 

accidental contamination of food, further illustrate the potentially horrific 

effects of a deliberate and carefully choreographed event. For example, 

the United Kingdom has estimated that its outbreak of foot-and-mouth 

disease resulted in over $10 billion (U.S.) in losses to tourism and the food 

and agriculture sectors and the slaughter of over 4 million animals. 

Estimates of direct costs for a similar outbreak in the United States run as 

high as $24 billion with the destruction of about 13 million animals. 

Terrorists seeking ways to harm the United States could deliberately 

introduce foreign animal diseases into the country. In addition, according 

to a recent media report, the USDA calculated that a foot-and-mouth 

disease outbreak could spread to 25 states in as little as 5 days. 

Furthermore, according to the media report, a simulation exercise by the 

National Defense University in June 2002 predicted that a foot-and-mouth 

disease outbreak could spread to more than one-third of the nation’s cattle 

herds. As that exercise demonstrated, diseases affecting livestock could 

have significant impacts on the U.S. economy and consumer confidence in 

the food supply. 

Overview of the 

Vulnerability of the 

U.S. Agriculture 

Sector and Food 

Supply to Intentional 

Contamination 
Page 5 GAO-04-259T Threats to Agriculture and Food 

With regard to food, one large-scale U.S. foodborne illness outbreak in 

1994 sickened 224,000 people nationwide with Salmonella enteritis from 

eating a national brand of ice cream. That outbreak, though not deliberate 

in nature, is estimated to have cost about $18.1 million in medical care and 

time lost from work. Widely publicized illness outbreaks in 2002 resulted 

in illnesses, deaths, and costly food recalls. One involved ground beef 

produced by a plant in Colorado that caused at least 46 people in 16 states 

to become ill from E. coli O157:H7. The plant conducted a recall to 

remove about 18 million pounds of potentially contaminated beef that had 

entered commerce. The other outbreak involved fresh and frozen ready-toeat turkey and chicken products. Those products, manufactured in a 

Pennsylvania plant, carried Listeria monocytogenes, caused 46 illnesses in 

eight states, as well as seven deaths and three stillbirths or miscarriages. 

The plant recalled approximately 27.4 million pounds of potentially 

contaminated poultry products that had entered commerce. However, 

most foodborne illnesses are not reported and the vast majority of 

foodborne outbreaks are never traced to a specific food source. 

We recognize that the U.S. Department of Agriculture (USDA) and the 

Food and Drug Administration (FDA)—the federal agencies with primary 

responsibility for safeguarding our agriculture and food sectors—have 

stepped up their prevention and response efforts. In addition, we 

recognize the concerted efforts to better safeguard U.S. borders that have 

been taken over by the Department of Homeland Security, which also 

recently took over the operation of the Plum Island Animal Research 

Facility from USDA. Nevertheless, serious questions remain about whether 

the agriculture sector and the food supply are sufficiently prepared for 

deliberate acts of terrorism. Over the last 10 years, GAO has issued many 

reports that, in aggregate, portray a national food safety system that is 

fragmented and problem-laden. It is that system, however, on which the 

nation must depend to prevent, prepare against, and respond to 

bioterrorism events against our food supply. 

Four recently issued GAO reports, in particular, identified weaknesses in 

federal systems for protecting U.S. livestock against devastating animal 

diseases and ensuring security at food-processing facilities and at Plum 

Island—the nation’s principal diagnostics laboratory for foreign animal 

diseases, including some that can transfer to humans. The information 

from these four reports will not provide a comprehensive presentation of 

potential risks; there are certainly other potential targets in the farm-totable food continuum, including the food transportation sector, that we 

have not yet examined for vulnerability to intentional contamination. 

Recent GAO Reports 

Identified Weaknesses 

in U.S. Systems for 

Protecting Livestock 

and the Food Supply 

and Preventing the 

Release of Animal 

Diseases that Present 

Human Health Risks 
Page 6 GAO-04-259T Threats to Agriculture and Food 

These reports do, nonetheless, highlight weaknesses in U.S. systems for 

protecting critical agriculture and food safety sectors. 

Two reports we issued in 2002—on foot-and-mouth disease and on mad 

cow disease—examined, among other things, U.S. measures for preventing 

those diseases from entering the United States.1

 We found that, because of 

the sheer magnitude of international passengers and cargo that enter this 

country on a daily basis and the inspection resources that are available, 

completely preventing the entry of those diseases may be infeasible. Footand-mouth disease can be carried on the shoes of international passengers 

and the packages they carry, in international mail, and in garbage from 

international carriers. We found that USDA did not provide timely 

guidance to border inspectors for screening cargo and international 

passengers after foot-and-mouth disease struck Europe in 2001. We also 

reported that only one international bulk mail facility used new scanning 

equipment to help inspectors more accurately identify products potentially 

carrying animal diseases that could contaminate U.S. cattle. 

Our 2003 report on food-processing security noted that experts from 

government and academia agreed that terrorists could use food products 

as a vehicle for introducing harmful chemical or biological agents into the 

food supply.2

 We found that USDA and FDA had each, independently, 

published comprehensive security guidelines for processors to help them 

prevent or mitigate the risk of deliberate contamination at their facilities. 

Additionally, we reported that USDA and FDA did not have clear authority 

to require processors to take safety measures, such as installing fences, 

alarms, or outside lighting. These measures could improve security in the 

event of deliberate contamination. In addition, the field personnel at the 

two agencies did not have adequate training on security matters, which 

would hamper their ability to conduct informed discussion with 

processing plant personnel. 

 1

Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain Vigilant and 

Resolve Outstanding Issues, U.S. General Accounting Office, GAO-02-808 (Washington, 

D.C.: July 26, 2002) and Mad Cow Disease: Improvements in the Animal Feed Ban and 

Other Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General 

Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002). 

2

Food-Processing Security: Voluntary Efforts Are Under Way, but Federal Agencies 

Cannot Fully Assess Their Implementation, U.S. General Accounting Office, GAO-03-342 

(Washington, D.C.: February 14, 2003). 
Page 7 GAO-04-259T Threats to Agriculture and Food 

In September 2003, we also reported fundamental concerns with security 

at the Plum Island Animal Disease Center that leave the facility vulnerable 

to security breaches.3

 We found that alarms and door sensors for the 

biocontainment area were not fully operational; outdoor lighting was not 

adequate to support security cameras; and certain assets, including the 

foot-and-mouth disease vaccine bank, were not adequately protected. 

Controls over access to the pathogens were also inadequate—scientists 

from other countries were given access to the biocontainment area 

without escorts while their background checks were incomplete; no 

background checks were done on students attending classes in the 

biocontainment area; and the cleaning crew were among the unauthorized 

staff entering the biocontainment area unescorted. Controlling access to 

pathogens is critical because a tiny quantity of pathogen could be removed 

without being detected and developed into a weapon. Lastly, we found 

that the security guards protecting the Island had been operating without 

authority to carry firearms or to make arrests; the facility’s written plans 

for responding to a terrorist incident exceeded the capability of its 

security system and the emergency response plans were not adequately 

coordinated with state and local emergency and law enforcement 

responders. Our report noted that the Department of Homeland Security 

officials agreed with our identification of these problems and stated that 

they had initiated actions to address our concerns. 

The four reports made recommendations to USDA, FDA, and the 

Department of Homeland Security for correcting the problems we found, 

and the agencies generally agreed with our recommendations. Appendix I 

discusses the four reports, our recommendations, and the agencies’ 

positions in greater detail. 

 3

Combating Bioterrorism: Actions Needed to Improve Security at Plum Island Animal 

Disease Center, U.S. General Accounting Office, GAO-03-847 (Washington, D.C.: September 

19, 2003). 
Page 8 GAO-04-259T Threats to Agriculture and Food 

For future contacts regarding this statement, please contact Lawrence J. 

Dyckman at 202-512-3841. Individuals making key contributions to this 

statement included Maria Cristina Gobin, Erin Lansburgh, Charles Adams, 

and Clifford Diehl. This statement will also be available on the GAO Web 

site at http://www.gao.gov. 

Contacts and 

Acknowledgments 
Page 9 GAO-04-259T Threats to Agriculture and Food 

Four recently issued GAO reports identified weaknesses in federal 

systems for protecting U.S. livestock against devastating animal diseases 

and ensuring security at food-processing facilities and at Plum Island—the 

nation’s principal diagnostics laboratory for animal diseases. The 

following reports highlight weaknesses in U.S. systems for protecting 

critical agriculture and food safety sectors: 

• Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain 

Vigilant and Resolve Outstanding Issues, U.S. General Accounting Office, 

GAO-02-808 (Washington, D.C.: July 26, 2002). 

Because the livestock industry is a key element of the U.S. agricultural 

sector and economy, protecting U.S. livestock from foot-and-mouth 

disease is an important federal responsibility. The 2001 outbreak of this 

disease in the United Kingdom clearly illustrated the destruction that this 

highly contagious animal disease can cause to a nation’s livestock industry 

and other sectors of the economy. Foot-and-mouth disease is one of the 

most devastating viral animal diseases affecting cloven-hoofed animals—

such as cattle and swine—and has occurred in most countries of the world 

at some point over the past century. The last foot-and-mouth disease 

outbreak in the United States was in 1929.1

 According to federal officials, 

even a single case of the disease would cause our trading partners to 

prohibit U.S. exports of live animals and animal products and could result 

in losses of between $6 billion and $10 billion a year while the country 

eradicated the disease and until it regained disease-free status. 

As part of our study, we examined whether U.S. measures for preventing 

foot-and-mouth disease from entering the United States were effective and 

whether the United States could respond quickly and effectively to an 

outbreak of the disease if it were to occur. 

We found that, because of the sheer magnitude of international passengers 

and cargo that enter this country on a daily basis, completely preventing 

the entry of foot-and-mouth disease may be infeasible. The volume of 

incoming items make it impossible for border inspectors to physically 

inspect every incoming cargo container or each international passenger’s 

 1

The foot-and-mouth virus is relatively hardy and can survive in certain environments for 

considerable periods of time. For example, it can live in salted bacon for up to 183 days or 

in air-dried animal hides or skins for 6 weeks. Should a person step in manure from an 

infected animal, the virus can live on the shoes for up to 9 weeks in summer conditions or 

up to 14 weeks in winter. 

Appendix I: Recent GAO Reports Highlight 

Gaps in Federal Efforts to Protect 

Agriculture and the Food Supply 
Page 10 GAO-04-259T Threats to Agriculture and Food 

luggage. The U.S. Department of Agriculture (USDA) has identified key 

pathways through which this highly contagious disease might enter the 

United States, such as on imported live animals or animal products; on the 

shoes of, or in packages carried by, international passengers; in 

international mail; and in garbage from international carriers. We also 

reported that, after the foot-and-mouth disease outbreak in the United 

Kingdom in 2001, USDA did not inform Customs of its decision to prohibit 

or restrict certain products or more vigilantly screen passengers arriving at 

U.S. ports of entry from the United Kingdom. USDA did not provide such 

official guidance until the Acting Commissioner of Customs formally 

requested such information more than a month after the outbreak began in 

the United Kingdom. USDA and the Department of Homeland Security 

(DHS) are working to increase defenses against diseases entering through 

those pathways. 

We further reported that, should preventive measures fail, and the United 

States experience an outbreak, the country would face challenges in 

responding quickly and effectively. While considerable planning and 

testing of emergency response plans had occurred, we noted several 

factors that could limit a rapid response to a foot-and-mouth disease 

outbreak, including (1) the need for rapid disease identification and 

reporting; (2) effective communication, coordination, and cooperation 

between federal, state, and local responders; (3) an adequate response 

infrastructure, including equipment, personnel, and laboratory capacity; 

and (4) clear animal identification, indemnification, and disposal policies. 

Our report recommended that USDA develop a formal mechanism to 

notify Customs as outbreaks of foot-and-mouth disease spread in other 

countries and develop uniform, nontechnical procedures that Customs 

inspectors could use to process international passengers and cargo 

arriving from disease-affected countries. USDA agreed with our 

recommendations. It said it would work with DHS to ensure that formal 

protocols are established for the seamless communication of animal 

disease risk information for border inspection. 

• Mad Cow Disease: Improvements in the Animal Feed Ban and Other 

Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General 

Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002). 

Mad cow disease—or BSE—is an always fatal, neuro-degenerative disease 

that had been found in cattle in 23 countries around the world at the time 

we issued this report. Cattle contract the disease through feed that 

contains protein derived from the remains of diseased animals. Scientists 
Page 11 GAO-04-259T Threats to Agriculture and Food 

generally believe an equally fatal disease in humans—known as variant 

Creutzfeldt-Jacob Disease—is linked to eating beef from cattle infected 

with BSE; over 100 people have died from the human variant. During long 

incubation periods—2 to 8 years in cattle and possibly up to 30 years in 

humans—the disease is undetectable. 

As part of our study, we assessed the effectiveness of federal actions to 

prevent the emergence and spread of BSE and ensure compliance with the 

animal feed ban. 

We found, among other things, that federal actions could not sufficiently 

ensure that all BSE-infected animals or products would be kept out of the 

United States or that if BSE were found, it would be detected promptly 

and not spread to other cattle through animal feed or enter the human 

food supply. The United States had imported about 125 million pounds of 

beef (0.35 percent of total imported) and about 1,000 cattle (0.003 percent 

of total imported) from countries that later discovered BSE—during the 

period when BSE would have been incubating. We reported that USDA’s 

and the Food and Drug Administration’s (FDA) import inspection capacity 

had not kept pace with the growth of imports. We also found that the one 

international bulk mail facility that used the newest technology in 

scanning equipment that would help inspectors more accurately identify 

products that could carry BSE was not being used during periods of 

operation when inspectors were not on duty. We further reported that 

Customs found discrepancies with the accuracy of importer-provided 

information and, as a result, BSE-risk imports may go undetected. 

We also reported that FDA’s enforcement of the feed ban, which was put 

in place to prevent the spread of BSE if it were found in U.S. cattle, was 

limited and that FDA inspection data were flawed. FDA had not identified 

and inspected all firms subject to the ban and had not acted promptly to 

compel firms to keep prohibited proteins out of cattle feed and to label 

animal feed that cannot be fed to cattle. FDA’s data on inspections of feed 

facilities were so severely flawed that the agency could not know the full 

extent of industry compliance. 

We noted that, if BSE were found in the United States, the economic 

impact on the $56 billion beef industry could be devastating—consumers 

might refuse to buy domestic beef; beef exports could decline 

dramatically; and sales in related industries, such as hamburger chains and 

soup and frozen dinner manufacturers, could be similarly affected. 
Page 12 GAO-04-259T Threats to Agriculture and Food 

We recommended that USDA and FDA, among other things, develop a 

coordinated strategy to identify resources needed to increase inspections 

of imported goods and that FDA strengthen enforcement of the feed ban 

and its management of inspection data. USDA and FDA agreed with these 

recommendations. Additional funds were requested and approved to 

strengthen border inspections. FDA has increased the number of feed-ban 

compliance inspections, and implemented a new feed-ban inspection data 

system. 

• Food-Processing Security: Voluntary Efforts Are Under Way, but Federal 

Agencies Cannot Fully Assess Their Implementation, U.S. General 

Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 2003). 

The food-processing sector is generally described as the middle segment 

of the farm-to-table continuum—it extends from the time livestock and 

crops leave the farm for slaughter and processing until food products 

reach retail establishments and the consumer. Experts from government 

and academia agreed that terrorists could use food products as a vehicle 

for introducing harmful chemical or biological agents into the food supply. 

In June 2002, the National Academies had also reported that terrorists 

could use toxic chemicals or infectious agents to contaminate food 

production facilities and that FDA should act promptly to extend the use 

of its Hazard Analysis and Critical Control Point methods for ensuring 

food safety to deal with the risk of deliberate contamination.2

 The Centers 

for Disease Control and Prevention had also reported on the need for 

vigilance in protecting food and water supplies. Within this context, in 

2002 we examined federal efforts to enhance security at food-processing 

facilities. 

We reported that the two agencies with primary responsibility for ensuring 

for food safety—USDA and FDA—had each, independently, published 

comprehensive security guidelines for food processors to help them 

identify measures to prevent or mitigate the risk of deliberate 

contamination at their production facilities. Both agencies encouraged 

processors to review their current operations and to adopt those measures 

that they believed would be best suited for their facilities. FDA’s guidance 

contains over 100 suggested security measures and USDA’s some 68 such 

items. Among other things, the guidelines included recommendations for 

 2

USDA requires meat and poultry plants to use a Hazard Analysis and Critical Control Point 

system and FDA requires that system for juices, fish, and shellfish. 
Page 13 GAO-04-259T Threats to Agriculture and Food 

improving personnel security by conducting screening and background 

checks and controlling entry into the facilities; securing hazardous 

materials by controlling access to storage areas; improving outside 

security by monitoring all access to the establishment; installing lighting; 

ensuring that in-house laboratories have comprehensive and validated 

security and disposal procedures in place; and that parking areas are a 

safe distance from the facility. 

However, we also reported that USDA and FDA had determined that their 

existing statutes did not provide them with absolutely clear authority to 

impose security requirements at food-processing facilities. For example, 

neither agency had authority to require processors to implement measures 

to enhance security outside the food-processing environment, such as 

installing fences, alarms, or outside lighting. Nor did the agencies believe 

they had authority to require food processors to conduct employee 

background checks. Because of these uncertainties about their authority, 

the security guidelines they gave food processors are voluntary. Since the 

guidelines were voluntary, USDA and FDA have not been enforcing, 

monitoring, or documenting their implementation. We also found that 

most of USDA’s and FDA’s field staff had not received training on security 

matters. And, although the field staff were instructed to be vigilant and on 

“heightened alert,” they were also told not to document or report their 

observations regarding security at the plants because the information 

could be obtained under a Freedom of Information Act request. 

We also reported on recent congressional efforts to protect the nation’s 

drinking water from terrorist acts that may offer a model for FDA and 

USDA to help them monitor security measures at food-processing facilities 

and to identify any gaps that may exist. Specifically, the Public Health 

Security and Bioterrorism Preparedness and Response Act of 2002 

requires community water systems to assess their vulnerability to terrorist 

attacks and develop emergency plans to prepare and respond to such 

events. They are also required to submit copies of their plans to the 

Environmental Protection Agency. The act specifically exempts these 

assessments from the Freedom of Information Act. 

We concluded that FDA and USDA could not assess the industry’s efforts 

to prevent or reduce their vulnerability to deliberate contamination. 

Lacking such baseline information, they could not be prepared to advise 

food processors on any additional actions needed. We also concluded that 

the lack of security training for field personnel hampered their ability to 

conduct informed discussion with facility personnel. 
Page 14 GAO-04-259T Threats to Agriculture and Food 

We recommended that FDA and USDA study their agencies’ existing 

statutes and identify what additional authorities they may need relating to 

security measures. On the basis of the results of these studies, the 

agencies should seek additional authority from the Congress. While USDA 

agreed with our recommendation, FDA took no position. We also 

recommended that both agencies provide training for all field personnel to 

enhance their awareness and ability to discuss security measures with 

plant personnel. USDA and FDA agreed with the need for additional 

training. 

• Combating Bioterrorism: Actions Needed to Improve Security at Plum 

Island Animal Disease Center, U.S. General Accounting Office, GAO-03-

847 (Washington, D.C.: September 19, 2003). 

USDA scientists at the Plum Island Animal Disease Center are responsible 

for developing strategies for protecting the nation against animal diseases 

that could be accidentally or deliberately introduced in to the country. 

These scientists—often with the assistance of scientists from other 

countries—identify the pathogens that cause animal diseases in foreign 

countries and then work to develop vaccines against them. Some 

pathogens maintained at USDA’s Plum Island laboratory, such as foot-andmouth disease, are highly contagious to livestock and could cause 

catastrophic economic losses if they were released outside the facility. 

Questions about the security of Plum Island arose after the September 

2001 terrorist attacks and when employees of the contractor hired to 

operate and maintain the Plum Island facilities went on strike in August 

2002. About 10 months later, in June 2003, DHS became responsible for 

Plum Island while the USDA staff are continuing their research programs. 

In September 2003, we reported that our review of security at Plum Island 

identified fundamental concerns that leave the facility vulnerable to 

security breaches. We found that immediately after the September 2001 

terrorist attacks, USDA began a concerted effort to assess security at 

many of its laboratories, including Plum Island. Using a risk management 

approach, USDA identified certain pathogens as the primary asset 

requiring protection, the potential threats to this asset, and the associated 

risk. USDA also began to upgrade security at Plum Island. For example, 

USDA hired armed guards to patrol the island and installed fingerprint 

recognition locks on freezers containing pathogens. 

Despite these improvements, we identified shortcomings in Plum Island’s 

security arrangements. We found that Plum Island’s physical security was 

incomplete and limited. For example, the alarms and door sensors that 
Page 15 GAO-04-259T Threats to Agriculture and Food 

were recommended for the biocontainment area were not fully 

operational; outdoor lighting was not adequate to support security 

cameras; and physical security was not sufficient for certain assets, 

including the foot-and-mouth disease vaccine bank. DHS officials said the 

alarms and door sensors will be in place by December 2003 and they were 

evaluating other physical security matters. 

Furthermore, we found that Plum Island officials had not adequately 

controlled access to the pathogens. Eight scientists from other countries 

were given access to the biocontainment area without escorts while their 

background checks were incomplete; no background checks were done on 

students who regularly attended classes within the biocontainment area; 

and individuals entering the biocontainment area to perform 

nonlaboratory functions, such as cleaning, were not always escorted. 

Controlling access to the pathogens is particularly important because no 

security device is currently capable of detecting a microgram of 

pathogenic material. Therefore, a scientist could remove a tiny quantity of 

pathogen without being detected and potentially develop it into a weapon. 

Many facilities take measures to minimize this risk. For example, at the 

U.S. Army Medical Research Institute of Infectious Diseases, background 

checks must be updated regularly to evaluate the continued suitability and 

reliability of employees working with pathogens. According to DHS 

officials, they are taking action to revise policies for access to the 

biocontainment area. 

We also found limitations in Plum Island’s incident response capability. 

For example, the guard force had been operating without authority to 

carry firearms or to make arrests. Plum Island’s incident response plan 

does not address what to do if an incident, such as a terrorist attack, 

exceeds the capability of the security system, and officials have not tested 

the facility’s response capability to ensure its effectiveness. DHS officials 

told us they have started to take actions to fully address these incident 

response issues and are obtaining assistance from the Federal Protective 

Service. 

Because of the strike that occurred in August 2002 and the hostility 

surrounding it, the risk that someone may try to steal pathogens has 

increased. One striker was convicted of tampering with the island’s water 

distribution and treatment system as he walked off the job the day the 

strike began, and USDA officials suspect that this individual did not act 

alone. The intelligence community considers disgruntled employees as 

posing a security risk. Although USDA did consider the possibility that it 

could have a disgruntled worker, it did not reevaluate the level of risk, the 
Page 16 GAO-04-259T Threats to Agriculture and Food 

assets requiring protection, or its incident response plans for Plum Island 

in light of specific events related to the strike. Furthermore, USDA did not 

discuss the defined threat with the intelligence community and local law 

enforcement officials to ensure that threats particular to Plum Island and 

its vicinity were taken into consideration. 

We concluded that further actions are needed to provide reasonable 

assurance that pathogens cannot be removed from the facility and 

exploited for use in bioterrorism. Particularly, it is important to better 

secure the foot-and-mouth disease vaccine bank to ensure its availability 

for combating an outbreak. The lack of comprehensive policies and 

procedures for limiting access to pathogens unnecessarily elevates the risk 

of pathogen theft. Moreover, because physical security measures alone are 

not adequate to secure pathogens, all laboratories containing these 

materials face the challenge of developing other approaches to mitigate 

the risk of theft. By consulting with other laboratories to discover methods 

they are using to mitigate the risk to pathogens, Plum Island officials can 

learn more about safeguards being employed elsewhere. 

We recommended that DHS (1) correct physical security deficiencies at 

Plum Island; (2) limit access to pathogens and identify ways to mitigate 

the inherent difficulty of securing pathogens; (3) enhance Plum Island’s 

incident response capability; and (4) reconsider the risks and threats to 

Plum Island and revise the security and incident response plans as needed. 

DHS has agreed with the report and has started to implement these 

recommendations. 

(360418) 
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