DEPARTMENT OF HOMELAND SECURITY 

Office of Inspector General 

The Department of Homeland Security’s 

Role in Food Defense and 

Critical Infrastructure Protection 

OIG-07-33 February 2007
Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

February 23, 2007 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector General 

Act of 1978. This is one of a series of audit, inspection, and special reports prepared as part of our 

oversight responsibilities to promote economy, effectiveness, and efficiency within the department. 

This report assesses actions taken by DHS in support of food defense and critical infrastructure 

protection. It is based on interviews with employees and officials of relevant agencies and 

institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our office, and 

have been discussed in draft with those responsible for implementation. It is our hope that this 

report will result in more effective, efficient, and economical operations. We express our 

appreciation to all those who contributed to this report. 

Richard L. Skinner 

Inspector General 
Contents 

Executive Summary ..................................................................................................................... 1 

Background..................................................................................................................................... 2 

Overview of the Food Sector ................................................................................................... 2 

Hazards to the Food Sector...................................................................................................... 3 

Potential Impacts of Food Sector Hazards............................................................................... 6 

A Historical Perspective on Federal Food Defense and Critical Infrastructure Protection 

Responsibilities........................................................................................................................ 8 

DHS Food Sector Responsibilities ........................................................................................ 12 

Challenges Intrinsic to the Fulfillment of DHS’ Mandate..................................................... 14 

Results of Review ........................................................................................................................ 17

DHS’ Internal Coordination of Food Sector Activities ......................................................... 17 

Distribution of DHS Food Sector Activities.............................................................. 17 

Management of DHS Food Sector Activities ............................................................ 20 

Need for Consolidated DHS Food Sector Leadership ............................................... 27 

Public and Private Partners .................................................................................................... 28 

Sector Governance and Information Sharing............................................................. 29 

Charting and Protecting the Food Sector................................................................... 44 

Coordination of Research and Development, Education and Training Initiatives .... 50 

Prioritization Challenges........................................................................................................ 59 

DHS Fulfillment of its Responsibilities................................................................................. 68 

Opportunities for Additional Work........................................................................................ 74 

Conclusion ..................................................................................................................................... 87 

Management Comments and OIG Analysis...................................................................... 88 

Appendices 

Appendix A Purpose, Scope, and Methodology................................................................. 98 

Appendix B Recommendations.......................................................................................... 99 

Appendix C Management Comments on the Draft Report ............................................... 101 

Appendix D Farm-to-Table Continuum ............................................................................ 120 

Appendix E Federal Food Sector Regulatory Oversight................................................... 121 

Appendix F Critical Infrastructure Sectors and Designated Sector-Specific Agencies.... 124 

Appendix G DHS Food Sector Responsibilities ............................................................... 125 

Appendix H DHS Food-Sector-Related Programs and Initiatives .................................... 128 

Appendix I The Food Sector in Frameworks for Infrastructure Protection, 

National Preparedness, and Incident Management....................................... 136 

Appendix J Chronology of Significant Events................................................................. 144 

Appendix K Major Contributors to This Report ............................................................... 147 

Appendix L Report Distribution ....................................................................................... 148 

DHS’ Role in Food Defense and Critical Infrastructure Protection 
Contents 

Tables 

Table 1 DHS Food Defense and Critical Infrastructure Protection 

Activities and Initiatives ................................................................................ 19 

Table 2 Areas of Shared DHS Food Defense and Critical Infrastructure Protection 

Program Thrust .............................................................................................. 24 

Table 3 DHS Execution of Food-Related Responsibilities......................................... 68 

Table 4 Critical Infrastructure Sectors and Sector-Specific Agencies....................... 124 

Table 5 DHS Food Sector Responsibilities and Their Origins .................................. 125 

Figures 

Figure 1 Review Focus Along Incident Timeline ........................................................ 13 

Figure 2 Farm-to-Table Continuum ............................................................................ 120 

Figure 3 Regulatory Oversight of Sample Foods........................................................ 123 

Figure 4 Food Sector Elements of Homeland Security Frameworks.......................... 141 

Abbreviations 

CBP Customs and Border Protection, Department of Homeland Security 

CDC Centers for Disease Control and Prevention, Department of Health and 

Human Services 

DHS Department of Homeland Security 

FBI Federal Bureau of Investigation, Department of Justice 

FDA Food and Drug Administration, Department of Health and Human Services 

GAO Government Accountability Office 

HHS Department of Health and Human Services 

ISAC Information Sharing and Analysis Center 

NCFPD National Center for Food Protection and Defense 

NIPP National Infrastructure Protection Plan 

S&T Science and Technology Directorate, Department of Homeland Security 

UC Davis University of California, Davis 

U.S. United States 

U.S.C. United States Code 

USDA United States Department of Agriculture 

DHS’ Role in Food Defense and Critical Infrastructure Protection 
OIG 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The federal government is charged with defending the food supply from 

intentional attacks and natural hazards. While the Department of Homeland 

Security (DHS) is not the designated lead for a number of key activities in this 

area, Congress and the President have assigned DHS many important food 

defense and critical infrastructure protection responsibilities. This report 

examines DHS activities relating to post-harvest food, and focuses on 

prevention, protection, preparedness, and detection efforts. 

There are four main limitations in DHS’ related efforts. First, DHS must 

improve internal coordination. DHS food sector activities are distributed 

across multiple organizational units, and similar program thrusts have 

emerged. Consolidated management attention is required to reduce the risk of 

duplication and promote collaboration. 

Second, DHS needs to engage its public and private food sector partners more 

effectively. Food sector partners were frustrated by the quality and extent of 

DHS external coordination in sector governance and information sharing; 

mapping; and research, development, education, and training. 

Third, DHS could do more to prioritize resources and activities based on risk. 

DHS units have used different approaches to prioritizing food sector activities 

in the context of their larger missions, and have not developed a common 

perspective on food sector risk. There is little consensus on how any of the 

elements of risk apply to the food sector, and staff in key positions expressed 

misinformed views about food sector risk. 

Finally, DHS must fully discharge its food sector responsibilities. DHS has 

satisfied basic requirements in most, but not all, areas of responsibility. The 

department has not submitted an integrated federal food defense budget plan 

or clearly established assessment standards for use in the food sector. 

Our report contains 16 recommendations to enhance DHS’ performance and 

improve the security posture of the food supply. DHS concurred with 12 of 

these recommendations. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Background 

Overview of the Food Sector 

The nation’s food sector is comprised of an array of distinct businesses 

and operations that help bring food products to consumers around the 

world. The host of steps in the food production system is often 

collectively described as a “farm-to-table” continuum. This continuum is, 

in fact, a tremendously complex system characterized by numerous 

interdependencies. An illustration of the farm-to-table continuum can be 

found in Appendix D. 

Pre-harvest elements of the continuum include crops and animals in the 

field, as well as fertilizers and animal feed. The harvesting or slaughter of 

agricultural products marks the beginning of the post-harvest food sector, 

which extends through the balance of the continuum until products are 

consumed. This review concentrated on post-harvest elements of the food 

supply so as not to duplicate previous Government Accountability Office 

work on the pre-harvest side.1 

The post-harvest food industry accounts for 12% of the nation’s economic 

activity and employs more than 10% of the American workforce.2 It 

consists of enormous subsectors, including business lines addressing 

processing, storage, transportation, retail, and food service. Statistics on 

just two of these subsectors serve to illustrate the magnitude of the sector. 

The National Restaurant Association projects that the industry’s 925,000 

U.S. locations will reach $511 billion in sales for 2006, serving over 70 

billion “meal and snack occasions” for the year.3 Meanwhile, the nation’s 

$460 billion food retail business consists of more than 34,000 

supermarkets, 13,000 smaller food markets, 1,000 wholesale club stores, 

13,000 convenience stores, and 28,000 gas station food outlets. Like the 

other components of the food industry, these subsector business units have 

a broad geographic distribution and are present in all regions of the 

country. 

1

 For more information on efforts to counter pre-harvest agroterrorism, refer to the Government Accountability 

Office’s March 2005 report, Homeland Security: Much Is Being Done to Protect Agriculture from a Terrorist

Attack, but Important Challenges Remain (GAO-05-214). 2

 Bureau of Labor Statistics, Occupational Employment Statistics, “Frequently Asked Questions,” 

http://www.bls.gov/oes/oes_ques.htm. 3

 http://www.restaurant.org/pdfs/research/2006factsheet.pdf

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Private sector entities are the predominant owners and operators of the 

food sector. Federal, state, and local governments have noteworthy food 

production, distribution, retail, and service operations, but these are small 

when compared to private sector operations. 

Regulation of the food industry is divided between federal, state, and local 

agencies. State, territorial, and local governments conduct oversight of 

food retail and food service establishments within their jurisdictions. 

These levels of government oversee restaurants, institutional food service 

establishments, and hundreds of thousands of food retailers. Within the 

federal government, primary responsibility for food safety rests with two 

agencies. The Food Safety and Inspections Service of the U.S. 

Department of Agriculture (USDA) oversees the processing of red meat, 

poultry, and processed egg products. The Food and Drug Administration 

(FDA) of the Department of Health and Human Services (HHS), in turn, 

regulates the processing of virtually all other food products. In addition to 

these two, several other federal agencies provide oversight of food 

processing, distribution, and retail. A comparison of foods regulated by 

the Food Safety and Inspections Service and FDA can be found in 

Appendix E. 

Hazards to the Food Sector 

The food sector could experience several types of significant adverse 

events. Among these, intentional food contamination is of greatest 

concern to many in the food security and safety fields. In December 2004, 

the former Secretary of Health and Human Services, Tommy Thompson 

remarked that, “I, for the life of me, cannot understand why the terrorists 

have not attacked our food supply because it is so easy to do."4 

Protecting the U.S. food supply from intentional adulteration has grown in 

importance since the attacks of September 11, 2001. Some have 

suggested that terrorist attacks on the food supply are increasingly likely. 

In 2003, the President’s Council of Advisors on Science and Technology 

wrote that “terrorist acts of a widely diffuse nature such as attacks on the 

food supply ... could become a preferred means of attack in an 

environment where terrorist networks have been ‘decapitated’ and their 

ability to communicate and raise funds significantly diminished.”5 Food 

4 William Branigin, Mike Allen and John Mintz, “Tommy Thompson Resigns From HHS,” Washington Post, 

December 3, 2004. 5

 President’s Council of Advisors on Science and Technology, The Science and Technology of Combating 

Terrorism, July 2003, p. 5. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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products may be deliberately contaminated with chemical, biological, or 

radiological agents. Despite the range of possible contaminating agents 

and the openness of parts of the food supply chain, there have been few 

recorded cases of deliberate food contamination in the United States. 

These events have only had a localized effect and have not resulted in 

serious casualties on a massive scale or catastrophic economic loss. The 

following are three prominent domestic incidents of food contamination: 

• In 1984, members of a religious cult poisoned ten Oregon salad 

bars with Salmonella, resulting in 751 individual cases of illness. 

• In 1996, a disgruntled employee of a Texas hospital willfully 

tainted snacks in a staff break room. This incident caused illness in 

12 people.6 

• In 2003, a Michigan supermarket employee infected 200 pounds of 

beef with an insecticide, causing illness in 92 people.7 

Though it is without domestic precedent, the prospect of a mass-scale food 

contamination event is of particular concern because the nation is subject 

to major unintentional foodborne illness outbreaks. Experts reason that, 

with some study and limited access, an individual or individuals with 

malevolent aims could reproduce these outbreaks with more dire 

consequences. In 2003, the FDA wrote that, “If an unintentional 

contamination of one food ... can affect 300,000 individuals, a concerted, 

deliberate attack on food could be devastating, especially if a more 

dangerous chemical, biological, or radionuclear agent were used.”8 

Food safety practitioners devote considerable attention and resources to 

addressing the hazards associated with unintentional food contamination. 

In the past, this type of food contamination has led to some major 

outbreaks, which have occurred with much more frequency and on a 

considerably larger scale than deliberate acts of contamination. In 1985, 

for example, the unintentional contamination of milk with Salmonella 

typhimurium caused illness in 170,000 individuals in the United States. A 

decade later, an estimated 224,000 people in 41 states became ill after 

consuming ice cream with Salmonella enteriditidis.

9 

While foodborne disease outbreaks typically result from products 

contaminated by naturally occurring biological pathogens, foodborne 

 Ali S. Khan, David L. Swerdlow, and Dennis D. Juranek, “Precautions against Biological and Chemical Terrorism 

Directed at Food and Water Supplies,” Public Health Reports, January-February 2001, pp. 3-14. 7

 Association of State and Territorial Health Officials, “Issue Brief: State Activities in Food Security,” April 2004. 8

 FDA, “Risk Assessment for Food Terrorism and Other Food Safety Concerns,” October 13, 2003. 9

 Food Safety Department, World Health Organization, Terrorist Threats to Food: Guidance for Establishing and 

Strengthening Prevention and Response Systems, 2002, p. 5. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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6
illnesses have also been traced to toxins, heavy metals, pesticides, and 

other chemicals. In 1981, for instance, a toxic agent in cooking oil 

sickened about 20,000 and resulted in the deaths of approximately 800 in 

Spain.10 Such contamination events can have long-term effects. In 

Michigan in 1973, a fire retardant containing a potentially carcinogenic 

hazardous substance was inadvertently mixed with cattle feed and several 

thousand people ingested products from animals that had eaten the 

contaminated feed. Studies have shown that people who consumed these 

products maintained high levels of the toxic substance years later. It 

persists, for example, in the breast milk of women who consumed affected 

foods.11 

Intentional or unintentional damage to food industry facilities could also 

adversely affect the sector and result in temporary shortages of certain 

food products. Because there are available substitutes for most foodstuffs, 

however, the effect of such losses may be firm-, product-, or industryspecific, and not widespread. Damage to facilities at “chokepoints” in the 

supply chain for a number of food products, however, could have more 

pronounced economic effects. 

The food sector could also suffer adversely from the debilitation of other 

sectors. Because food is often consumed some distance from its point of 

production, significant transportation disruptions have the potential to 

spawn food shortages. The availability of food products is also dependent 

on the continuing efforts of the food sector workforce. Conditions that 

undermine the willingness of food industry workers to go to their 

worksites or to otherwise perform their jobs could also contribute to food 

shortages. Because major U.S. cities typically have access to about one 

week’s supply of food, however, transportation and labor disruptions of 

this kind would have to be sustained before they could critically undercut 

the availability of food.12 Sustained disruptions could occur, for example, 

in the case of a widespread outbreak of a communicable disease during 

which workers may be reluctant to appear at job sites for extended 

periods. In addition, although it is possible to sustain the flow of some 

foodstuffs during extended electrical outages, the supply of perishable 

food products could be significantly reduced in the absence of electricity. 

10 FDA, “Risk Assessment for Food Terrorism and Other Food Safety Concerns,” October 13, 2003. 

(http://www.cfsan.fda.gov/~dms/rabtact.html). 11 http://www.sciencedaily.com/releases/2000/12/001214082240.htm and Brilliant, L.B., et al. “Breast-milk

monitoring to measure Michigan's contamination with polybrominated biphenyls,” The Lancet, Volume 312, Issue 

8091, (September 23, 1978), pp. 643-646. 12 McIntire Peters, Katherine. “Officials fear terrorist attack on U.S. food supply,” Government Executive, June 10,

2003. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Potential Impacts of Food Sector Hazards 

The White House has stated that a successful attack on the nation’s 

agriculture and food system could have “catastrophic health and economic 

effects.”13 Indeed, regardless of the cause, an adverse food sector event 

could negatively impact public health, the economy, the public’s 

psychological well-being, and the effectiveness of government. DHS 

recognizes negative impacts in these four areas as the types of 

consequences that might result from incidents affecting the nation’s 

critical infrastructures.14 

Foremost among potential effects are those on public health and safety. 

Foodborne illness outbreaks currently cause widespread morbidity and 

mortality. The Centers for Disease Control and Prevention (CDC) 

estimates that the United States experiences 76 million illnesses, 325,000 

hospitalizations, and 5,000 deaths from unintentional food contamination 

each year.15 Recent USDA estimates place the annual cost of premature 

deaths caused by a single common foodborne illness, salmonellosis – an 

illness resulting from infection with Salmonella bacteria – at over $2.1 

billion.16 The current public health burden of unintentional contamination 

is borne more heavily by vulnerable subpopulations, such as individuals 

with weakened immune systems. In some cases, sickness from 

contaminated food results in chronic illness. 

Significant public health consequences also are to be anticipated in the 

event of a well-orchestrated deliberate act of food contamination. A 

recent article predicted that over 100,000 Americans – many of them 

school children – could be poisoned if a single milk truck was 

contaminated with one gram of botulinum type A toxin.17 Though some 

experts questioned the technical basis for the paper’s conclusions and 

signaled that the dairy industry had taken appropriate countermeasures to 

reduce this threat,18 a single intentional food contamination event could 

sicken thousands. 

13 Homeland Security Presidential Directive 9: Defense of United States Agriculture and Food, January 30, 2004, 

paragraph 2. 14 DHS, National Infrastructure Protection Plan, June 30, 2006, p. 1. 15 Mead, Paul S., et al., “Food-Related Illness and Death in the United States,” Emerging Infectious Diseases, vol. 5,

1999, pp. 607-25. 16 http://www.ers.usda.gov/Data/FoodBorneIllness/salm_Intro.asp?Pathogen=Salmonella&p=1&s=&y=2005&n=

1397187 17 Wein, Lawrence M. and Yifan Liu, “Analyzing a bioterror attack on the food supply: The case of botulinum toxin 

in milk,” Proceedings of the National Academy of Sciences, July 12, 2005, pp. 9984-9989. 18 Leitenberg, Milton and George Smith, “Got Toxic Milk?: A Rejoinder.” June 14, 2005

(http://www.fas.org/sgp/eprint/milk.html), and Clay Detlefsen, “Dairy Industry vigilant in addressing food security,” 

Cheese Market News, July 1, 2005. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Given the size of the food sector, damage to the sector could undermine 

the orderly functioning of the economy. The broad distribution and 

widespread prevalence of the nation’s food processing plants, storage 

facilities, and retail outlets, along with the continuous distribution and 

transportation of food, suggest that a major contamination event could 

have a significant disruptive effect on the national economy. The food 

industry also accounts for $60 billion in exports and a positive net balance 

of trade. Damage to the nation’s food sector could result in the loss of 

export markets and add to trade deficits. 

An incident need not be widespread to cause major harm to U.S. trade. 

U.S. beef exports plunged when 119 countries instituted bans on American 

beef after “mad cow” disease was found in a U.S. herd in 2003.19 Japan, a 

$1.4 billon annual market for U.S. beef, partially lifted its ban two years 

later. Even then, nearly half of the countries accepting U.S. beef in 2003 

had not permitted the resumption of U.S. beef imports.20 

Commentators on the subject have observed that an adverse food sector 

event could also reduce state and local governments’ ability to maintain 

order and deliver essential services. A major food contamination event 

could engender public panic on a local or mass scale, depending on the 

affected food product and population, and media coverage of the incident. 

Widespread public panic could occur if adulteration of foods resulted in a 

large number of deaths. An appreciable decline in public confidence in 

the government could result if a contamination event were linked to a 

government facility. 

Finally, an adverse incident affecting the food sector could undermine 

public morale and confidence in the nation’s institutions. Most Americans 

currently regard their food as safe. A July 2005 Gallup Poll found that 

large majorities of respondents were “confident” that food in U.S. grocery 

stores and restaurants was safe.21 Because there have been few incidents 

of large-scale food contamination, it is not clear how the public’s 

perceptions about the safety of food might change in response. The 

Gilmore Commission reported that a major act of terrorism against the 

food supply is likely to have “a major psychological impact.” It further 

19 USDA, “Livestock and Poultry: World Markets and Trade,” November 2005. 20 USDA, “Statement by Agriculture Secretary Mike Johanns Regarding the Opening of the Japanese Market to U.S.

Beef,” Release No. 0544.05, December 11, 2005. 21 Gallup Poll News Service, "Is Confidence in U.S. Food Supply Wilting?," September 20, 2005. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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indicated that the psychological consequences of such an attack were “not 

well understood.”22 

A Historical Perspective on Federal Food Defense and 

Critical Infrastructure Protection Responsibilities 

It is the policy of the federal government to protect the food system from 

“terrorist attacks, major disasters, and other emergencies.”23 The structure 

of government support for this policy is set out in several different laws 

and executive directives. To understand the current state of federal efforts 

surrounding food defense and critical infrastructure protection, one must 

first understand the history behind those efforts. 

A number of federal food-related responsibilities arise from the 

government’s role in critical infrastructure protection. Federal efforts in 

the critical infrastructure protection arena emerged in July 1996, when 

President Clinton formed the President’s Commission on Critical 

Infrastructure Protection. This commission, which consisted of 

representatives of federal agencies, was tasked with assessing the 

vulnerabilities and threats to the nation’s critical infrastructures. For these 

purposes, “critical infrastructure” was defined to include infrastructures 

the incapacitation or destruction of which would debilitate the defense or 

economic security of the country. At the time, food and agriculture were 

not regarded as critical infrastructure sectors.24 

Presidential Decision Directive 63 outlined ways for the Executive Branch 

to enhance the protection of critical infrastructures. The directive assigned 

lead responsibilities for infrastructure sectors to particular federal 

agencies. For example, the Department of the Treasury was designated 

the lead agency for the banking and finance sector. Responsible agencies 

were, in turn, to help “swiftly eliminate any significant vulnerability to 

both physical and cyber attacks on our critical infrastructures.”25 

In addition, the directive envisioned a growing partnership between 

federal, state, and private sector entities to develop plans to defend against 

and recover from attacks on infrastructure.26 Presidential Decision 

22 Advisory Panel to Assess Domestic Response Capabilities for Terrorism Involving Weapons of Mass Destruction 

(Gilmore Commission), Fourth Annual Report to the President and Congress, December 15, 2002, p. 68. 23 Homeland Security Presidential Directive 9: Defense of United States Agriculture and Food, January 30, 2004, 

paragraph 4. 24 EO 13010: Critical Infrastructure Protection, July 15, 1996, paragraph 1. 25 Presidential Decision Directive 63: Critical Infrastructure Protection, May 18, 1998, Section 2. 26 Ibid., Section 4.

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Directive 63 sought to foster this partnership through the formation of 

Information Sharing and Analysis Centers (ISACs) – which were to serve 

as information exchange centers. 

As food and agriculture were not considered critical infrastructure sectors 

at the time, they did not receive direct attention under Presidential 

Decision Directive 63’s framework. Notwithstanding their absence from 

critical infrastructure discussions of the day, food and agriculture did 

formally register among White House national security considerations. 

The National Security Council’s Weapons of Mass Destruction 

Preparedness Group included a subgroup related to agriculture and food 

safety chaired by USDA.27 

These structures were in place at the time of the terrorist attacks of 

September 11, 2001. Soon thereafter, President Bush signed Executive 

Order 13231, modifying White House involvement in critical 

infrastructure protection activities. This Executive Order stressed the 

protection of information systems supporting critical infrastructures, 

forged a presidential critical infrastructure protection board with a number 

of specialized standing committees, and established a new infrastructure 

advisory council with membership drawn from the private sector, 

academia, and state and local government.28 

Heightened awareness of the hazards facing the food sector grew within 

the executive and legislative branches of the federal government following 

the September 2001 attacks. This awareness was reflected, in part, by the 

June 2002 passage of the Public Health Security and Bioterrorism 

Preparedness and Response Act of 2002 (Bioterrorism Act). The 

Bioterrorism Act called for increased controls on dangerous biological 

agents and toxins, and provided the FDA with more authorities to detect 

and respond to the possible adulteration of food products.29 

Awareness of these hazards also expanded as a result of the work of the 

Gilmore Commission. In its fourth annual report to Congress and the 

President, the Commission discussed its concerns about the readiness of 

the food and agriculture sectors in the event of a terrorist attack. After 

examining the readiness of these sectors, the Commission directed 6 of its 

27 Presidential Decision Directive 62: Protection Against Unconventional Threats to the Homeland and Americans 

Overseas, May 22, 1998. Noted in Advisory Panel to Assess Domestic Response Capabilities for Terrorism

Involving Weapons of Mass Destruction (Gilmore Commission), Fourth Annual Report to the President and 

Congress, December 15, 2002, pp. 69-70. 28 EO 13231: Critical Infrastructure Protection, October 16, 2001, Sections 1, 3, and 10. 29 21 U.S.C. §§ 331, 334, 335a, 341, 342, 343, 350, 374, 381, 398, and 399.

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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56 recommendations at improving terrorism preparedness and response for 

the food and agriculture sectors.30 

In July 2002, the White House Office of Homeland Security released a 

National Strategy for Homeland Security that elevated the national 

security standing of the food sector. Acknowledging possible “insider 

threats” to the food supply through food product tampering by employees 

in the processing and distribution system, the National Strategy for 

Homeland Security expanded the list of “critical” infrastructure sectors to 

include food and agriculture.31 

The February 2003, National Strategy for Physical Protection of Critical 

Infrastructure and Key Resources highlighted the possible exploitation of 

critical infrastructure to cause harm and disruption. Whereas past 

guidance on critical infrastructure protection stressed the risks associated 

with destroying or disabling critical infrastructures, this new strategy 

explicitly recognized the potential to exploit critical infrastructures to ill 

effect.32 This new recognition may have been the product of a painful 

lesson on September 11, 2001, a day on which commercial airlines were 

exploited to inflict damage beyond the aviation sector. Whatever its 

origins, this was an important acknowledgement for the food sector, as 

many experts regard the exploitation of the sector as of considerably 

greater concern than the destruction or disabling of its assets. 

DHS’ engagement in critical infrastructure protection efforts dates to its 

inception. The department’s enabling legislation, the Homeland Security 

Act,

33 transferred the infrastructure protection functions of the Federal 

Bureau of Investigation’s (FBI) National Infrastructure Protection Center 

and Department of Commerce’s Critical Infrastructure Assurance Office 

to DHS.34 In addition, the Homeland Security Act assigned DHS 

overarching responsibility for the following critical infrastructure 

protection activities: 

• Carrying out comprehensive assessments of the vulnerabilities of 

the nation’s critical infrastructures; 

30 Advisory Panel to Assess Domestic Response Capabilities for Terrorism Involving Weapons of Mass Destruction 

(Gilmore Commission), Fourth Annual Report to the President and Congress, December 15, 2002, p. viii. 31 Executive Office of the President, Office of Homeland Security, National Strategy for Homeland Security, 

July 2002, pp. 30, 34. 32 National Strategy for Physical Protection of Critical Infrastructure and Key Resources, February 2003, p. viii. 33 6 U.S.C. § 101 et seq. 34 6 U.S.C. § 121(g)(1) transferred most National Infrastructure Protection Center functions to DHS. The Critical

Infrastructure Assurance Office’s functions are transferred to DHS in § 121(g)(3). 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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• Integrating relevant information in order to identify priorities for 

protection and support measures undertaken by the public and 

private sectors; 

• Developing a comprehensive national plan for securing critical 

infrastructures; and, 

• Recommending measures necessary to protect critical 

infrastructures.35 

In crafting the Homeland Security Act, Congress also recognized the 

possible danger of foodborne terror. Section 308(b)(2) of the Homeland 

Security Act, 6 U.S.C. §188, required DHS to establish university-based 

centers of excellence in order to enhance the statutory mission of the new 

department. Congress set one criteria for the selection of Centers of 

Excellence as a “demonstrated expertise in food safety.” 

In December 2003, the White House issued the seventh in a series of 

Homeland Security Presidential Directives, often referred to as HSPDs, 

setting homeland security policy for the federal government. This policy 

directive, Homeland Security Presidential Directive 7, amended the model 

for interagency coordination on critical infrastructure protection originally 

set out in Presidential Decision Directive 63. Homeland Security 

Presidential Directive 7 modified the existing framework by identifying 

the DHS Secretary “as the principal [f]ederal official to lead, integrate, 

and coordinate implementation of efforts among [f]ederal departments and 

agencies, [s]tate and local governments, and the private sector to protect 

critical infrastructure and key resources.”36 It also designated SectorSpecific Agencies for each critical infrastructure sector responsible for 

working with DHS to augment security. The food sector is part of one of 

the 17 federally recognized critical infrastructure sectors. Homeland 

Security Presidential Directive 7 identified USDA and HHS as co-SectorSpecific Agencies for the food sector, making this the only sector with two 

Sector-Specific Agencies. A list of critical infrastructure sectors and 

corresponding Sector-Specific Agencies is presented in Appendix F. 

Homeland Security Presidential Directive 7 also stipulates that DHS is to 

“produce a comprehensive, integrated national plan” to protect critical 

infrastructures.37 In June 2006, DHS released a National Infrastructure 

Protection Plan (NIPP) consistent with this requirement. The NIPP 

describes missions, goals, and standards for protection of infrastructure 

35 6 U.S.C. §§ 121(d)(2), (3), (5), and (6). 36 Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization, and Protection, 

December 17, 2003, paragraph 12. 37 Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization, and Protection, 

December 17, 2003, paragraph 27. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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sectors, and expounds on the relationship between DHS and the SectorSpecific Agencies. 

Another primary source of executive branch food defense responsibilities 

is Homeland Security Presidential Directive 9, “Defense of United States 

Agriculture and Food,” which outlines the policy framework for the 

protection of the food supply. Issued in January 2004, Homeland Security 

Presidential Directive 9 set out numerous related requirements for DHS, 

USDA, and FDA, among other federal agencies. Homeland Security 

Presidential Directive 9 appointed DHS “responsible for coordinating the 

overall national effort” to protect the food and agriculture sectors, and 

designated the DHS Secretary as “the principal [f]ederal official to lead, 

integrate, and coordinate implementation of efforts” among federal, state, 

local, and private sector elements.38 Thus, a primary measure of DHS’ 

effectiveness in protecting the food sector is how well the department 

works with outside entities, especially its federal partners, to facilitate the 

improved security of the sector. 

Other pertinent presidential policy guidance, Homeland Security 

Presidential Directives 8 and 10, set forth national policy for preparedness 

and biodefense, respectively. Each accords DHS important related 

responsibilities. 

DHS Food Sector Responsibilities 

While the two primary sources of DHS’ food defense and critical 

infrastructure protection responsibilities are Homeland Security 

Presidential Directives 7 and 9, additional responsibilities are outlined in 

other Presidential Directives,39 the Homeland Security Act, USA PATRIOT 

Act, and strategic documents like the NIPP. These responsibilities can be 

viewed as existing along an incident timeline from prevention to 

preparedness and detection to recovery. 

38 Homeland Security Presidential Directive 9: Defense of United States Agriculture and Food, January 30, 2004, 

paragraph 6. 

39 Homeland Security Presidential Directive 8: Preparedness, Homeland Security Presidential Directive 9: Defense 

of United States Agriculture and Food, and Homeland Security Presidential Directive 10: Biodefense for the 21st 

Century also identify pre-response DHS food-sector responsibilities. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 13 
Detection 

Prevention 

Recovery Response Preparednes sProtection 

Figure 1. Review Focus Along Incident Timeline 

Incident 

Focus of this Review 

This review focused on DHS’ pre-response obligations to food sector 

defense and critical infrastructure protection. Pre-response activities are 

those that precede awareness that an incident has occurred. Accordingly, 

they exclude activities in the incident response and recovery process. 

DHS pre-response responsibilities in food defense and critical 

infrastructure protection can be grouped into eight categories: 

• critical infrastructure protection management and coordination 

• asset identification and sector mapping 

• information sharing, threat awareness, and warning 

• vulnerability assessment 

• consequence assessment and modeling 

• protective measures and prioritization 

• research and development 

• education, outreach, training, and preparedness 

Some of these responsibilities specifically identify the food sector as a 

focus of the department’s obligations. In many other cases, however, 

DHS’ responsibilities in the food sector derive from the industry’s 

standing as critical infrastructure. For more detail on these responsibilities 

and their statutory origins please consult Appendix G. 

Congress and the White House have instructed DHS to assume different 

roles in the execution of its food sector responsibilities. For some 

responsibilities, DHS is given primary or exclusive responsibility for a 

task. In other cases, the department is to work collaboratively with other 

federal departments to fulfill a shared responsibility. Finally, in some 

other instances, DHS’ responsibility is to serve in a supporting capacity. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 14 
Challenges Intrinsic to the Fulfillment of DHS’ Mandate 

DHS faces some noteworthy challenges in the pursuit of its food sector 

responsibilities. Many of these challenges arise from factors outside of the 

department’s control. 

One challenge stems from the sector’s absence from early critical 

infrastructure planning efforts. As discussed earlier, until 2002, executive 

directives on critical infrastructure protection did not acknowledge the 

food sector’s place among critical infrastructures. The Gilmore 

Commission attributed its observation that “relatively little action ha[d] 

been taken to address the threat” to food and agriculture due, in part, to the 

late acknowledgement of the sector as critical.40 Prior to 2002, strategies 

and approaches to critical infrastructure protection were developed 

without particular emphasis on or consideration of the food sector. This 

late start represents a hurdle in DHS’ efforts to fulfill its food defense and 

critical infrastructure protection responsibilities. 

An additional challenge relates to the fact that so much of the food 

industry is privately owned and outside of the department’s regulatory 

control. This restricts DHS’ familiarity with food industry operations, as 

well as its understanding of related threats, vulnerabilities, and 

consequences. DHS also has a limited ability to directly influence 

appropriate preparedness and mitigation actions. Vibrant cooperation and 

support between government and the private sector are needed to fully 

understand vulnerabilities, study possible consequences, prepare for 

threats, and implement mitigation measures. 

Another major challenge DHS faces is a product of the department’s 

pedigree. DHS was assembled from twenty-two pre-existing agencies and 

organizations. None of these organizations had a primary mission focus 

on post-harvest food products, though some had contact with the food 

industry. The closest contact any constituent group within DHS had with 

food products came through the import inspection process. Agricultural 

import inspectors, who transferred to DHS from USDA’s Animal and 

Plant Health Inspection Service, regularly inspected imported food 

products to determine whether they were host to animal or plant pests and 

pathogens that posed a threat to the nation’s pre-harvest agricultural and 

livestock production. Also, some customs inspectors had received crossdesignation as FDA inspectors, and other customs staff were engaged in 

the implementation of the Bioterrorism Act prior to DHS’ formation. In 

40 Advisory Panel to Assess Domestic Response Capabilities for Terrorism Involving Weapons of Mass Destruction 

(Gilmore Commission), Fourth Annual Report to the President and Congress, December 15, 2002, p. 69. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 15 
addition, the National Infrastructure Protection Center, which operated 

under the Department of Justice prior to the formation of DHS, had some 

engagement with food sector defense after the sector gained recognition as 

a critical infrastructure sector. Finally, the Federal Emergency 

Management Agency dealt with food products as they related to 

emergency response. Even in combination, these legacy engagements 

with the food sector were minor. Despite the limited familiarity DHS had 

with the food sector at the time of its formation, the department was 

assigned numerous important responsibilities in the area within a year of 

its establishment. 

In part because of DHS’ limited legacy expertise in the field, the 

successful execution of the department’s food defense and critical 

infrastructure protection responsibilities requires substantial coordination 

with public sector partners. Because numerous public sector entities 

regulate the food industry, the insights to be gained through partnerships 

with food industry regulators come with a significant coordination 

requirement. 

Thus, another challenge relates to the fragmentary nature of government 

food safety regulation and quality assurance activities. Within the federal 

government, primary responsibility for food safety rests with two agencies 

with distinct authorities and regulatory regimes, HHS’s FDA and the 

USDA’s Food Safety and Inspections Service. In addition to these two 

primary federal food regulators, at least seven other federal agencies 

provide some oversight of food processing, distribution, and retail.41 

Strung together by more than two dozen laws, the complex web of federal 

food oversight has been draped unevenly over the sector. Consequently, 

some foods are subject to considerably more intensive oversight than 

others. As the Government Accountability Office (GAO) has reported, 

USDA has historically outspent FDA in food safety activities despite the 

fact that it regulates approximately nine times fewer facilities. This 

imbalance in spending is also noteworthy considering that the food 

products USDA regulates account for almost four times less consumer 

spending, and are tied to about two times fewer foodborne illness 

outbreaks than those for which FDA is responsible.42 

41 USDA’s Grain Inspection, Packers and Stockyards Administration; USDA’s Agricultural Marketing Service; the 

Department of Commerce’s National Oceanic and Atmospheric Administration; the Environmental Protection 

Agency; the Federal Trade Commission; the Department of the Treasury’s Alcohol and Tobacco Tax and Trade 

Bureau; and DHS’ Customs and Border Protection. 42 Prepared Statement of Lawrence J. Dyckman, Government Accountability Office, Federal Food Safety and 

Security System – Fundamental Restructuring Is Needed to Address Fragmentation and Overlap, March 20, 2004, 

pp. 9-10. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 16 
Even where oversight is intensive, federal regulators can exercise only 

limited authority. Neither the Food Safety and Inspections Service nor 

FDA has the authority to issue mandatory food recalls, except in the case 

of infant formula. GAO reported that neither agency believes current food 

safety and inspection laws provide them with authority to fully regulate all 

aspects of food security. 

Added to the patchwork of federal food oversight is the work of state and 

local agriculture and public health departments, which also regulate the 

industry. As noted previously, state, territorial, and local governments 

oversee the safety of food retail and food service establishments within 

their jurisdictions. 

The enormity of the food sector and the complexity of government 

oversight pose substantial challenges to food defense and critical 

infrastructure protection. These challenges are compounded by the fact 

that some of the department’s obligations to the food sector are set out in 

guidance documents that are not clearly compatible. Homeland Security 

Presidential Directive 7, for example, focuses on terrorism threats, while 

other applicable presidential directives mandate that DHS protection and 

preparedness activities address all hazards, regardless of cause. 

Furthermore, it is sometimes difficult to translate activities across the 

different frameworks laid out in these directives. It is not easy, for 

example, to understand how preparedness activities conducted under 

Homeland Security Presidential Directive 8 support the critical 

infrastructure protection responsibilities established under Homeland 

Security Presidential Directive 7. Differences like these have helped set 

the stage for some of the difficulties in defining priorities and monitoring 

resource allocation discussed in the following sections. Appendix I 

provides more information on the interplay of the frameworks for 

infrastructure protection, national preparedness, and incident management 

as they apply to post-harvest food. 

Facing a complex and unfamiliar infrastructure sector with little legacy 

expertise, DHS has been invested with a range of responsibilities. Though 

numerous, these responsibilities represent only a fraction of the 

department’s overall commitments. While DHS must fulfill its food 

sector responsibilities, the department’s level of engagement and resource 

allocation to related activity should be shaped by a rational assessment of 

priorities. It is DHS’ stated policy to prioritize efforts in accordance with 

risk. As defined by the department, risk contains three elements: 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 17 
• Threat – the “intention and capability of an adversary to undertake 

actions that would be detrimental” to critical infrastructures;43 

• Vulnerability – a “weakness in the design, implementation, or 

operation of an asset or system that can be exploited by an 

adversary, or disrupted by a natural hazard or technological 

failure,”44 and 

• Consequence - the “result of a terrorist attack or other hazard that 

reflects the level, duration, and nature of the loss resulting from the 

incident.”45 

Determining how the three elements apply to the food sector is a 

challenging task. Mapping this assessment onto judgments about risk in 

other areas of DHS responsibility and developing risk-driven priorities is a 

profoundly difficult undertaking. 

Results of Review 

DHS’ Internal Coordination of Food Sector Activities 

Several organizational units in the department carry out DHS food-sectorrelated activities. The supervision of these activities is distributed across 

several managers in these units. This divided leadership arrangement has 

produced similar programming across different components and has not 

provided the level of internal coordination required. The internal 

coordination that has occurred has been performed on an inconsistent 

basis. As a result, opportunities to leverage information from one program 

in support of another have been missed. Coordination across DHS food 

sector programming can be improved through focused, consolidated 

leadership attention, with responsibility assigned to a single senior staff 

official. 

Distribution of DHS Food Sector Activities 

DHS is not organized to address its food sector responsibilities in a 

consolidated way. These responsibilities are distributed across multiple 

DHS units. This is the result of the interplay of DHS’ organizational 

structure and the responsibilities themselves. 

43 DHS, NIPP, June 30, 2006, p. 105. 44 Ibid. 45 Ibid., p. 103. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 18 
As presently structured, DHS has four directorates, seven agencies, fifteen 

major offices, and a center. These organizational elements are structured 

to address missions like improving the nation’s all-hazards preparedness 

and securing the border while facilitating the legitimate flow of trade. 

There is no major organizational entity within DHS that is focused 

exclusively or even largely on the execution of DHS responsibilities in the 

food sector. 

Drawn from several statutes, the department’s food sector responsibilities 

are broad-based. These responsibilities extend from the monitoring of 

sector infrastructure protection progress to the development of 

countermeasures, and from asset identification to consequence modeling. 

Under DHS’ current organization, the functional expertise required to 

fulfill these responsibilities is distributed across several organizational 

units. 

Efforts to operationalize these responsibilities are also distributed widely 

across DHS. Many of these efforts are undertaken in units of DHS’ 

Preparedness Directorate. Two divisions in its Office of Infrastructure 

Protection – the Infrastructure Partnerships Division and Risk 

Management Division – conduct food sector critical infrastructure 

protection activities. Another major office within the Preparedness 

Directorate, the Office of Grants and Training, funds curriculum 

development, education, outreach, exercises, and planning to prepare for 

hazards to the food sector. A third unit, the Office of the Chief Medical 

Officer manages a data system that integrates foodborne illness 

information, among other related activities. Food defense and critical 

infrastructure protection activities are also conducted and sponsored by the 

Science and Technology (S&T) Directorate. S&T supports related 

research, education, and analysis through its Office of Research and 

Development, Biological Countermeasures Portfolio, and Homeland 

Security Advanced Research Projects Agency. Finally, Customs and 

Border Protection (CBP) has contact with food defense issues through its 

efforts to enforce federal commercial importation laws and secure the 

nation’s borders. 

DHS operates a number of programs and initiatives with food defense and 

critical infrastructure protection features. Related programs and activities 

are arrayed across the five different DHS organizational entities discussed 

above: the Office of Infrastructure Protection, Office of Grants and 

Training, Office of the Chief Medical Officer, S&T, and CBP. The 

following table illustrates the placement of DHS food-related programs 

and initiatives within each of these five DHS units. For more information 

on DHS food-sector-related programs and initiatives refer to Appendix H. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 19 
DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 20 
Table 1. DHS Food Defense and Critical Infrastructure Protection 

Activities and Initiatives 

DHS Activities and Initiatives with Food Defense Applications 

Office of Infrastructure Protection 

Food & Agriculture Government Coordinating Council 

Food & Agriculture Sector Coordinating Council support 

Homeland Security Information Network - Food & Agriculture Portal 

National Infrastructure Coordination Center 

Homeland Infrastructure Threat and Risk Analysis Center 

Protected Critical Infrastructure Information program 

DHS Educational Reports 

Site Assistance Visits 

Buffer Zone Plans* 

Strategic Partnership Program for Agroterrorism support 

National Asset Database 

National Infrastructure Simulation and Analysis Center 

Office of Grants and Training 

Multi-State Partnership for Security in Agriculture support 

University of California - Davis (UC Davis) training support 

University of Tennessee vulnerability assessment training support 

Lousiana State University agroterrorism course development 

Exercise support 

State Homeland Security Program 

Office of the Chief Medical Officer 

National Biosurveillance Information System** 

Science and Technology Directorate (S&T) 

National Center for Food Protection and Defense (NCFPD) 

Food Biological Agent Detection Sensor 

National Biodefense Analysis and Countermeasures Center research 

University of Kentucky tracking system 

Critical Infrastructure Protection Decision Support System 

Customs and Border Protection (CBP) 

Notification and Targeting Support 

* Buffer Zone Plans are products of the Buffer Zone Protection Program, a joint effort between the 

Office of Infrastructure Protection and Office of Grants & Training. 

** Management of the National Biosurveillance Integration System transferred from the Office of 

Infrastructure Protection to the Office of the Chief Medical Officer on September 1, 2006. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 21 
DHS programs and initiatives that support food defense and critical 

infrastructure protection also frequently support other efforts. Some DHS 

programs that apply to the food sector serve critical infrastructure 

protection efforts at large, and only engage the food sector to a limited 

degree. Other DHS programs and initiatives address both pre-harvest and 

post-harvest elements of the food supply chain. The level of attention and 

focus these programs and initiatives place on food defense and critical 

infrastructure protection, in particular, varies considerably. Only 3 of the 

25 programs and initiatives listed in the table focus primarily or 

exclusively on post-harvest food defense and critical infrastructure 

protection – the National Center for Food Protection and Defense, the 

Food Biological Agent Detection Sensor, and University of Kentucky 

tracking system. 

Management of DHS Food Sector Activities 

The management of DHS’ food-sector-related activities is as dispersed as 

the activities themselves. At the time of our fieldwork, no single senior 

manager or official in DHS was dedicated to monitoring or overseeing all 

of the department’s food sector activities. Rather, responsibility for 

executing these activities rested with managers across the five DHS 

components discussed above. 

Nested within separate DHS units, program managers for food-sectorrelated efforts had limited information about activities in other parts of 

DHS. As a result, they were not able to easily identify areas in which 

coordination would have been beneficial. Because these program 

managers had restricted insight into the related activities of other 

departmental components, they sometimes executed and supported foodsector-related activities without an appropriate level of internal 

coordination. 

This dynamic was evident in initiatives funded by the Office of Grants and 

Training and S&T. Grants and Training and S&T did not collaborate with 

each other in the development of grant guidance and requirements or in 

the review of grant applications. Just as the Grants and Training did not 

involve S&T in the development of education, training and outreach 

programs at the outset, S&T did not involve Grants and Training in the 

development of its Broad Agency Announcement for its food protection 

and defense Center of Excellence. 

The shortage of advance communication and coordination contributed, in 

part, to the propagation of similar projects and initiatives. Common 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 22 
program thrusts emerged in the areas of communication; education, 

training, and exercises; threat agent studies; and sector modeling and 

consequence assessment. 

Many of these common program thrusts evolved at the S&T-sponsored 

National Center for Food Protection and Defense (NCFPD), which has 

pursued a broad base of food-related work. The NCFPD, based at the 

University of Minnesota, is a university-based Homeland Security Center 

of Excellence. As of September 2006, the NCFPD had 39 active research 

projects involving 83 students, including 9 post-doctoral and 56 graduate 

students. 

Initiatives similar to the work conducted by the NCFPD have been 

sponsored by Grants and Training under the Homeland Security Exercise 

and Evaluation Program, the Multi-State Partnership for Security in 

Agriculture, as well as through the University of California at Davis 

(UC Davis), the University of Tennessee, and Louisiana State University. 

Programs that S&T has funded that perform work similar to that of the 

NCFPD include the Food Biological Agent Detection Sensor, and the 

National Biodefense Analysis and Countermeasures Center. Other 

parallel efforts are underway at the national laboratories under the 

auspices of Office of Infrastructure Protection- and S&T-supported 

programs, the National Infrastructure Simulation and Analysis Center and 

Critical Infrastructure Protection Decision Support System, respectively. 

Communication Initiatives 

Several projects funded by Grants and Training and S&T, such as risk 

communication initiatives and website and database development 

activities, support initiatives to improve food sector communication and 

information sharing. 

The NCFPD, the Multi-State Partnership, and UC Davis each have foodrelated risk communication projects that seek to build the capability to 

educate planners, first responders, and the public about the risks of an 

attack on the food supply. The NCFPD’s risk communication program 

focuses on the development and delivery of training modules and visual 

aids to convey messages on food-related incidents. The Multi-State 

Partnership’s risk communication initiatives target key personnel involved 

in conveying messages to the public during and after a bioterrorism event. 

Like the NCFPD, it has conducted risk communication training and 

developed risk communications products for food-related incidents. 

UC Davis offers a course on risk communication. Its objective is to 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 23 
prepare first responders to communicate with the public after an 

intentional attack on the food sector. 

S&T and Grants and Training also fund parallel website and database 

development efforts. The NCFPD, UC Davis, and the National 

Biodefense Analysis and Countermeasures Center each support websites 

or databases that currently host or will host information on threats, 

vulnerabilities, consequences, and protective measures that relate to 

biological or chemical agents that can be introduced into the food supply. 

A separate set of similar websites and databases are under development by 

the Multi-State Partnership and the Homeland Security Exercise and 

Evaluation Program. The Multi-State Partnership and Homeland Security 

Exercise and Evaluation Program both sponsor website and database 

development efforts that will support information on exercises, exercise 

methodologies, and best practices. 

Education, Training, and Exercises 

The NCFPD, and Grants and Training-supported programs at the MultiState Partnership, UC Davis, the University of Tennessee, and Louisiana 

State University are all involved in the development, delivery, and 

evaluation of courses and exercises in the realm of food protection and 

defense. 

The NCFPD, the Multi-State Partnership, UC Davis, the University of 

Tennessee, and Louisiana State University have educational programs on 

planning for and responding to food-related bioterror attacks, and provide 

information on assessing vulnerabilities and developing protective 

measures for the food sector. All of these programs target, at least in part, 

the first responder community. 

Currently, the Homeland Security Exercise and Evaluation Program, the 

Multi-State Partnership, and UC Davis are all directly engaged in the 

development and delivery of exercises and the subsequent provision of 

lessons learned and best practices to the food sector. Grants and Training 

has directly supported four food contamination exercises since DHS was 

established. Recently, six states participated in a Multi-State Partnershipfacilitated exercise designed to identify the strengths and weaknesses of 

current information sharing systems. Further, the Multi-State Partnership 

is involved in assessing training and exercises, and inventorying food 

emergency response exercises. Although UC Davis does not have as 

extensive an exercise program, it has integrated tabletop exercises into its 

educational curriculum. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 24 
Threat Agent Studies 

The NCFPD, National BioDefense Analysis and Countermeasures Center, 

and Food Biological Agent Detection Sensor programs have projects that 

support threat agent identification and detection in food matrices. The 

detection and identification of agents in foods (food matrices) poses 

significant challenges. Unlike pure lab samples of threat agents, food 

matrices contaminated with threat agents contain substances that can help 

the agent multiply, mask its presence, or generally undermine the 

effectiveness of detection techniques that are reliable in other settings. 

Food products contain a range of substances and have varied 

consistencies, factors that confound efforts to apply any single detection 

technique widely. Also, threat agents may be unevenly distributed in 

foods, so identifying appropriate sampling procedures represents another 

challenge. 

The NCFPD’s detection and diagnostics projects focus on developing 

rapid and accurate methods for detecting biological and chemical agents in 

food products and enabling efficient monitoring and testing in a range of 

production, processing, and retail settings. The Biological Threat 

Characterization Center at the National BioDefense Analysis and 

Countermeasures Center pursues some similar work, and has 

comparatively tested laboratory test technique and protocols for detecting 

threat agents in one food matrix. Finally, S&T is sponsoring the 

development of rapid, portable technology to detect select agents in liquid 

food matrices under its Food Biological Agent Detection Sensor 

46 program.

Both the NCFPD and National BioDefense Analysis and Countermeasures 

Center support research on agent viability in food matrices. The NCFPD’s 

work relates to the deactivation of threat agents, while the 

Countermeasures Center effort is centered on the study of agent 

survivability in different food matrices. 

Sector Modeling and Consequence Assessment 

DHS has pursued food sector modeling efforts through the NCFPD, the 

Critical Infrastructure Protection Decision Support System, and the 

National Infrastructure Simulation and Analysis Center. The NCFPD has 

developed a food contamination event modeling tool that can be used 

46 Pursuant to Section 201 of the Bioterrorism Act (P.L. 107-188), codified at 42 U.S.C. § 262a, CDC has identified 

41 “select agents” that pose a threat to human health and safety. CDC lists toxins, bacteria, fungi, and viruses 

among select agents affecting human health. (http://www.cdc.gov/od/sap/docs/salist.pdf). 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 25 
Program Areas

track the effect of hypothetical food contamination events. The NCFPD 

system models the distribution and consumption of the food product, 

resulting illnesses, public health system contacts, and response. The 

Critical Infrastructure Protection Decision Support System has assembled 

a more limited capability in this area by assembling a model for the supply 

chain for a single food commodity. The National Infrastructure 

Simulation and Analysis Center is also developing a model for a portion of 

the food supply chain – the dairy industry. 

Table 2. Areas of Shared DHS Food Defense and Critical Infrastructure Protection 

Program Thrust 

IP 

Areas of Common Program Thrust 

S&T G&T 

NCFPD 

NBACC 

FBADS 

CIP-DSS 

UC Davis 

MSP 

U. Tenn. 

LSU 

HSEEP 

NISAC

Program Areas 

3⁄4 Risk communication 3 3 3 

3⁄4 Websites & Databases 3 3 3 3 

3⁄4 Education 3 3 3 3 3 

3⁄4 Training & Exercises 3 3 3 

3⁄4 Agent Detection & ID 3 3 3 

3⁄4 Agent Viability 3 3 

3⁄4 Modeling Activities 3 3 3 

Communication 

Education, Training & Exercises 

Threat Agent Studies 

Sector Modeling & Consequence Assessment 

G&T – Office of Grants and Training; IP – Office of Infrastructure Protection; NCFPD – National Center for Food Protection and 

Defense; NBACC – National Biodefense Analysis and Countermeasures Center; FBADS – Food Biological Agent Detection 

Sensor; CIP-DSS – Critical Infrastructure Protection Decision Support System; MSP – Multi-State Partnership for Security in 

Agriculture; LSU – Louisiana State University; HSEEP – Homeland Security Exercise and Evaluation Program; NISAC – National 

Infrastructure Simulation and Analysis Center 

The common program thrusts that have arisen need not result in waste. 

Indeed, while many of the programs developing under these common 

thrusts are similar, several are complementary. Provided adequate 

coordination, programs with common thrusts can fruitfully contribute to 

one another’s work and advance the DHS mission. Shared program 

thrusts present many opportunities to leverage information and improve 

final products. However, a management regime is not in place to ensure 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 26 
that this coordination occurs as needed. As a result, the internal 

coordination of these efforts has often taken place after programs were 

already funded or in progress. 

Some efforts to coordinate across existing programs have resulted from 

DHS staff improvisation. Although DHS staff in the different directorates 

were not initially aware of other DHS food-related activities, they sought 

to coordinate efforts when they encountered similar programs elsewhere in 

the department. 

After the White House issued Homeland Security Presidential Directive 9, 

DHS program staff from around the department converged to discuss ways 

for the department to address its related responsibilities. Affected 

program staff initially met on a monthly basis. While these Homeland 

Security Presidential Directive 9 sessions ultimately waned, they did 

increase awareness that similar programming was occurring in different 

parts of the department. This awareness prompted Office of Grants and 

Training staff to establish a forum for collaborating on food-related 

research projects. Grants and Training staff forged an Agroterrorism 

Training Working Group in late 2004 and invited S&T and Office of 

Infrastructure Protection staff to its sessions. 

Recently, contacts among the program staff overseeing DHS’ food sector 

activities intensified through exchanges on avian influenza. Several key 

participants in the Homeland Security Presidential Directive 9 sessions 

reportedly reconvened to support coordination on pandemic influenza 

preparedness, and new linkages between the Office of Infrastructure 

Protection and CBP have developed as well. 

Continuing collaboration through the Agroterrorism Training Working 

Group and on avian influenza, however, have not provided the level of 

cross-program coordination required. In several instances, coordination 

across DHS programs occurred as a result of outreach efforts by the 

institutions performing DHS-sponsored work. Sometimes, this 

coordination took place without DHS staff involvement. Had these 

institutions not determined how their efforts would best complement one 

another, we believe that resources would have been expended in redundant 

efforts. 

The NCFPD’s efforts to collaborate across DHS programs provide a good 

illustration of this dynamic. DHS provided inadequate liaison support to 

the NCFPD. When we visited the NCFPD in December 2005, staff 

reported difficulties accessing information and personnel from DHS 

programs outside of S&T’s University Programs group. At the time, 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 27 
NCFPD was not familiar with important DHS programs involved in food 

sector protection work, including DHS-funded work being done by other 

entities. 

In September 2006, S&T reported that it was “taking steps to increase the 

staff devoted to improving coordination” with the NCFPD. But even 

before the NCFPD had received appropriate DHS liaison support, it had 

established contacts with the National Labs. NCFPD representatives were 

able to share information on related modeling efforts under the Critical 

Infrastructure Protection Decision Support System program and are now 

in the early stages of planning future collaboration in this area. 

The NCFPD also formed relationships with DHS-sponsored food-related 

initiatives at the Multi-State Partnership and UC Davis and without the 

department’s assistance. As a result, the three institutions have 

participated in one another’s events and have shared information on 

research findings and best practices. The NCFPD has fostered numerous 

linkages with these organizations, and in one instance, brought in the 

Multi-State Partnership to participate in a panel discussion on a postharvest food contamination scenario. 

Coordination at the project level is not the exclusive domain of the 

NCFPD – other DHS-supported grant recipients have taken steps to 

accommodate other DHS programs. The Multi-State Partnership, for 

example, initially had plans to conduct vulnerability assessments and 

vulnerability assessment training, but elected to forgo its independent 

efforts and work through the Strategic Partnership Program Agroterrorism 

initiative. Both programs are now working together to increase its 

members’ knowledge and understanding of vulnerability assessments. In 

these cases, however, it was the grant recipient, rather than DHS, that 

sought out and initiated coordination with allied programs. 

Despite recent efforts to coordinate at the program and project level, some 

limited duplication of effort has occurred. Common thrusts in the Food 

Biological Agent Detection Sensor program and at the NCFPD have 

converged to the point that they focus on identical research objectives. 

Without advance coordination, the Food Biological Agent Detection 

Sensor program and NCFPD both independently embarked on research 

initiatives to develop rapid testing platforms to detect the same select 

agents in the same food matrix. In one case related to the detection of one 

Clostridium botulinum in a particular food matrix, Food Biological Agent 

Detection Sensor program and NCFPD testing platforms target detection 

at different points in the production cycle, and might complement one 

another. Food Biological Agent Detection Sensor program and NCFPD 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 28 
testing platform development efforts related to the detection of Bacillus 

anthracis in the same food matrix, however, appear to be competing 

approaches to the same problem. It is important to note, however, that 

while these efforts have duplicative aims, and thereby focus on the same 

research objective, they are not identical. Both the specific technical 

approaches underlying these platform development efforts, as well as their 

timelines for completion, differ. 

Need for Consolidated DHS Food Sector Leadership 

The department’s support for common program thrusts creates a 

continuing need for thoughtful management attention and oversight of 

related efforts. 

The limited leadership attention to food defense and critical infrastructure 

protection is so pronounced that several key DHS staff could not identify a 

senior DHS official responsible for Homeland Security Presidential 

Directive 9 implementation. One DHS employee advised us that a single 

DHS contractor was responsible for tracking and monitoring the 

department’s efforts to implement Homeland Security Presidential 

Directive 9 responsibilities. 

Some government officials we spoke with suggested that the DHS Chief 

Medical Officer was best positioned to assemble a unified effort on food 

defense and critical infrastructure protection. Indeed, the Chief Medical 

Officer’s primary functions include the coordination of DHS’ biodefense 

activities, and service as the principal DHS liaison with HHS and USDA. 

Office of the Chief Medical Officer staff we interviewed interpret these 

functions to include coordination of DHS’ implementation of Homeland 

Security Presidential Directives 9 and 10, and in recent testimony the 

Under Secretary for Preparedness added that the Chief Medical Officer 

was responsible for the coordination of “activities to prevent and mitigate 

biologically-based attacks on ... our food supply.”47 

Despite these assertions of Chief Medical Officer responsibilities in this 

area, the Chief Medical Officer has not been given explicit authority to 

accomplish coordination and oversight of all DHS food defense and 

critical infrastructure protection activities. The Chief Medical Officer 

does not have formal authority to direct the work of other DHS offices and 

47 Statement of George Foresman, DHS Under Secretary for Preparedness, before the U.S. House of 

Representatives, Committee on Homeland Security, Subcommittee on Emergency Preparedness, Science and 

Technology, March 8, 2006. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 29 
these DHS offices are subject to no specific requirement to support the 

Chief Medical Officer’s efforts. Moreover, at present, the Chief Medical 

Officer does not have adequate staff support to discharge this 

responsibility. Within the Office of the Chief Medical Officer, 

coordination of DHS food-related biodefense activities falls under the 

purview of the Science, Policy, and Biodefense Division. This division is 

also tasked with coordinating and integrating DHS’ biodefense portfolio, 

developing policy and procedures for specific threats, and improving 

international medical coordination. Yet, as of June 2006, it had only two 

staff. 

Effective implementation of DHS’ food sector responsibilities requires 

focused, consolidated leadership attention to preside over internal 

coordination efforts. This leadership attention can help lend clarity to 

decisions on prioritizing resources and maintain an overall picture of 

implementation of DHS food sector responsibilities. If the Chief Medical 

Officer is to perform this function and do so effectively, he or she will 

require more clear authorities and additional qualified staff. 

To address the internal coordination requirement associated with DHS’ 

food sector activities more effectively, we recommend that the Under 

Secretary for Preparedness, in conjunction with the Under Secretary for 

Science and Technology: 

Recommendation #1: Identify a single senior DHS official to be 

accountable for coordinated implementation of all DHS food sector 

responsibilities, and provide this official with clear authorities and 

adequate staffing to perform this function. 

Public and Private Partners 

External coordination is essential for DHS to succeed in executing its 

responsibilities for food defense and critical infrastructure protection. 

Relationships with food sector partners are important because of the 

operational control and regulatory sway that they have with the sector. 

Related input from public and private sector partners is particularly 

valuable in light of DHS’ limited food sector experience. Partnerships 

with governmental entities are also vital because DHS shares so many 

food sector responsibilities. 

DHS’ interaction with public and private sector partners will shape the 

level of engagement and support that these groups provide the department 

in executing its food-related responsibilities. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 30 
Sector Governance and Information Sharing 

Status of the Food ISAC 

Coordination among federal agencies and the private sector on food 

defense and critical infrastructure protection issues predates DHS. Before 

DHS became operational, the FBI’s National Infrastructure Protection 

Center became involved in the formation of a private sector Information 

Sharing and Analysis Center for the food industry. A product of the 

infrastructure protection framework outlined in Presidential Decision 

Directive 63, ISACs were to “serve as the mechanism for gathering, 

analyzing, appropriately sanitizing and disseminating private sector 

information” to both industry and the government. ISACs were also 

envisioned as providing a means to disseminate select government 

information to the private sector.

48 

The Food ISAC was established in February 2002, as a direct outgrowth 

of an agreement between the National Infrastructure Protection Center and 

the Food Marketing Institute. At the time, the National Infrastructure 

Protection Center Director noted that Food Marketing Institute was a 

natural leader of the ISAC because of its ability to represent the sector and 

disseminate information to a wide audience.49 

Declared the “focal point for gathering information on threats” to domestic 

infrastructures, the National Infrastructure Protection Center integrated a 

representative of the Food ISAC into its operations – providing the new 

ISAC a seat at the table alongside members of the intelligence 

community.50 According to industry representatives, the Food ISAC 

distributed some useful threat and vulnerability information to food 

industry associations and firms in 2002 and early 2003. 

By mid 2003, however, DHS’ Office of Infrastructure Protection had 

concluded that, as implemented, the Food ISAC was not well-suited to 

serve the department’s full range of information sharing and analysis 

objectives. The Office of Infrastructure Protection contended that the 

Food Marketing Institute’s ISAC did not reach a sector-wide audience, 

and one DHS manager said that the ISAC’s connection to the Food 

Marketing Institute could produce “constant battles” between the Food 

Marketing Institute and other food sector associations. The Office of 

Infrastructure Protection also expressed concern that the Food ISAC was 

48 Presidential Decision Directive 63: Critical Infrastructure Protection, May 18, 1998. Section IX, Annex A. 

49 http://www.fmi.org/media/mediatext.cfm?id=390 50 Ibid. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 31 
not performing analytical work – a major ISAC responsibility. Rather, the 

Food Marketing Institute was simply passing news items and government 

information to its membership. The Office of Infrastructure Protection 

sought to develop a new structure to serve its vision for information 

sharing and analysis better. 

In August 2003, Office of Infrastructure Protection managers assembled 

more than 200 food and agriculture sector representatives to discuss the 

department’s vision for information sharing and coordination. According 

to the Office of Infrastructure Protection, the assembled sector 

representatives were then given the opportunity to develop a new 

organizational structure. Two bodies emerged from this DHS-facilitated 

process – the Food and Agriculture Government Coordinating Council and 

the Food and Agriculture Sector Coordinating Council. 

DHS leaders proclaimed the resulting “self-organization” of the food and 

agriculture sectors a national model.51 The Government Coordinating 

Council, which draws on representatives from government at all levels, 

including federal departments other than the Sector-Specific Agencies, is 

responsible for coordinating the food sector’s security activities, policy, 

and communication across layers of government and the private sector. 

The Sector Coordinating Council consists of private sector representatives 

from various parts of the food and agriculture sectors. Due to the size of 

the food and agriculture sectors and the diversity of enterprises active 

within them, the Sector Coordinating Council is divided into seven 

subcouncils. While working either independently or with the Government 

Coordinating Council, the Sector Coordinating Council’s mission is to 

provide DHS and the Sector Specific Agencies a private sector perspective 

on food and agriculture defense. 

DHS sought to apply a new suite of information sharing and analysis 

initiatives to the new organizational structure. DHS offered these tools to 

the sector to help address the limitations it perceived in the Food ISAC’s 

operations. One of these new tools, the Homeland Security Information 

Network Food and Agriculture portal, is specific to the sector. Three other 

entities, the National Infrastructure Coordinating Center, the Homeland 

Infrastructure Threat and Risk Analysis Center, and Protected Critical 

Infrastructure Information Program, address all infrastructure sectors. 

Although we encountered little criticism of the composition of Sector 

Coordinating Council and Government Coordinating Council structures 

51 National Pork Producers Council, Capital Update, Vol. 4, Issue 14, April 29, 2005. 

(http://www.nppc.org/wm/show.php?id=443&c=3) 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 32 
that emerged from this process, the Food Marketing Institute said that the 

reorganization effort resulted in lost time and only produced a marginal 

return. With more than 50 member associations, the Food Marketing 

Institute asserted that the Food ISAC was able to reach a large proportion 

of the sector. Instead of building upon this existing information sharing 

initiative, the Food Marketing Institute maintained that DHS chose “to 

burn the ISAC and salt the earth.” From the Food Marketing Institute’s 

perspective, the department’s decision to restructure private sector 

engagement with the government needlessly set back food sector 

infrastructure protection efforts. 

In July 2004, the National Infrastructure Advisory Council – a joint public 

and private sector body charged with advising the President and DHS 

Secretary – recommended that government, "assist the ISACs in 

delivering basic alerts and advisories to their sectors" and seek to increase 

the volume and dissemination of alerts and advisories.52 The evolution of 

government engagement with the Food ISAC has not developed in line 

with the National Infrastructure Advisory Council recommendation. 

Rather than assisting the ISAC in delivering alerts and advisories, DHS 

has essentially kept the ISAC from such a role. With the transfer of the 

National Infrastructure Protection Center to DHS, the Food ISAC lost 

ready access to sanitized government information that it had been able to 

disseminate to ISAC members in the past. By spring 2006, the Food 

ISAC’s contact with the government had deteriorated to the extent that, 

according to the ISAC, it did not have a dedicated DHS point of contact. 

This has contributed to a decline in the volume and scope of information 

disseminated to industry by the ISAC. Industry representatives reported 

that the flow of information from the ISAC to the private sector had 

declined, and that this decline had not been offset by increased 

information flow from other sources. 

Interestingly, the Sector Coordinating Council is not very distinct from the 

ISAC in terms of industry representation. The Sector Coordinating 

Council, for the most part, has the same industry participants as the ISAC. 

Four Sector Coordinating Council subcouncils represent the post-harvest 

elements of the food supply chain. As of February 2006, nine of the 

twelve members representing these post-harvest subcouncils on the Sector 

Coordinating Council were on the Food ISAC’s membership list. One of 

the three not included in this group is a member of an association that is 

part of the ISAC. The similarity of the Sector Coordinating Council to the 

Food ISAC is echoed on the pre-harvest side. Five of the nine 

52 National Infrastructure Advisory Council, Evaluation and Enhancement of Information Sharing and Analysis, July 

13, 2004, p. 12. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 33 
organizations on the three pre-harvest Food and Agriculture Sector 

Coordinating Council subcouncils were also members of the Food ISAC. 

Thus, the Sector Coordinating Council only scarcely expanded industry 

representation beyond the Food ISAC’s membership. Though structured 

distinctly, the Sector Coordinating Council has essentially the same 

constituent parts as the ISAC, including the Food Marketing Institute. 

While the Food ISAC was operating with a representative membership 

and board in August 2003 when DHS moved to reorganize the sector, the 

first session of the Sector Coordinating Council did not take place for 

another ten months, in June 2004. These modest readjustments were 

accompanied by a hiatus in activity lasting nearly a year. 

In contrast to DHS’ concern that the ISAC’s affiliation with one food 

industry association may trigger conflicts or disadvantage others, industry 

representatives we spoke with evinced no apprehension on this front. 

Rather, some expressed puzzlement over DHS’ decision to “orphan” the 

Food ISAC. Experts outside of the Food Marketing Institute, including 

other original members of the Sector Coordinating Council, shared this 

sentiment. 

DHS’ diminished engagement with the Food ISAC contributed to its 

decline. An expression of the moribund nature of the Food ISAC is its 

absence from the ISAC Council, a group of ISACs designed to improve 

information sharing linkages across sectors. Sustained by the continued 

involvement of 12 ISACs, the Council seeks to improve national 

infrastructure protection “by establishing and maintaining a framework for 

valuable interaction between and among the ISACs and with 

government.”53 The food sector could be missing valuable partnership 

opportunities because it does not have a representative on the ISAC 

Council. DHS notes, for example, that the Sector Coordinating Council 

Chairs are working with the ISAC Council “to determine and implement 

information sharing requirements” for each sector. The absence of the 

Food ISAC from the ISAC Council is likely to diminish the value of this 

effort for the food sector. 

Instead of drawing on the food industry’s post-9/11 momentum on critical 

infrastructure protection efforts, DHS effectively alienated the ISAC’s 

leadership and disengaged from its operations. Meanwhile, as we discuss 

later, the coordination and information sharing mechanisms DHS 

53 http://www.isaccouncil.org/about/ 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 34 
instituted to address the ISAC’s limitations have been slow to develop and 

are only partially successful. 

DHS should leverage more effectively the Food ISAC’s information 

dissemination capabilities in keeping with the National Infrastructure 

Advisory Council’s vision for DHS engagement with ISACs. This can be 

accomplished without altering the current state of sector governance. 

We recommend that the Assistant Secretary for Infrastructure Protection: 

Recommendation #2: Restore communication with the Food ISAC by 

re-establishing a DHS point of contact and creating food-industry-specific 

products for ISAC distribution. 

A New Framework for Coordination 

Notable limitations in partnership efforts surfaced after the waning of the 

ISAC. The current and former Government Coordinating Council and 

Sector Coordinating Council members we interviewed almost uniformly 

agreed that these councils originally did not have a coherent focus and a 

true sense of partnership. Notwithstanding their concerns about the startup of these bodies, most government and industry representatives we 

spoke with were optimistic about the future of the Government 

Coordinating Council and Sector Coordinating Council. And no one we 

interviewed said that the councils should be abandoned. DHS’ official 

view of the status and operations of the Government Coordinating Council 

and Sector Coordinating Council is favorable. A December 2005, Office 

of Infrastructure Protection report card for the food and agriculture sector 

gives it top ratings for all seven governance metrics. 

Participants in the two councils said that they saw the councils as “still 

evolving” and “in flux.” Whether in private or public capacities, council 

members noted the need to show the employers they represent a “tangible 

benefit” of their Government Coordinating Council or Sector Coordinating 

Council participation. Yet early meetings reportedly were poorly 

organized and inefficient. For several months, basic organizational issues 

consumed the work of the two councils; meetings had little substantive 

content and stimulated minimal discussion. 

Past and present council members attributed this sluggish start to DHS. 

They reported that DHS had taken a “top-driven” approach to its critical 

infrastructure protection leadership role, and that this detracted from the 

vitality of the councils and sapped the cooperative spirit from the process. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 35 
This approach reportedly created a difficult environment for the growth of 

collaborative efforts and did little to foster productive working 

relationships with industry leaders and government experts. Several 

council participants we interviewed said that DHS needed further growth 

as a business partner. 

Early Sector Coordinating Council and Government Coordinating Council 

meetings did not foster efforts to formulate policy, and when DHS 

solicited the ideas and recommendations of council members on policy 

matters, the solicitation process was sometimes regarded as flawed. One 

limiting factor for policy development during meetings was a shortage of 

time to comment on draft documents. Some Sector Coordinating Council 

members reported that their association members generally did not 

comment on DHS drafts because they were provided insufficient time to 

do so. This made it hard for food associations to communicate their 

members’ concerns. DHS may have thus lost out on important insights 

from major components of the nation’s food sector. 

Participation in the development of key policy documents can serve as an 

important means of exchange with external partners. DHS engaged the 

Sector Coordinating Council and Government Coordinating Council to 

comment on the NIPP, the document that articulates national policy for 

protecting all critical infrastructures. The NIPP passed through many 

iterations. A NIPP Draft Base Plan was released on September 15, 2004, 

followed by an Interim NIPP, which was completed in February 2005. A 

Draft NIPP followed in November 2005. The final NIPP was published 

in June 2006. 

DHS coordination efforts surrounding the NIPP did not proceed smoothly. 

A common frustration among sector participants we interviewed was that 

they never learned how or whether their comments were applied to 

subsequent drafts of the NIPP. This led more than one council member to 

question the value of time spent reviewing DHS policy documents. Other 

representatives complained that they were provided insufficient time to 

comment. Some felt that they received little in return for their extensive 

engagement. 

USDA and FDA staff also reported that DHS had not set out a reasonable 

timeline for developing Sector-Specific Plans. Sector-Specific Plans, 

which are authored by the Sector-Specific Agencies, discuss how each 

sector will address infrastructure protection. While DHS reportedly 

developed the Sector-Specific Plan template over the course of a year, it 

allowed the Sector-Specific Agencies just two months to complete their 

draft Sector-Specific Plans. This was an especially challenging task 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 36 
because the Sector Specific Agencies were asked to consult with their 

stakeholders as part of the Sector-Specific Plan formulation process. As a 

result, staff from the Sector-Specific Agencies indicated that Draft SectorSpecific Plans were assembled hurriedly and were not as valuable as they 

could have been. 

Council participants also signaled that, in contrast to DHS’ intensive 

demands upon council members, DHS had demonstrated only limited 

commitment of its own to the effort. In particular, USDA and FDA 

expressed concerns about the organizational standing of DHS staff that 

attend Government Coordinating Council meetings. While a Deputy 

Under Secretary regularly represents USDA at the Government 

Coordinating Council, junior staff or contractors have often represented 

DHS. Staff from one Sector-Specific Agency argued that, as a result, the 

councils frequently did not have access to anyone in DHS with policy 

setting authority. 

Frustration with the slow pace of council progress and disenchantment 

with DHS’ management style and level of engagement may have led to 

declining participation in the Government Coordinating Council. Our 

analysis of Government Coordinating Council meeting minutes shows a 

difficulty achieving what the Council’s charter calls a “decision-making 

quorum.” This quorum is reached when there is at least one representative 

each from DHS, FDA, USDA, the Association of State and Territorial 

Health Officials, National Association of State Departments of 

Agriculture, and National Association of County and City Health 

Officials. We examined minutes for the 27 Government Coordinating 

Council meetings that took place between mid-2004 and early 2006. Only 

14 of these meetings met the “decision-making quorum” requirement. In 

the first 15 meetings, only 4 meetings lacked the quorum. By contrast, a 

quorum was not achieved for 9 of the 12 most recent meetings. This 

decline in attendance over the more recent meetings may be a product of 

the frustrations members reported. 

One common disappointment Government Coordinating Council and 

Sector Coordinating Council members shared with us was the unfulfilled 

expectation that the councils would offer a window into DHS as a whole. 

Although council members reported that DHS participants in the 

Government Coordinating Council meetings were generally competent 

and accessible, many anticipated direct access to more of the department 

than was provided. While Office of Infrastructure Protection 

representatives served as the principal DHS points of contact to the 

councils, members desired more interaction with such DHS components as 

S&T, Grants and Training, and, because of food import concerns, CBP. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 37 
Even after several requests for an audience, some DHS components 

reportedly did not attend Government Coordinating Council and Sector 

Coordinating Council sessions. This led some council members to 

develop unfavorable views of DHS, including one who described the 

department as “so big and so dysfunctional.” 

As council members’ frustration mounted, Hurricane Katrina brought 

further dissatisfaction over DHS interaction with the food sector. 

Although sector experts agreed that the resiliency of food production did 

not lead to major supply problems, council members maintained that they 

were not used appropriately to support relief efforts. One Sector 

Coordinating Council member wondered why members spent so much 

time on the councils if the councils are essentially ignored during a major 

event. Perhaps more importantly, we were informed that during the crisis 

following Hurricane Katrina, the Federal Emergency Management Agency 

was asked to attend a joint session of the councils, but did not do so. The 

councils were an untapped resource that could have been more involved in 

getting food and bottled water to affected citizens. We were told that, due 

to DHS’ perceived unresponsiveness, companies used their own 

connections to provide food assistance to hurricane victims. 

Another area in which DHS can improve its work with the councils is by 

helping to establish a direct link to the National Infrastructure Advisory 

Council. Originally, the National Infrastructure Advisory Council did not 

have a member from the food sector, but a former Chief Executive Officer 

of a major food company has since been appointed. FDA staff expressed 

concerns that this individual does not have a formal relationship with the 

Government Coordinating Council and Sector Coordinating Council. An 

original member of the Sector Coordinating Council confirmed that the 

food industry does not have a “formal link” to the National Infrastructure 

Advisory Council. Without an appropriate linkage to the Government 

Coordinating Council and Sector Coordinating Council, the National 

Infrastructure Advisory Council may arrive at judgments incompatible 

with Government Coordinating Council and Sector Coordinating Council 

positions. 

Leveraging the expertise and capabilities of the food sector may be easier 

due to recent improvements council participants reported in the operation 

of these bodies. As a result of DHS’ growing experience with food 

infrastructure, some interviewees said DHS has developed a better 

understanding of private sector needs. Also, council participants believe 

that DHS’ leadership is seeking to be more responsive to the councils than 

in the past. They praised the Assistant Secretary for Infrastructure 

Protection for his commitment to improved coordination between DHS 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 38 
and the private sector. Through enhanced coordination, ultimately DHS 

was able to secure the support of the Secretaries of Agriculture and Health 

and Human Services for the frameworks and processes outlined in the 

NIPP.

54 Overall, Government Coordinating Council and Sector 

Coordinating Council representatives were optimistic that DHS would 

continue to develop its relationship with the coordinating councils. DHS’ 

ability to foster and maintain a positive relationship with the coordinating 

councils will do much to determine the department’s overall effectiveness 

in providing leadership, coordination, and support of food defense efforts. 

We recommend that the Assistant Secretary for Infrastructure Protection: 

Recommendation #3: Seek out improvement in DHS’ relationship with 

food sector partners through: 

• Better attention to the demands and information flow related to 

coordinating council comments on DHS initiatives; 

• Higher level DHS official attendance at council meetings; and 

• Increased responsiveness to council requests for information, 

briefings, and presentations by other DHS components. 

DHS Support for Food Sector Information Sharing 

DHS support of food sector information sharing currently hinges on: the 

National Infrastructure Coordinating Center; the Homeland Security 

Information Network Food and Agriculture portal; Homeland 

Infrastructure Threat and Risk Analysis Center; and the Protected Critical 

Infrastructure Information program. Each of these programs and 

initiatives had shortcomings with respect to food sector information 

sharing at the time of our fieldwork. The persistence of shortcomings in 

these areas is disturbing when considered alongside the decline of the 

Food ISAC. 

The public and private sector representatives we interviewed generally did 

not have a good sense of the work DHS performs in these four areas. As 

an illustration of the limited extent to which food sector experts were 

familiar with DHS’ information sharing efforts, few could differentiate 

between the National Infrastructure Coordinating Center and the 

Homeland Infrastructure Threat and Risk Analysis Center. 

The National Infrastructure Coordinating Center 

54 DHS, NIPP, June 30, 2006, p. 3. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 39 
Industry and government representatives we met with rarely had any 

knowledge of the National Infrastructure Coordinating Center or its 

operations. Two federal food sector intelligence experts outside of DHS 

said that they were not aware that the National Infrastructure Coordinating 

Center existed. “If we’ve never heard of it,” one noted, “what does that 

tell you about the[ir] marketing plan?” In fact, a National Infrastructure 

Coordinating Center manager acknowledged that the Center had not 

pursued any food- or agriculture-specific outreach. 

Given the limited familiarity food industry and government partners had 

with the National Infrastructure Coordinating Center, it should not be 

surprising that the Center received little or no information on post-harvest 

food-related threats, incidents, or crises. A 24/7 watch operation center 

overseen by the Office of Infrastructure Protection, the National 

Infrastructure Coordinating Center is to serve as a point of “two-way 

communication” between the private sector and DHS for reporting threats, 

events, or crises that might affect critical infrastructure. The Center 

forwards select information it receives from the public and private 

industry to other units in DHS using several different types of reports. 

From August 2005 through late March 2006, the National Infrastructure 

Coordinating Center produced 855 written reports, of which 93 (about 

11%) referenced food or agriculture. According to the Office of 

Infrastructure Protection, however, the National Infrastructure 

Coordinating Center “did not produce any reports that relate to postharvest food matters” during that period – which included Hurricane 

Katrina response and recovery efforts. 

The absence of any informational products related to post-harvest food 

during that period might also result from the National Infrastructure 

Coordinating Center’s location and composition. This make-up might 

lead the Center to focus more effort on outreach and product development 

in infrastructure sectors in which staff have especially good access or 

expertise. For example, the National Infrastructure Coordinating Center 

can directly access transportation sector information and expertise through 

its co-location with DHS’ Transportation Security Operations Center and 

the presence of the Highway ISAC in the same facility. When we visited 

the Center in February 2006, a few National Infrastructure Coordinating 

Center staff had sector-specific experience, although none had experience 

in food or agriculture. It is reasonable to expect that the sector-specific 

experience center staff had, in turn, formed the basis for more effective 

infrastructure information monitoring and reporting in those sectors. 

The National Infrastructure Coordinating Center is designed to facilitate 

information sharing “among Sector Coordinating Councils, Government 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 40 
Coordinating Councils, ISACs, and other security partners.”55 In order to 

fulfill its mission in this area, the Center must build more substantial 

relationships with food sector entities. 

We recommend that the Assistant Secretary for Infrastructure Protection: 

Recommendation #4: Expand National Infrastructure Coordinating 

Center outreach efforts to include outreach targeted to the food sector, and 

actively seek to increase information flow related to the food sector. 

Homeland Security Information Network’s 

Food and Agriculture Portal 

The effectiveness of other DHS information sharing initiatives also has 

been limited with respect to the food sector. The Homeland Security 

Information Network is comprised of a number subsystems structured 

around different user communities. It includes subsystems supporting law 

enforcement, international interests, and emergency management, among 

others.56 Among these subsystems is the “Critical Sectors” subsystem, 

which supports the Food and Agriculture portal. The Homeland Security 

Information Network Food and Agriculture portal is a web-based tool for 

sharing threat and analytical information with sector representatives. DHS 

engaged food sector representatives in the design and online layout of the 

portal starting in October 2004. More than a year-and-a-half later, these 

discussions were still ongoing. 

The general view of food sector experts we spoke with was that the 

network’s Food and Agriculture portal has potential value, but limited 

utility for the sector’s information sharing purposes in its current form. 

Concerns expressed centered on the following areas: 

• The absence of staff support for the portal by food experts 

undermines its ability to offer germane, timely information. 

• The portal has few members and an even smaller group of regular 

users, limiting the reach of information on the site. In December 

2005, the Office of Infrastructure Protection reported that only 166 

individuals had access to the Homeland Security Information 

Network’s Food and Agriculture portal. 

55 DHS, NIPP, June 30, 2006, p. 64. 56 For more information on the Homeland Security Information Network please consult our recent report on the 

subject. (DHS OIG, Homeland Security Information Network Could Support Information Sharing More Effectively, 

OIG-06-38, June 2006.)

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 41 
• The portal is a passive system and does not notify members about 

new content. 

• Content is generally not very relevant, current, or useful from the 

vantage point of food sector representatives. 

• The portal may not be well-suited to duplicate the threat reporting 

function envisioned for the ISAC. 

While food sector representatives were aggrieved by the portal’s early 

stage of development, we are concerned that the network’s Food and 

Agriculture portal may essentially duplicate an FBI effort. A limited 

access web community with information on threats, vulnerabilities, and 

protective efforts related to the food and agriculture sectors, the FBI’s 

AgInfraGard became operational in March 2006. As described by the FBI 

and food sector representatives with access to the web community, much 

of AgInfraGard’s content is similar to that of the Homeland Security 

Information Network’s portal. The FBI believes its system is developing 

more quickly than the Homeland Security Information Network’s and has 

greater capability for information exchange. Meanwhile, according to one 

FBI analyst, the DHS system “takes information but it doesn’t give a lot.” 

Notwithstanding these areas of concern, there are some positive signs 

regarding Food and Agriculture portal development. Perhaps the most 

significant is the expressed interest of the Office of Infrastructure 

Protection in detailing a state government and private sector representative 

to help develop portal content. Identifying funding for this effort and 

ensuring that detailees have adequate expertise will be keys to success on 

this point. Without such an investment, a Sector Coordinating Council 

representative candidly warned, “Homeland Security Information Network 

is going to die.” If the Office of Infrastructure Protection is able to 

advance plans in this area, it might be able to fulfill the potential of the 

system, and cultivate a vital information sharing network. 

We recommend that the Assistant Secretary for Infrastructure Protection: 

Recommendation #5: Evaluate the feasibility of providing financial 

support for and otherwise facilitate the detailing of state or local 

government and private sector representatives to support Office of 

Infrastructure Protection food sector efforts with an emphasis on the 

Homeland Security Information Network’s Food and Agriculture Portal. 

Homeland Infrastructure Threat and Risk Analysis Center 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 42 
Another major DHS information sharing initiative, the Homeland 

Infrastructure Threat and Risk Analysis Center, is also in an early stage of 

development. The center, which began operating in January 2005, 

conducts threat, vulnerability, and consequence analysis related to the 

nation’s infrastructure. As of June 2006, the center had prepared 38 

written products. Of these, four related to post-harvest food. Two of the 

four address the same material; one in classified form, the other in 

unclassified form. 

The Homeland Infrastructure Threat and Risk Analysis Center regards 

private sector infrastructure owners as a primary customer base. Yet, few 

food sector representatives we spoke with were familiar with the center or 

any of its products. Private sector representatives who had received 

specialized briefings by the center’s staff, and others who reviewed the 

center’s products, however, reflected positively on the program and its 

work. A member of the Sector Coordinating Council praised one May 

2006, briefing the center proactively organized, and reported that the 

Homeland Infrastructure Threat and Risk Analysis Center has been 

receptive to industry input on its products. 

Conversely, FDA and National Counterterrorism Center staff were critical 

of food-related intelligence products developed by the Homeland 

Infrastructure Threat and Risk Analysis Center. They said that these 

products had not drawn on subject matter expertise as much as conjecture, 

and said that some included irresponsible speculation. They said that they 

often considered the center’s products to be at odds with the experts in 

other government organizations, and asserted that the center’s products 

had not been vetted to the extent necessary. 

The Homeland Infrastructure Threat and Risk Analysis Center was, 

however, able to supply some evidence that its food and agriculture sector 

products were vetted by government and private sector experts, and 

stressed the importance of independent assessments of intelligence 

information. The center also supplied evidence that its products had been 

received well by a Department of Justice official and state homeland 

security representatives from North Dakota and New York. 

Since its formation, Homeland Infrastructure Threat and Risk Analysis 

Center staff have participated in exercises and food sector intelligence 

meetings with other federal food sector experts. Unfortunately, 

difficulties in the relationship between staff in other departments and one 

Homeland Infrastructure Threat and Risk Analysis Center representative 

strained the center’s exchanges with FDA and the National 

Counterterrorism Center. An official from the Homeland Infrastructure 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 43 
Threat and Risk Analysis Center reported that this individual has been 

reassigned, and USDA, FDA, and National Counterterrorism Center staff 

remained committed to working with DHS. Recent indications are that the 

Homeland Infrastructure Threat and Risk Analysis Center’s relationship 

with outside food intelligence experts has improved in recent months. 

The FDA staff we spoke with recommended that the Homeland 

Infrastructure Threat and Risk Analysis Center develop more internal 

expertise on particular infrastructure sectors by adding staff. When we 

spoke with center representatives, they, too, acknowledged a need in this 

area and indicated that the center was working to increase its staff. In the 

meantime, it is imperative that DHS exploit USDA and FDA expertise to a 

greater extent in interpreting food sector threat and vulnerability 

information. Additional contact with USDA and FDA could also help the 

center develop products that support the informational needs of industry 

better. 

Protected Critical Infrastructure Information Program 

The Homeland Security Act armed DHS with a new tool for gathering 

private sector information on the nation’s critical infrastructure – the 

ability to designate information as Protected Critical Infrastructure 

Information. Approved infrastructure information submitted to the 

government under DHS’ Protected Critical Infrastructure Information 

program is protected from disclosure under the Freedom of Information 

Act and should not be subject to production under a subpoena in civil 

litigation. Infrastructure information related to any infrastructure sector 

can be submitted through the program. 

The food sector has been the most engaged infrastructure sector in 

Protected Critical Infrastructure Information activities. Protected Critical 

Infrastructure Information program staff described FDA’s Center for Food 

Safety and Nutrition as the program’s “biggest customer.” Indeed, the 

agency was one of the first government units outside of DHS to become 

Protected Critical Infrastructure Information accredited, and Protected 

Critical Infrastructure Information program staff reported that other HHS 

agencies and USDA were next on their list of federal entities targeted for 

accreditation. Perhaps more notably, most of the Protected Critical 

Infrastructure Information program’s information submissions came from 

the food industry as of February 2006. In fact, at the time, 257 of 330 

total submissions, or about 78%, were food sector submissions. 

Despite these successes, FDA representatives we met with had 

unenthusiastic impressions of the Protected Critical Infrastructure 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 44 
Information program. While they planned to use the program to protect 

needed private sector infrastructure information in the future, they decried 

early difficulties in meeting the Protected Critical Infrastructure 

Information program’s extensive training and security requirements to 

become accredited. FDA staff said that the “intense” accreditation process 

took four months. One FDA representative remarked that if he had known 

how difficult it would be to achieve accreditation, he would have opted to 

use another means to gather the food infrastructure information FDA 

needed. 

Government Coordinating Council and Sector Coordinating Council 

members who discussed the Protected Critical Infrastructure Information 

program with us reported that the program’s staff has been very helpful in 

working with the private sector. Yet Government Coordinating Council 

participants in one federal department advised that they were concerned 

that Protected Critical Infrastructure Information program staff’s limited 

familiarity with the particulars of the food industry might lead them to 

make improper judgments in granting Protected Critical Infrastructure 

Information protections for related information. 

Even with publication of the Protected Critical Infrastructure Information 

Final Rule on September 1, 2006, industry skepticism about the program 

may persist. One food security expert at a large firm said the law and 

regulation had established a “cumbersome operational mechanism” that 

weighed against participation. Other industry representatives we spoke 

with were not convinced that the program would be very useful for food 

companies. Meanwhile, a government representative expressed the view 

that the industry was likely to regard the program warily until its 

information protections had been challenged in a legal setting and upheld 

in court. A recent GAO report, Information Sharing: DHS Should Take 

Steps to Encourage More Widespread Use of Its Program to Protect and 

Share Critical Infrastructure Information, made similar observations.57 

Protected Critical Infrastructure Information program staff said that the 

key to increasing Protected Critical Infrastructure Information utilization 

lies with potential end-users in government. Ultimately, government 

agencies’ need for information is the primary impetus driving Protected 

Critical Infrastructure Information submissions. Government end-users of 

Protected Critical Infrastructure Information are also well-positioned to 

lead private sector outreach efforts, as they can more effectively establish 

the government’s need for private sector critical infrastructure information 

on a case-by-case basis. Both USDA and FDA staff expressed the same 

57 GAO-06-383, May 2006, pp. 19-23. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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perspective and recognized that they are the key to more food industry 

participation. 

Charting and Protecting the Food Sector 

Asset Identification and System Mapping 

DHS is responsible for collecting information on critical infrastructure 

assets and systems. The National Asset Database is currently the 

department’s primary repository for maintaining information on critical 

infrastructure assets. It is not clear, however, how the National Asset 

Database in its present form satisfies DHS’ responsibilities regarding the 

food sector. The volume of recorded assets in the National Asset 

Database varies substantially by state, and the National Asset Database 

does not include all government information on food industry assets. 

Finally, the database draws together information on infrastructure assets, 

but not the systems that are vital to understanding the food sector. 

As of January 2006, the National Asset Database had information on 

77,069 infrastructure assets around the nation.58 Of those, 6,486 assets, or 

eight percent, were listed as relating to the post-harvest food sector.59 The 

National Asset Database contains other assets that support the food sector, 

but are not reflected in this figure because they are listed under other 

infrastructure sectors and segments. A number of port facilities that are 

involved in shipping of food, for example, are listed as transportation 

assets and, as a result, are not included in the 6,486 asset figure. 

Like National Asset Database assets at large, food sector assets in the 

database reflect variation in the intensity of state responses to 2003 and 

2004 data calls. Indiana and Wisconsin, for example, account for more 

than 53% of the total number of food sector assets in the database. 

Accordingly, Wisconsin’s 2,032 food sector assets in the database are 

about 20 times the number listed for Florida (102), and more than 145 

times more than the number listed for California (14). Meanwhile, the 

District of Colombia, Nevada, New Hampshire, Puerto Rico, Rhode 

Island, Vermont, and Wyoming have no food sector assets in the National 

Asset Database. 

58 DHS OIG, Progress in Developing the National Asset Database, June 2006, p. 1. 

59 For the purposes of this analysis, food and agriculture sector assets without agricultural attributes, and restaurants 

and food vendors were considered post-harvest food assets. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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The limitations of food sector entries in the National Asset Database are 

also evident upon examination of the assets listed for the 20 most 

populous U.S. counties. Despite the broad geographic distribution of food 

industry assets and the prevalence of major food processing, transit, retail, 

and service facilities in all major U.S. cities, all but 2 of these 20 counties 

had fewer than ten food assets listed in the National Asset Database. In 

fact, the National Asset Database listed no food assets for five of these 

counties: Clark County (Las Vegas), Nevada; Los Angeles County (Los 

Angeles), California; Miami-Dade County (Miami), Florida; New York 

County (Manhattan), New York; and Santa Clara County (San Jose), 

California. Six other top counties had only one food asset listed in the 

National Asset Database.

60 

One reason data limitations such as these persist is that the Office of 

Infrastructure Protection has been unable to exploit existing federal 

information about food industry assets. Office of Infrastructure Protection 

staff reported that, in one case, this was the result of the FDA’s 

unwillingness to share information. Office of Infrastructure Protection 

staff advised us that they had sought the registered food facility list that 

FDA is required by law to maintain, but said that FDA had resisted 

sharing this information.61 Nevertheless, other available federal food 

industry information is not included in the National Asset Database. The 

Food Safety and Inspections Service, for example, maintains a list of food 

processing facilities it inspects. We compared a sample of 100 facilities 

from this list to the National Asset Database and found that none were 

recorded in the database. 

The Office of Infrastructure Protection has an opportunity to resolve some 

of these basic issues in the near term, as it intends to convene expert 

panels to review and refine National Asset Database asset information for 

each sector. Although a panel has not yet been assembled for the food and 

agriculture sector, a panel of sector experts was scheduled to have 

reviewed all the sector’s assets by October 2006. 

While an expert panel may be able to resolve some issues with the 

National Asset Database data, other more foundational issues also require 

attention. The USA PATRIOT Act defines critical infrastructure to include 

systems and assets,62 yet the National Asset Database emphasizes assets. 

To date, the most advanced step by DHS to define parts of the food system 

60 Broward County, Florida; Maricopa County, Arizona; Orange County, California; Riverside County, California; 

San Bernardino County, California; and San Diego County, California. 61 FDA maintains a listing of registered food facilities in the United States pursuant to Section 305(a) of the 

Bioterrorism Act, P.L. 107-188, codified at 21 U.S.C. § 415a. 62 USA PATRIOT Act, P.L. 107-56 § 1016(e), codified as 42 U.S.C. § 5195c(e). 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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has been the development of a sector taxonomy to support the 

classification of National Asset Database assets. This taxonomy was 

designed to categorize infrastructure elements and facilitate 

communication about them by forging common terms of reference.63 

The Office of Infrastructure Protection staff we spoke with touted this 

taxonomy development effort as a noteworthy success and indicated that 

its development had been a point of coordination with USDA and FDA. 

Industry and federal partners we spoke with, however, did not regard 

consultation on the development of the sector taxonomy to be a major 

point of success in defining food industry systems. Instead, they held that 

DHS had focused too intently on assets, and devoted too little thought and 

energy to understanding the food sector as a system. Additionally, they 

considered DHS’ perceived asset-orientation to place the food sector at an 

unfair disadvantage in relation to other sectors. 

The view that DHS had taken an asset-driven approach to infrastructure 

protection was advanced by the Draft NIPP’s emphasis on assets and the 

National Asset Database in its proposals for prioritizing critical 

infrastructure protection. The Draft NIPP stressed that “identifying and 

prioritizing nationally critical assets” were at the core of DHS’ 

infrastructure protection budgeting process.64 It also indicated that the 

National Asset Database was to “support the implementation of NIPP risk 

management framework activities,” while serving as “the foundation for 

the NIPP risk assessment process.”65 

Food sector representatives said that DHS’ asset-orientation would result 

in an understatement of food sector risk for three reasons. First, they 

perceived that the DHS’ focus on assets led the department to emphasize 

the effects of asset destruction over asset exploitation. As discussed 

earlier, the greatest concern to many in the food sector relates to the 

exploitation of the sector to distribute intentionally adulterated foods. 

Thus, an emphasis on the effect of asset destruction would miss the most 

consequential possible effects of an attack on the food sector. 

Furthermore, the consequences of losing a single food industry asset are 

considered relatively small because the food industry has few monolithic 

components and because it has many infrastructural redundancies. This 

redundancy contributes to the likely resiliency of the food sector such that, 

if, for example, a single food processing plant were destroyed, agricultural 

products could be shipped to other food processing plants. 

63 DHS, Infrastructure Taxonomy (Draft), May 20, 2005, p. 1. 64 DHS, Draft NIPP, November 2, 2005, p. 92. 65 Ibid., p. 82.

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Second, food sector representatives pointed out that important links in the 

food supply chain are not easily captured in an asset-based model. The 

food industry is, for example, heavily dependent on transportation, yet 

mobile transportation links cannot be mapped in an asset database the 

same way as fixed physical assets. Unlike buildings, refrigerated trucks 

do not have set geographic coordinates. Moreover, the transit routes they 

frequent are subject to change. Because of these traits, food industry 

transportation assets of this kind are not reflected in the National Asset 

Database. 

Finally, food sector representatives expressed concern that DHS’ assetorientation would lead it away from an understanding of the second- and 

third-order effects of a food contamination incident. In focusing on a 

particular food industry asset, they believed DHS would lose perspective 

on upstream and downstream consequences of an incident affecting that 

asset. For example, contamination at a processing facility might not just 

affect that facility. Upstream producers of the contaminated commodity 

might suffer if consumer demand for the resulting products declines. In 

addition, downstream distributors, retailers, and food service 

establishments serving the contaminated product might also experience a 

downturn in their business as a result of such an incident. In addition, 

other parts of the economy, like the public health system, might be 

stressed as a result of a contamination incident. Accordingly, to grasp the 

second- and third-order effects of an adverse food event at a single 

facility, DHS must first understand that facility’s place within the food 

supply chain and larger economic system. 

Food and agriculture sector representatives said that their frustration with 

DHS’ apparent asset-orientation peaked in 2005. During the summer of 

that year, DHS asked the sector to prepare a list of the “Top 100 Assets” in 

food and agriculture. With only a short time to assemble a list, the sector 

responded with an apparently unprioritized, alphabetical list of 47 food 

commodities and systems. Public and private sector representatives 

complained that DHS had set up a “box-checking exercise” that simply 

did not work from a food supply standpoint. They argued that the creation 

of a top 100 list of physical assets in the sector was not possible at the 

time, and that DHS’ imperative that one be developed showed that the 

department did not understand the sector. 

The same redundancies that contribute to the resiliency of the sector in the 

event that one infrastructure unit is destroyed, also make it extremely 

difficult to define a limited set of highly critical assets. The food sector is 

replete with accessible “critical nodes” at which food products could be 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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contaminated intentionally. The consequence of contaminating food 

products at many different “critical nodes” in the supply chain of several 

different food products may be similar. And, in many cases, particular 

“critical nodes” exist in the thousands, even for a single food product. 

This calculus combined with the sheer size of the food sector have led 

USDA and FDA to focus their vulnerability and consequence assessments 

on particular industry subsystems and food products, rather than on 

particular assets. Despite this, DHS maintained an interest in the 

identification of priority assets. The Draft NIPP set out a requirement for 

Sector Specific Agencies to submit priority assets to DHS by May 1, 

2006.66 According to USDA representatives, however, the Sector Specific 

Agencies did not accommodate this request. 

In response to food and agriculture sector concerns that DHS’ approach to 

critical infrastructure protection had not properly addressed the underlying 

systems, the federally funded research center known as the Homeland 

Security Institute is studying ways to integrate a systems-based approach 

into infrastructure protection in a way that is applicable to all sectors.67 As 

part of its related research effort, the Homeland Security Institute is tasked 

with defining criticality criteria that can be used to frame sector risk 

analysis and risk management activities. Food sector representatives 

expressed optimism that this analysis would yield major dividends in their 

dealings with DHS. 

A more effective dialogue between DHS and its partners is needed to 

address concerns about asset exploitation, assets that do not have fixed 

coordinates, and system-wide impacts that the malevolent exploitation of 

food sector assets might have. Recent revisions to the NIPP may help 

foster this dialogue. Whereas the November 2005 edition of the NIPP 

stressed the need to identify assets in its approach to risk management, the 

final NIPP expands the risk management framework to include the 

identification of systems, networks, and functions.68 Indeed, according to 

the department, “DHS has evolved to the realization that an asset-based 

focus is not representative of all sectors.” 

Targeting and Prior Notice Support 

Other DHS efforts to work with the Sector Specific Agencies to protect 

the food sector offer a better example of external coordination. The 

66 DHS, Draft NIPP, November 2, 2005, p. 88. 67 See Section 312 of the Homeland Security Act, 6 U.S.C. § 192. 68 DHS, NIPP, June 30, 2006, p. 4, and DHS, Draft NIPP, November 2, 2005, p. 26. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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ongoing operations of CBP’s National Targeting Center and the FDA’s 

Prior Notice Center are designed to augment the nation’s oversight of 

imported goods, including food products. The Bioterrorism Act invested 

FDA with several new authorities to protect the food supply. Section 307 

of the Act requires all food importers to notify the FDA if any of the 

agency’s regulated products are scheduled for import into the United 

States. This prior notice requirement is designed to allow the government 

to target high-risk food imports for additional scrutiny.69 

Collaboration between CBP and FDA on import protection began shortly 

after the passage of the Bioterrorism Act. Initial coordination between the 

two agencies concentrated on the development of prior notice rules, but 

quickly expanded to include technical exchanges on how to operationalize 

these rules. To ease importers’ reporting burden, CBP designed and built 

a food prior notice interface with the Automated Commercial System, the 

import tracking and control system used by CBP. The National Targeting 

Center also worked with FDA staff to create targeting criteria for high-risk 

foods. FDA’s Prior Notice Center, which is the entity administering the 

prior notice requirement, is now co-located with the National Targeting 

Center. Both CBP and FDA representatives commended the interagency 

cooperation exhibited by the National Targeting Center and Prior Notice 

Center. CBP and FDA staff we interviewed viewed the immediate 

personal contact and exchange that has grown out of this co-location as 

vital. 

Overall, representatives of both CBP and FDA described the two 

agencies’ working relationship favorably. It has formed the basis for other 

noteworthy collaborations. They have, for example, worked to develop 

joint contingency plans for their information systems. CBP has also 

trained many of its inspectors on FDA regulations and requirements, such 

that now about 10,000 inspectors are cross-designated. 

CBP’s relationship with the Food Safety and Inspections Service is not as 

well-developed, but has evolved quickly. CBP officials meet with Food 

Safety and Inspections Service staff weekly to discuss food shipment 

tracebacks and means of improving customs data linkages to Food Safety 

and Inspections Service’s food re-inspection facilities outside ports of 

entry. CBP is also working with Food Safety and Inspections Service staff 

to develop import targeting criteria for Food Safety and Inspections 

Service -regulated commodities. CBP planned to test these targeting 

criteria at select ports during the Summer of 2006. Finally, the two 

agencies are pursuing the signature of a Memorandum of Understanding 

69 21 U.S.C. § 381. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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that would, among other things, formally grant Food Safety and 

Inspections Service access to CBP’s targeting system. 

Coordination of Research and Development, and Education and 

Training Initiatives 

Critical Infrastructure Protection Research and Development 

Planning 

DHS is responsible for planning critical infrastructure protection research 

and development activities across the federal government. Homeland 

Security Presidential Directive 7 charges DHS to prepare annual federal 

research and development plans to enhance the protection of critical 

infrastructures in collaboration with the White House’s Office of Science 

and Technology Policy.70 

To fulfill these responsibilities, DHS has developed a National Plan for 

Research and Development In Support of Critical Infrastructure in 

consultation with other departments. This plan serves as the research and 

development roadmap for critical infrastructure protection. It outlines 

priorities, goals, and objectives for research and development projects 

across various departments and agencies. The first plan, for 2004, was 

released in April 2005. A 2005 plan was never released, and has 

reportedly been consolidated with the 2006 plan. As of early December 

2006, this plan had not yet been published. 

In the development of the 2004 plan, DHS solicited suggestions and 

recommendations from all federal departments charged with protecting 

critical infrastructures, including the Sector Specific Agencies for the food 

sector. According to S&T, USDA and HHS participated in sessions on the 

content of the 2004 plan, and provided information on the food and 

agriculture sector. The two departments have also been active participants 

and reviewers for the draft 2005 effort. 

Perhaps because the 2004 plan emphasized overarching critical 

infrastructure protection research themes, it did not highlight any work 

with a clear, direct connection to the food sector. Rather than selecting 

priority research and development efforts from among the needs identified 

for the protection of particular infrastructure sectors, the 2004 plan 

focused on nine research themes to support the protection of all critical 

70 Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization, and Protection, 

December 17, 2003, paragraph 30. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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infrastructure sectors. In particular, the plan identifies the following 

research and development themes as critical infrastructure protection 

priorities: detection and sensor systems; prevention and protection 

systems; entry and access portals; insider threats; analysis and decision 

support systems; response, recovery, and reconstitution tools; new and 

emerging threats and vulnerabilities; advanced infrastructure architectures 

and systems design; and human and social issues.71 Although the plan 

asserts that progress in each of these areas will benefit all infrastructure 

sectors, in several cases related research initiatives did not appear to have 

been developed in consideration of the food sector. For example, the 

plan’s discussion on detection and sensor systems mainly addresses cyber 

security and the protection of critical infrastructure facilities against 

attacks with small arms and explosives, rather than product contamination. 

The plan’s discussion of research area with possibly the greatest bearing 

on the protection of the food supply – protection and prevention – also 

focuses on assaults and intrusions targeted at physical and cyber critical 

infrastructure.

72 Moreover, while the plan repeatedly singles out other 

infrastructure sectors, it never mentions food. By contrast, the plan 

discusses the protection of the nation’s water supply seven times.73 

More meaningful integration of food sector research and development 

initiatives into the plan could be achieved though greater harmonization 

with the research and development requirements identified in Food and 

Agriculture Sector-Specific Plans. In their September 2004 draft SectorSpecific Plans, USDA and FDA identified post-harvest food sector 

research and development needs that do not clearly correspond with the 

research themes highlighted in the plan. It is not evident, for example, 

where threat agent characterization, studies of the human health impact of 

oral doses of threat agents, and medical diagnostics and countermeasures – 

areas FDA and USDA singled out as in need of research and development 

support – fall within plan’s nine research themes, if at all.74 

Closer coordination of critical infrastructure protection research and 

development plans may develop under a rubric recently outlined in the 

National Infrastructure Protection Plan. The NIPP requires, for example, 

that future Sector-Specific Plans represent sector-specific research and 

development needs within the context of the nine research and 

development “themes” presented in the plan. In addition, the NIPP 

71 NPRD, April 2005, pp. vii-viii. 72 Ibid., p. 29. 73 Ibid., pp. 20, 30, 32, 35, 36, 52, and 61. 74 USDA, Agriculture and Food (meat, poultry, and egg products) Draft Sector-Specific Plan, September 3, 2004,

pp. 174-75. FDA, Food Sector Draft Sector-Specific Plan, September 3, 2004, pp. 96-100. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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creates an annual reporting process for Sector Specific Agencies to submit 

sector-specific research and development requirements to DHS.75 

Coordination of Education, Training, and Research and Development 

Efforts 

In the past, DHS has not fully engaged its federal food sector and industry 

partners in the initial stages of grant development or in the proposal 

selection process for the Office of Grants and Training and S&T 

education, training, and research and development projects. As a result, 

federal partners said they were sometimes caught off guard when grant 

solicitations for food defense training, and research and development 

projects were issued. Because FDA, USDA, and other federal partners 

support similar food-related programs, it is important for DHS to improve 

coordination in this area. 

S&T External Coordination 

S&T’s success in bringing public and private sector partners together in 

selecting and managing food-related programs has been mixed. 

This mixed performance is evident in the case of S&T’s grant to the 

University of Kentucky to develop a wireless electronic monitoring 

system to secure milk. S&T did not involve USDA, FDA, or industry 

participants in the selection of the proposal for this program. In fact, 

because the University of Kentucky submitted the proposal in response to 

a broad solicitation for critical infrastructure protection projects of all 

kinds, the S&T proposal review team did not have any food-specific 

expertise. Notwithstanding the early absence of public and private sector 

partners from the proposal selection process for this program, University 

of Kentucky project staff reportedly have collaborated with other 

academic institutions and representatives of the milk industry following 

the grant award. 

A similar dynamic appears to have prevailed with S&T’s food defense 

center of excellence. We were unable to reconstruct fully the solicitation, 

selection, and award process for the National Center for Food Protection 

and Defense because S&T did not maintain complete records on these 

steps. 

75 DHS, NIPP, June 30, 2006, pp. 84-85, and 147. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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USDA officials reported that they were not included in the initial planning 

and development of program requirements or content for the NCFPD, 

while FDA representatives indicated that they participated in these efforts. 

USDA staff members became involved later in the grant process. 

S&T provided documentation for the first round of the proposal review 

and selection process, during which external reviewers, including 

representatives from USDA and FDA, evaluated proposals. S&T also 

provided memoranda that summarize the conclusions of the second and 

third phases of the Center of Excellence review and selection process, and 

state an affirmative case for the selection of the University of Minnesotabased consortium. S&T could not, however, produce detailed information 

on the deliberations involved in these two phases of the review and 

selection process. Nor did it provide a summary appraisal of the thirteen 

other proposals it received or the three other site visits it conducted for the 

second and third phases of the process. 

Despite these limitations in the documentation of the Center of Excellence 

review and selection process, no one we spoke with held that the 

University of Minnesota-based consortium was a poor choice for a DHS 

Center of Excellence. Indeed, in their narrative assessments of the 

University of Minnesota proposal, reviewers from the first round of the 

proposal review process noted the consortium's potential for adding much 

benefit to the food sector. One reviewer applauded the proposal for 

including processes to ensure “research findings get translated into use,” 

and others commended the consortium's flexibility, partnerships with 

industry and academic institutions, and management plan. 

Now that the Center is operational, both the Food Safety and Inspections 

Service and FDA communicate with it regularly. To support a close 

working relationship, the National Center for Food Protection and Defense 

holds bi-weekly teleconferences and periodic meetings with 

representatives from the two agencies. 

The NCFPD continues to engage and consult federal, state, and local 

government, as well as private-sector stakeholders, in pursuing its research 

agenda. NCFPD programs are reviewed, for example, by a seven-person 

External Board of Advisors consisting of academic, private industry, and 

federal government representatives. This group is to provide strategic 

oversight of NCFPD’s overall research program, and evaluate risks and 

opportunities in the area of food protection and defense.76 

76 NCFPD, National Center for Food Protection and Defense 2005 Annual Report, January 25, 2006. p. 12. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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The NCFPD enlists the support and counsel of key food industry 

representatives by other means, as well. The NCFPD regularly 

communicates with Sector Coordinating Council leadership, and has 

created an Industry Working Group. The NCFPD consults the Industry 

Working Group on ongoing research and has made responsive adjustments 

to its research plans as appropriate. In one instance, the NCFPD used the 

Industry Working Group as a “sounding board” for its supply chain 

questionnaire intended for an industry audience. The Industry Working 

Group reviewed the questionnaire, provided feedback to Center 

researchers on the survey's strengths and weaknesses, and helped 

researchers develop more probing questions to identify security gaps 

previously omitted from the survey. 

Industry Working Group members regard the working group as one of the 

Center’s strengths, and said that it links research proposals to real-world 

food defense challenges and consequences. One Industry Working Group 

member commended the Center for creating a neutral forum for private 

sector competitors and government regulators to collaborate on food 

defense issues. Generally, Industry Working Group members expressed 

their satisfaction with the NCFPD and said that their association with the 

NCFPD had resulted in valuable industry contacts, a sounding board for 

food defense requirements, and a partner for spreading awareness in the 

food sector on terrorism and intentional contamination. Further, they 

noted that the Center’s research projects will assist them in better securing 

industry processes and supply chains as well as fostering a collaborative 

environment with their competitors in the defense of the nation’s food 

supply. 

Industry consultation has also been a hallmark of another S&T program, 

the Food Biological Agent Detection Sensor. In developing program 

requirements, S&T staff responsible for the Food Biological Agent 

Detection Sensor program collaborated with federal partners and industry 

representatives. Program staff worked directly with FDA in the 

development of the Food Biological Agent Detection Sensor program. 

They collaborated in the development of detection thresholds, definition of 

agent and matrix characteristics, cycle times, and other detection platform 

requirements. In addition, S&T staff consulted with food industry 

officials and visited several facilities to ensure that the program 

requirements they established were compatible with food industry needs in 

areas like cost and performance. 

Despite these two favorable engagements with S&T, an FDA 

representative communicated his concern that S&T may be funding 

duplicative programs in other areas. In 2004, FDA requested an allDHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 56 
inclusive list of S&T food and agricultural-related research projects in 

order to coordinate and prevent duplicative research, but S&T never 

provided such a listing. FDA staff maintain that their request is crucial in 

preventing the emergence of duplicative research and development 

projects. In particular, FDA staff were concerned that the National 

BioDefense Analysis and Countermeasures Center was proceeding with 

research in this vein. Indeed, the Countermeasures Center has apparently 

not consulted with FDA in structuring its food-related research initiatives. 

To its credit, though, it is working closely with the Food Safety and 

Inspections Service, and is currently funding two Food Safety and 

Inspections Service vulnerability assessments. 

In the context of greater overall sharing of information on research 

initiatives among USDA, FDA, and DHS, we recommend that the Under 

Secretary for Science and Technology: 

Recommendation #6: Develop and maintain, in collaboration with the 

Offices of Grants and Training and Infrastructure Protection, a 

comprehensive report on DHS food sector research and education 

initiatives to be shared with FDA and USDA on a regular basis. 

Office of Grants and Training External Coordination 

Until late 2004, Office of Grants and Training did not seek Food Safety 

and Inspections Service, FDA, or food industry participation in the 

development or selection of Grants and Training education and training 

programs. These groups were not involved in the development of program 

requirements or in the Grants and Training grant solicitation or selection 

process. 

Government Coordinating Council members conveyed their concerns that 

Grants and Training did not solicit input for the development of grant 

requirements, solicitation, and the grant selection process for the 

UC Davis Agroterrorism Preparedness Training Curriculum. While an 

educational technology expert from USDA’s Animal and Plant Health 

Inspection Service participated in the selection of the UC Davis effort, 

neither Food Safety and Inspections Service nor FDA did. Perhaps as a 

result, Government Coordinating Council members said that they were 

caught off guard when the grant was awarded. Indeed, USDA had 

awarded funds to another university for similar work just days earlier. 

Seven days prior to the DHS announcement of its $4.7 million award to 

UC Davis to provide training and education on the protection of the food 

supply, USDA announced a $750,000 award to St. Joseph’s University to 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 57 
develop online courses aimed at protecting the nation's food supply from 

contamination. 

Following the UC Davis selection and resulting complaints from the 

Government Coordinating Council, Grants and Training sought to 

integrate other sector partners. Although Grants and Training successfully 

reached out to USDA and received participation from the Animal and 

Plant Health Inspection Service, it did not immediately involve the Food 

Safety and Inspections Service. Nor did it reach out to the FDA for some 

time. Without Food Safety and Inspections Service and FDA engagement, 

Grants and Training lost out on potentially valuable assessments of the 

impact of its programming on the post-harvest portion of the farm-to-table 

continuum. 

After awarding several training, education, and preparedness grants, 

Grants and Training developed a method for gathering the perspectives of 

food sector experts on its work. Grants and Training engaged federal and 

state partners through its Agro-Terrorism Training Initiative Working 

Group. The group has gathered statistics on agro-security programs, 

monitored their progress, exchanged related information, and assisted with 

course development efforts. At the outset, the only federal participants in 

the working group outside of DHS were from the Animal and Plant Health 

Inspection Service. Later, as the working group continued to facilitate 

information exchange and integrate subject matter expertise, Grants and 

Training enlisted and received the participation of the FBI, CDC, and state 

and academic partners. 

Initially, Grants and Training did not appreciate the need for FDA and 

Food Safety and Inspections Service participation in this forum. Grants 

and Training did not recognize that the federal agencies involved in the 

regulation of post-harvest food were absent from the working group until 

March 2005. That month, Grants and Training organized a summit to 

“develop a seamless emergency response to agro-terrorism training plan 

that reflected the coordination efforts between DHS and USDA.” 

Working group participants at the summit noted that the FDA and Food 

Safety and Inspections Service were not represented and expressed the 

view that they should be included in future sessions. After soliciting 

participants for contact information, Grants and Training extended 

invitations to FDA and Food Safety and Inspections Service, and both 

attended 2005 and 2006 working group sessions. 

While they did not participate in initial grantee selection processes, federal 

partners and private sector representatives have been involved in the 

course review process for Grants and Training’s food-related training and 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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education initiatives. To ensure that Grants and Training-sponsored 

courses provide accurate information and effectively reach target 

audiences, Grants and Training now requires that the FDA, Food Safety 

and Inspections Service, and the Animal and Plant Health Inspection 

Service formally endorse its food-related courses, and also involves 

private sector subject matter experts in its course review process. Grants 

and Training reports that all six of UC Davis’ food-related courses have 

been vetted and approved by USDA and FDA. 

Moreover, several of Grants and Training’s grant recipients have sought 

out key entities involved in post-harvest preparedness. UC Davis worked 

with more than 15 collaborators in developing its agroterrorism 

preparedness curriculum, including representatives of the State of 

California’s food and public health agencies, food and health associations, 

academic institutions, and private industry. Similarly, the University of 

Tennessee has collaborated with FDA, the Animal and Plant Health 

Inspection Service, the Food Safety and Inspections Service, other 

academic institutions (including two with DHS agroterrorism programs), 

and State of Tennessee agencies in developing its plans for a vulnerability 

assessment training course. The Multi-State Partnership for Security in 

Agriculture also drew on input from various state departments of food and 

agriculture, public safety, and state homeland security advisors in 

designing its proposal. 

Expanded regional collaboration is one of the national priorities identified 

in the National Preparedness Goal. This priority stems from recognition 

of the importance of establishing partnerships across jurisdictions and in 

cooperatively building capabilities. Regional collaboration is also valued 

because it allows for related costs and risks to be spread out over multiple 

jurisdictions. 

The vision for the State Homeland Security Program calls for regional 

collaboration of this nature, but it does not have a funding vehicle to 

support non-urban, multi-state efforts. Unlike the Urban Areas Security 

Initiative, which provides a means for suburban and urban areas to jointly 

apply for DHS grants to address risks across jurisdictions, the State 

Homeland Security Program has no provision for states to submit joint 

applications. This arrangement has reportedly worked to the detriment of 

an important multi-state food-sector program. 

The Multi-State Partnership for Security in Agriculture currently receives 

funding through an Urban Areas Security Initiative discretionary grant 

award channeled through the State of Iowa. Unless it is able to effectively 

petition for urban area funds once again, the only way the Multi-State 

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Partnership can access DHS financial support is through the State 

Homeland Security Program. As currently configured, though, the 

application process does not enable the Multi-State Partnership to 

effectively compete for funds. 

The Multi-State Partnership can apply for State Homeland Security 

Program support in two ways, neither of which is satisfactory. One way 

the Multi-State Partnership can apply for such funds is by having one state 

apply for funding to support the whole multi-state partnership. At present, 

however, State Homeland Security Program awards are given to states in 

undifferentiated blocks, so there would be no straightforward way to 

determine how much DHS intended to apportion to the multi-state effort 

as opposed to other state-specific projects. Moreover, states are reportedly 

anxious about applying for State Homeland Security Program funding for 

the multi-state effort because they fear that the budget for the multi-state 

effort will be withdrawn from other funds they would have received 

without including the Multi-State Partnership. 

In the alternative, the Multi-State Partnership could request that each of 

the participating states apply for funding under the initiative individually. 

However, this option is cumbersome and guarantees that the same issues 

with differentiating multi-state initiative funds from state-specific funds 

will be repeated across eleven states. Moreover, if it were to receive 

funding from eleven different states, the Multi-State Partnership may have 

to significantly alter its administrative and financial structure to account 

for activities and expenditures in a more disaggregated, unduly complex 

fashion. 

While the current grant application process presents significant barriers to 

non-urban, multi-state initiatives, Grants and Training’s ability to address 

these barriers is subject to some noteworthy constraints. For one, the 

Office of Grants and Training interprets its appropriation language to 

mean that it can only consider applications for State Homeland Security 

Program formula-based grant funds that are submitted by states.

77 As a 

result, non-profit consortia and regional organizations are precluded from 

directly applying for funds under the program. 

What is more, the Office of Grants and Training cannot easily fashion an 

alternative grant program to support such multi-state enterprises. The 

Office has no independent appropriations stream to support a new grant 

program of this nature, and believes it is not independently authorized to 

pursue one absent a congressional mandate. 

77 Public Law 109-295 (2006). 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Notwithstanding these constraints, Grants and Training can take steps to 

remove grant application barriers to multi-state initiatives. It can do so by 

fashioning a State Homeland Security Program grant application process 

that is more receptive to multi-state initiatives. This could be 

accomplished in a number of ways. One way would be for Grants and 

Training to permit groups of states to submit applications for State 

Homeland Security Program funds in support of multi-state initiatives. 

These applications would be submitted separately from states’ individual 

applications for funds, and could designate one state as the lead. 

We recommend that the Assistant Secretary for the Office of Grants and 

Training: 

Recommendation #7: Develop a grant process to support non-urban, 

multi-jurisdictional preparedness programs on a regional level. 

Prioritization Challenges 

Congress and the President have conferred enormous responsibilities upon 

DHS, requiring the department to embrace an ambitious mission. For 

DHS to effectively address its vast overall mission and significant 

responsibilities in food defense and critical infrastructure protection, it 

must allocate its resources and efforts in line with clear and rational 

priorities. 

Secretary Chertoff has frequently stressed the use of risk management 

techniques to prioritize the department’s activities. In his prepared 

remarks for a March 2005 speech, the Secretary endorsed a “risk-based 

approach” to guide DHS operations and target resources. He directed the 

department to prioritize its undertakings on the basis of three variables – 

threat, vulnerability, and consequence.78 

Notwithstanding this guidance, the department’s approach to food-sectorrelated work has not always been guided by risk in a clear, consistent way. 

Rather, multiple approaches to prioritizing efforts have been employed 

across different units within DHS. Further, we encountered little 

consensus on how the different elements of risk rate with respect to postharvest food. Disparate views in these areas are likely to persist if the 

78 DHS Secretary Michael Chertoff, Prepared remarks delivered at George Washington University’s Homeland 

Security Policy Institute on March 16, 2005. (http://www.dhs.gov/dhspublic/display?theme=42&content=4392) 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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department continues to apply inconsistent approaches in evaluating the 

elements of food sector risk. 

Of the DHS components working with the food sector, Grants and 

Training has perhaps the most anomalous and complex approach to risk. 

Grants and Training’s approach to prioritization can be seen as consisting 

of two parts. First, Grants and Training prioritizes support for activities 

based on how and whether they advance preparedness goals. Second, 

Grants and Training allocates funds to different applicants based on 

assessments of their applications and the level of perceived risk associated 

with their jurisdiction or geographical area. Neither of these approaches to 

prioritization portray the level of risk to the food sector in a clear and 

transparent way. Further, the second approach does not fully account for 

food sector risk. 

To determine which preparedness activities to support, Grants and 

Training began by considering the nation’s response requirements. The 

Office of Grants and Training’s mandate under Homeland Security 

Presidential Directive 8 is to prepare the nation for hazards of all kinds – 

natural and manmade, intentional and inadvertent. To determine how to 

prioritize its preparedness efforts, Grants and Training developed a series 

of scenarios intended to represent a broad range of catastrophic events that 

could occur. Grants and Training used these fifteen scenarios – one of 

which dealt with food contamination – to determine which tasks the nation 

needed to be prepared to perform to address these threats.79 Grants and 

Training, in turn, took these tasks and grouped them into three dozen 

capability requirements. Finally, Grants and Training, in consultation 

with homeland security stakeholders and in consideration of national, 

state, and urban area homeland security strategies, identified a subset of 

priority capabilities. Although “food and agriculture safety and defense” 

is listed as a capability requirement, it was not selected as a priority 

capability.80 Grants and Training thus notes the need for the development 

of food defense capabilities, but does not place a high priority on that 

effort. 

In addition to priority capabilities, the National Preparedness Goal 

identifies “overarching priorities,” that are not capability-specific. One of 

these overarching priorities – implementation of the National 

Infrastructure Protection Plan – addresses food critical infrastructure 

protection in part. 

79 DHS, National Preparedness Guidance, Homeland Security Presidential Directive 8: National Preparedness, 

April 27, 2005, pp. iii, and 3. 80 DHS, Interim National Preparedness Goal, March 31, 2005, pp. 7, 10. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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DHS’ judgments about priority capabilities and overarching priorities, 

however, are not the only factor in determining what activities 

preparedness funds support. States also have an important role in 

determining how Grants and Training funds are ultimately spent. Much of 

Grants and Training’s support of preparedness efforts is channeled 

through state governments. Grants and Training requires states to develop 

state-based homeland security strategies and set priorities within the scope 

of those strategies. Some states place particular emphasis on post-harvest 

food security in their homeland security strategies, and, in turn, support 

related priorities with funding distributed through Grants and Training’s 

State Homeland Security Program. Conversely, because DHS does not 

require states to address all target capabilities in their strategies, or food 

and agriculture safety and defense in particular, a number of states might 

not use any State Homeland Security Program funding to sponsor efforts 

in this area. 

Grants and Training’s past analysis of Fiscal Year 2004 state homeland 

security plans revealed that states planned initiatives in 14 different areas 

to address agroterrorism threats. Such initiatives ranged from 

vulnerability and risk assessments to exercises, and from information 

sharing and surveillance to public outreach. While several states and 

territories planned a broad complement of related activities, 13 states did 

not present any initiatives to address agroterrorism in their Fiscal Year 

2004 Homeland Security Strategies, according to Grants and Training. 

We could not ascertain which states were or were not currently 

performing Grants and Training-supported state food safety and defense 

activities because Grants and Training does not regularly track states’ 

activities in each of the target capability areas. Nor does Grants and 

Training track state and urban area support for food sector infrastructure 

protection activities. Grants and Training does, however, monitor state 

capability development priorities outlined in their homeland security 

strategies. For their 2005 State Homeland Security Strategy submissions, 

Grants and Training asked states to identify three to five additional 

capabilities that are priorities for them beyond DHS’ priority capabilities. 

In response, nearly one-third of states identified food and agriculture 

safety and defense as a state priority. 

Funds for Grants and Training’s largest grant programs are allocated in 

line with appraisals of the quality of the grant applications, and the level of 

perceived risk associated with a particular jurisdiction or geographical 

area. Grants and Training derives these assessments of risk from 

Infrastructure Protection’s Risk Management Division. In determining the 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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level of risk associated with a particular state or urban area, Risk 

Management Division considers the infrastructure assets in the area, 

population factors, other area attributes, and related threat information. 

The complex analysis underpinning these risk determinations specifically 

accounts for the presence of and risks to assets in 14 of the 17 recognized 

infrastructure sectors. It does not, however, include any specific reference 

to or coverage of post-harvest food assets. 

The risk analysis undergirding Grants and Training’s geographic 

allocation of funds partially accounts for threat of food contamination in 

other ways. It accounts for the possibility that the assets included in the 

analysis might be subject to a food contamination incident as part of the 

process of assessing their level of risk. So while the overall risk analysis 

does not account for the risk of food contamination at a food processing 

facility that could in turn affect people around the country, it does address 

the possibility of food contamination at schools, stadiums, and other 

assets. The risk analysis also considers some other factors, like a city’s 

population, that could impact a food contamination incident’s effect. Still 

other factors weighed in the analysis might, in part, reflect food-related 

threats or incidents. Another factor applied to the risk formula for states – 

state total agriculture sales – could serve as a proxy for the volume of 

foods produced in a state, though it does not account for the volume of 

foods processed, transported, stored, sold, or prepared. Even so, no 

comparable factors are considered in the risk analysis for urban areas. 

Although Grants and Training’s support of food defense and critical 

infrastructure protection activities cannot be easily understood in terms of 

risks to the food sector in particular, the prioritization efforts of other DHS 

units can. The prioritization conclusions staff in these units reached were 

not, however, consistent with one another. DHS staff, contractors, and 

grantees we interviewed had sharply discrepant views on the level of risk 

associated with an attack on the food sector. Some DHS perspectives on 

food sector risk, including those of senior managers, did not appear to be 

fully informed by information available to other parts of the department. 

In 2003, after conducting a risk assessment on the subject, FDA reported 

to Congress that there was a “high likelihood, over the course of a year, 

that a significant number of people will be affected by an act of food 

terrorism or by an incident of unintentional food contamination that results 

in serious foodborne illness.”81 While some DHS representatives have 

embraced this perspective on food sector risk, it is a view that was not 

supported by a number of key DHS managers. 

81 FDA, Risk Assessment for Food Terrorism and Other Food Safety Concerns, October 13, 2003. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Differences in DHS perceptions about food sector risk extended to all of 

the elements of risk. DHS staff perspectives on food sector threats, 

vulnerabilities, and consequences ranged from low to high. The 

distribution of views on food sector vulnerabilities provides a useful 

illustration. 

Most experts we spoke with regarded the food sector as highly vulnerable 

to attack. They considered food sector security to be less intensive than 

the security for other critical infrastructures. In addition, they noted the 

openness and international dimensions of the food supply chain as other 

factors contributing to its vulnerability. By contrast, one senior Office of 

Infrastructure Protection manager maintained that the food sector’s 

vulnerability was not very high because “food contamination is naturally 

tested for in food safety systems.” While this statement is not wholly 

inaccurate, it reveals an important misconception. Existing food safety 

operations to a very large extent have been structured to address naturally 

occurring food contaminants and contaminants that may be inadvertently 

introduced into food products. Until recently, these operations have not 

focused on detecting the kinds of agents that experts expect someone 

might use in the intentional contamination of food. As a result, their 

capacity to mitigate such threats is still limited. 

In another noteworthy case, a CBP manager expressed the view that the 

loss of life associated with a food contamination event was likely to be 

restricted to a hundred or so persons. This perspective is at odds with a 

food contamination event model at the NCFPD, which projects losses of 

life in the tens of thousands for a particular type of contamination incident. 

Misconceptions like this should not persist in a unit that has experts who 

are aware that food safety operations are not structured in a way to 

effectively address a number of food contamination scenarios. Yet we 

encountered other similarly misinformed perspectives among DHS 

managers on other occasions when better information was available 

elsewhere in the department. 

In some cases, DHS thinking about the vulnerabilities of food sector assets 

and the consequences of an attack on them did not account for the most 

serious threats to these assets. DHS has funded the production of several 

Buffer Zone Plans on food industry assets that do not discuss the 

possibility of contaminating food at these facilities. Whereas the 

intentional contamination of food would perhaps most likely result from 

an insider threat, Buffer Zone Plans concentrate on threats “outside the 

fence,” and seek to create a buffer zone around facilities. Accordingly, 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Buffer Zone Plans that do not account for the threat of food contamination 

are not necessarily deficient. Rather, they may simply add less value to 

the protective environment of food facilities than more comprehensive 

analyses. 

DHS has also funded the development of an automated tool to evaluate the 

consequences of terrorist attacks on different assets, but did not include 

food contamination among the possible modes of attack. The Gross 

Consequence of Attack tool provides high-level assessments of the 

consequences of 20 different modes of attack, many of which may be 

regarded as more technically challenging or less consequential than food 

contamination. The tool examines, for example, the consequence of aerial 

releases of chemical and biological agents at particular facilities, though 

the aerisolization and delivery of many chemical and biological agents 

presents major technical hurdles that contaminating food with the same 

agents does not. Despite this omission, the department planned to run the 

tool on all assets in the National Asset Database to help determine which 

were more consequential. Because the tool does not account for the most 

serious mode of attack on food assets, the maximum potential 

consequence of an incident affecting these assets will be greatly 

underrepresented in any resulting analysis. 

DHS is not likely to achieve internal consensus on food sector 

vulnerability until there is agreement on what tool or tools to use to 

measure it. Disagreement among DHS and its federal partners on the tool 

to use for food sector vulnerability assessments might have contributed to 

uneven vulnerability assessment practices across DHS units. 

DHS’ Office of Infrastructure Protection and S&T have funded CARVER 

and CARVER+Shock assessments of food systems and assets. 

CARVER+Shock is a prioritization tool originally developed by the 

Department of Defense that has been adapted to assess food sector 

vulnerabilities. CARVER+Shock examines the criticality, accessibility, 

recuperability, vulnerability, effect, recognizability, and shock from the 

disruption or loss of a particular asset or system to help develop protective 

measures. 

In the past, the Office of Infrastructure Protection funded such 

assessments through its support of Site Assistance Visits and Buffer Zone 

Plans in the food sector. The Office of Infrastructure Protection’s Risk 

Management Division’s support of the CARVER tool in the food sector 

has, however, ceased. S&T’s National BioDefense Analysis and 

Countermeasures Center is funding the conduct of two CARVER+Shock 

assessments by the Food Safety and Inspections Service. Meanwhile, the 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Office of Infrastructure Protection’s Infrastructure Partnerships Division is 

providing support for the FBI-led Strategic Partnership Program 

Agroterrorism Initiative, which employs CARVER+Shock. This support 

continues despite DHS’ past endorsement of the competing Risk Analysis 

and Management for Critical Asset Protection methodology for all critical 

infrastructure protection efforts.82 

As S&T and the Office of Infrastructure Protection’s Infrastructure 

Partnerships Division support large scale plans to move forward with 

CARVER+Shock assessments of food sector subsystems, another DHS 

component is supporting an effort to employ a different assessment 

methodology. As noted earlier, the Office of Grants and Training has 

provided a $2 million grant to the University of Tennessee to develop an 

agroterrorism assessment training program. Under current plans, the 

program will encourage program participants to focus on an Operational 

Risk Management approach to assessment, as well as CARVER+Shock. 

For DHS to resolve differences in the appraisal of food sector risk, the 

department must take several steps. In particular, DHS must embrace a 

common approach to food sector vulnerability assessment, develop more 

internal expertise on food defense matters, improve coordination among 

affected staff in the department, and strengthen communication with 

experts outside DHS. In addition, DHS must ensure that formal 

assessment tools used in the food sector are similar to or compatible with 

those applied in other infrastructure sectors. 

Without departmental consensus on the level of overall food sector risk or 

any of its elements, DHS cannot be expected to rationally apportion its 

resources and efforts across the full range of infrastructure sectors. As the 

basis for their decisions on how to allocate resources and efforts across 

infrastructure sectors, DHS managers could point to no document that 

rated risk across all sectors and ranked them accordingly. What is more, 

DHS managers cannot, at present, refer to a standardized consequence and 

vulnerability assessment instrument to measure these elements of risk 

across sectors. 

DHS managers have had to make difficult choices about apportioning 

resources and efforts across different infrastructure sectors without the 

benefit of a clear consensus on cross-sector priorities. In more than one 

case, DHS managers reportedly assigned risk and priority across 

infrastructure sectors using rather informal approaches. Protected Critical 

Infrastructure Information program staff advised us that they determined 

82 DHS, Draft NIPP, November 2, 2005, p. 125. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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which sectors to target for outreach activities by discussing among 

themselves what sectors, “as a public citizen, they would be most 

concerned about.” For Protected Critical Infrastructure Information 

program staff, food was chosen as one of the sectors of highest concern. 

Homeland Security Information Network staff reportedly applied a similar 

approach and arrived at a similar conclusion – the food sector was among 

their priorities, as well. 

Despite these informal conclusions that the food sector should be a high 

priority, the department devotes fewer resources to it than at least one 

other sector. The transportation sector receives dedicated funding for 

mass transit, port, and aviation security, each of which exceeds DHS’ 

funding for food and agriculture security. Other sectors, like the chemical 

and nuclear sectors, are also the focus of intensive programs and funding. 

In considering the level of support received by the food sector relative to 

other infrastructure sectors, some food and agriculture security experts 

questioned whether the department has directed sufficient resources to 

improve the sector’s protective posture. Until a thoughtful consensus on 

cross-sector risk emerges, however, it is difficult to assess the merits of 

this critique. 

While a fully comprehensive and well-founded solution to cross-sector 

prioritization may be some time off, less ambitious efforts to prioritize 

efforts are in order at this time. There is an immediate need for 

prioritization across the food and agriculture sectors. 

DHS’ current patchwork of programs, initiatives, and staff supporting 

food sector defense and critical infrastructure protection more often than 

not also support agricultural defense. This bundling of pre- and postharvest food responsibilities is evident, for example, in the Government 

Coordinating Council and Sector Coordinating Council, as well as a 

number of Grants and Training-funded initiatives. The institutional habit 

of addressing these threats with shared resources is, to a large extent, an 

outgrowth of the fact that the two share a common “farm-to-table” 

continuum. Allocating common resources across food and agriculture is 

often sensible, as adverse events affecting one part of the continuum tend 

to have negative consequences elsewhere along the supply chain. 

It may not be necessary or wise to completely separate activities 

supporting food defense from agricultural defense, but it is important to 

monitor the balance of efforts devoted to one or the other and determine 

which of the two should receive greater attention. At present, little 

attention has been spent on tracking the balance of DHS effort devoted to 

the post-harvest food sector as compared to agricultural defense. Due to 

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the intense bundling of the food- and agriculture-related efforts, it is 

difficult to discern the effective level of prioritization attached to postharvest food defense. 

Though we were unable to separate expenditures between the two 

subsectors, it appeared to us that pre-harvest agricultural defense was 

receiving more support than post-harvest food defense. This seemed to be 

the case both from an overall program perspective and within bundled 

programs and activities. 

Pre-harvest activities receive considerable direct attention in the 

department’s efforts, while post-harvest food rarely received comparable 

attention. On the pre-harvest side, for example, S&T manages the Plum 

Island Animal Disease Center ($60.0 M) in addition to a Center of 

Excellence on Foreign Animal and Zoonotic Disease ($6 M). Meanwhile, 

Grants and Training supports what appear to be exclusively pre-harvest 

course development and training initiatives at Kirkwood Community 

College ($3.2 M) and the Center for Domestic Preparedness ($0.8 M). By 

contrast, DHS only sponsors two programs with a primarily post-harvest 

orientation, the National Center for Food Protection and Defense ($5 M) 

and Food Biological Agent Detection Sensor ($3.6 M). Overall, DHS 

spends eight times more on pre-harvest programs than programs with a 

post-harvest focus. 

Within bundled DHS programs and activities, more often than not preharvest efforts appeared to be ascendant. A pre-harvest orientation is, for 

example, evident with respect to some of Grants and Training’s related 

programming. Louisiana State University’s agroterrorism preparedness 

and response course, for example, is focused primarily on the pre-harvest 

parts of the supply chain; only about one twentieth engages post-harvest 

food defense. 

DHS personnel working on food and agricultural issues also tend to have a 

pre-harvest orientation. Almost all of these staff have backgrounds in 

animal health, while only a few have direct experience related to postharvest food. This is an important distinction because, as one government 

representative noted, there is a “huge difference between being a vet and 

being a food safety expert.” 

The agriculture sector’s comparative ascendance with respect to postharvest efforts occurs despite the absence of an apparent management 

decision to prioritize agriculture over food. While we found no evidence 

of a clear, consistent management decision to prioritize pre-harvest 

activities over post-harvest activities, the recent attention to avian 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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influenza has driven many of the department’s bundled internal resources 

to focus more intensively on the agricultural sector. 

DHS and its federal partners need flexibility in apportioning resources to 

support pre- and post-harvest defense, as related levels of risk are subject 

to change over time. Nevertheless, it is important to develop shared 

perspectives on the relative risk of threats in the pre- and post-harvest 

portions of the farm-to-table continuum. Further, it is important for DHS 

to monitor the relative allocation of resources across food and agriculture 

to ensure that these are balanced in line with risk determinations. 

DHS Fulfillment of its Responsibilities 

In most areas of DHS food sector responsibility, the department has taken 

action to meet its obligations. It has done so despite the fact that a number 

of its related responsibilities were set out recently. Many of DHS’ foodrelated responsibilities originated with the issuance of Homeland Security 

Presidential Directive 9 less than three years ago. 

Despite this challenge, DHS has satisfied basic requirements in most areas 

of food defense and critical infrastructure protection responsibility. 

Nonetheless, to date, DHS has not fully met all of its food-related 

responsibilities. In two areas, we were unable to identify fully responsive 

DHS activities. First, DHS has not collaborated with USDA and FDA to 

prepare and submit an integrated food defense budget plan to the White 

House. Second, DHS has yet to develop adequate standards or processes 

for integrating food sector vulnerability assessments through the 

development of common consequence and vulnerability standards and 

guidance. 

Table 3. DHS Execution of Food-Related Responsibilities 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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DHS Execution of Food Related Responsibilities 

Critical Infrastructure Protection Management and Coordination 

Asset Identification and Mapping 3 

Information Sharing, Threat Awareness, and Warning 3 

Vulnerability Assessment 

Consequence Assessment and Modeling 3 

Protective Measures and Prioritization 3 

Research & Development 3 

Education, Outreach, Training, and Preparedness 3 

Budget Coordination 

Homeland Security Presidential Directive 9 established that, “for all future 

budgets, the Secretaries of Agriculture, Health and Human Services, and 

Homeland Security shall submit ... an integrated budget plan for defense 

of the United States food system.”83 According to the department, the 

Homeland Security Council initially directed DHS to delay 

implementation of this requirement. 

As DHS food defense spending has increased and its related programs 

have grown, so have the benefits of coordinating food defense budgets 

with USDA and HHS. Yet almost three years after Homeland Security 

Presidential Directive 9 issued, we did not see any evidence that DHS was 

complying with this requirement. 

When we queried about DHS’ plans to satisfy its budget coordination 

obligations under Homeland Security Presidential Directive 9, one Office 

of Infrastructure Protection manager advised that the resource 

prioritization process in the NIPP would fulfill the department’s budget 

coordination requirement. There is, however, an important difference 

between the Homeland Security Presidential Directive 9 requirement and 

the resource prioritization process in the NIPP. 

The process outlined in the NIPP relates to overall national protective 

prioritization, not the formulation of integrated budget plans for each 

sector. The requirement in Homeland Security Presidential Directive 9 

83 Homeland Security Presidential Directive 9: Defense of United States Agriculture and Food, January 30, 2004, 

paragraph 26. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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focuses on maximizing efficiency among the federal departments 

responsible for food defense, whereas the process outlined in the NIPP is 

not specific to any infrastructure sector. 

To meet its responsibilities under Homeland Security Presidential 

Directive 9, we recommend that the Under Secretary for Preparedness, in 

conjunction with the Under Secretary for Science and Technology: 

Recommendation #8: Work with HHS and USDA to prepare an 

integrated food defense budget plan for Fiscal Year 2009 using a process 

that satisfies Homeland Security Presidential Directive 9 requirements. 

Vulnerability Assessment Standards 

Homeland Security Presidential Directive 7 mandates that DHS “establish 

uniform policies, approaches, guidelines, and methodologies for 

integrating [f]ederal infrastructure protection and risk management 

activities within and across sectors.”84 To satisfy this mandate, DHS must 

establish uniform approaches to the assessment of vulnerability – a key 

ingredient of risk. 

To date, DHS actions have contradicted its responsibility in this regard. 

Rather than pursuing a uniform approach to food sector vulnerability 

assessment, DHS is supporting a number of approaches and has not set 

clear standards to ensure compatible assessment results. 

After September 11, 2001, FDA and Food Safety and Inspections Service 

conducted initial vulnerability assessments of the food industries they 

regulate. While each of these assessments rated the vulnerability and 

criticality of particular steps in the production, processing, distribution, 

and retail of the products they regulated, the two efforts employed 

different methodologies. A White House-based subcommittee later 

directed the two agencies to apply a common approach to vulnerability 

assessment. FDA and Food Safety and Inspections Service thus came to 

use the CARVER+Shock assessment methodology. 

FDA and Food Safety and Inspections Service have subsequently used 

CARVER+Shock to conduct numerous vulnerability assessments. Staff 

from these organizations reported that experts from the two agencies have 

scored steps in the supply chain of similar food products similarly using 

84 Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization, and Protection, 

December 17, 2003, paragraph 14. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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CARVER+Shock. Although use of CARVER+Shock may lead to parallel 

conclusions for the same or similar products, the difference in the 

agencies’ regulatory cultures and areas of statutory emphasis could 

contribute to important differences of opinion in certain areas. 

Perhaps for these reasons, some Office of Infrastructure Protection staff 

regard CARVER+Shock as unscientific and inexact. One senior Office of 

Infrastructure Protection manager expressed the view that CARVER is 

“totally subjective,” leading to vulnerability determinations that are the 

“best guess” of those completing the assessment. Our review of CARVER 

assessments in Buffer Zone Protection Program and Site Assistance Visit 

reports tended to support this assessment. CARVER assessments for the 

same facility type conducted during the same month, for example, 

produced very different scores from one report to the next. A CARVER 

assessment of one dairy plant rated the vulnerability and criticality of a 

particular production node to be three times greater than another 

assessment on the same node of a different plant. Because the 

accompanying narratives do not provide comparable information on 

facility production or security features it is not possible to determine 

whether these scoring discrepancies can be justified. 

Office of Infrastructure Protection staff in the Risk Management Division 

regard the Risk Analysis and Management for Critical Asset Protection as 

a more objective, precise process that can be tailored to the food sector. 

This view was reinforced by the Draft NIPP, which stated that, “ideally, 

all asset owners and operators will use the Risk Analysis and Management 

for Critical Asset Protection methodology to assess their assets once the 

methodology is finalized.”85 

The tension between advocates for one assessment methodology or the 

other was palpable during our interviews. Food industry and government 

representatives in other departments have not embraced DHS’ support of 

the Risk Analysis and Management for Critical Asset Protection 

assessment methodology over CARVER+Shock. A Food Safety and 

Inspections Service representative underscored the fact that the White 

House had instructed the food sector to use CARVER+Shock as its 

standard vulnerability assessment tool, and expressed dismay that DHS 

sought to shift to another tool. FDA and USDA had collaborated to apply 

CARVER+Shock to the food and agriculture sectors. They were not keen 

on shifting to another tool. Some industry representatives are also 

reluctant to embrace a new vulnerability assessment tool, as they 

considered the familiar CARVER+Shock to suit their needs. 

85 DHS, Draft NIPP, November 2, 2005, p. 125. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Despite DHS’ early stand in favor of Risk Analysis and Management for 

Critical Asset Protection, the food sector’s support for CARVER+Shock 

remains unabated. Perhaps the best expression of this is the tool’s use in 

the largest current food sector vulnerability assessment initiative. 

Announced in July 2005, the Strategic Partnership Program for 

Agroterrorism Initiative is an FBI-funded effort to develop a 

comprehensive perspective on food and agricultural vulnerabilities by 

performing new assessments and validating old ones. FDA or USDA 

representatives serve as Strategic Partnership Program Agroterrorism 

assessment facilitators, while DHS, FBI, and state and local departments 

of health and agriculture, as well as volunteer private sector 

representatives, participate in these assessments.86 Participants plan to 

complete 52 vulnerability assessments for food and agriculture subsectors 

by 2007. 

Further confounding matters is the fact that different DHS components 

support different assessment methodologies. In practice, DHS is 

supporting three different approaches. As noted earlier, the National 

BioDefense Analysis and Countermeasures Center and the Infrastructure 

Partnerships Division currently support CARVER+Shock assessment 

initiatives, while Grants and Training sponsors a course development 

effort at the University of Tennessee based, in part, on Operational Risk 

Management. Meanwhile, Risk Management Division staff maintain that 

the only suitable approach is Risk Analysis and Management for Critical 

Asset Protection. 

Although DHS has officially advocated the universal adoption of the Risk 

Analysis and Management for Critical Asset Protection assessment, the 

department has yet to develop final guidance and tools to support its use in 

the food sector. The Office of Infrastructure Protection reports that 

technical specifications for Risk Analysis and Management for Critical 

Asset Protection modules have been written for five infrastructure sectors, 

and that modules are in use in the nuclear power and chemical 

manufacturing industries. Despite progress in other sectors, DHS has not 

completed overarching guidance and sector-specific modules for the food 

and agriculture sector. Furthermore, an Office of Infrastructure Protection 

manager advised us that DHS has no short or medium term plans to 

proceed with the costly process of developing a Risk Analysis and 

Management for Critical Asset Protection module for the food sector. 

86 Center for Food Safety and Applied Nutrition, “Strategic Partnership Program Agroterrorism (SPPA) Initiative: 

A Joint Effort of the FBI, DHS, USDA, and FDA to Help Secure the Nation's Food Supply,” August 2005; and 

Center for Food Safety and Applied Nutrition, “SPPA Initiative Questions and Answers,” September 23, 2005. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Discord on the choice for an assessment tool is a point of major concern. 

If DHS ultimately determines that past USDA, FDA, and private sector 

CARVER+Shock assessments are not compatible with its baseline criteria 

for use in comparative risk analysis, then this large body of work will be 

rendered moot in cross-sector considerations. This concern becomes more 

pressing as the volume of CARVER+Shock assessments grows. 

S&T reports that it has plans to engage its Centers of Excellence and the 

national labs to research “all available [assessment] tools and 

methodologies and then to develop, test, and field” a new sector specific 

tool to replace CARVER+Shock, in consultation with the sector. The 

need for action in this area is urgent. Those conducting food sector 

assessments should be able to proceed with the confidence that their 

efforts will be considered in DHS’ comparative risk analysis. DHS must 

do as it has committed in the NIPP, and make a determination about the 

suitability of existing food assessment methodologies for inclusion in 

comparative risk analysis.87 Further, DHS must establish how these 

assessments will be applied in a broader sector-specific risk methodology 

in collaboration with USDA and FDA. These reviews should proceed 

without delay. Accordingly, we recommend that the Assistant Secretary 

for Infrastructure Protection: 

Recommendation #9: Expedite the review of existing food sector 

assessments to determine their suitability for use in comparative risk 

analysis, and collaboratively identify the role of these assessments in the 

sector-specific risk methodology. 

Additional Staff Support Needed 

Although DHS has addressed the remainder of its basic food sector 

responsibilities, public and private sector partners did not characterize the 

department’s activities in many of these areas as particularly effective. 

DHS would be better equipped to acquit its responsibilities if it devoted 

more staff resources to the post-harvest food sector. As noted earlier, the 

public and private sector viewed DHS staff currently working on postharvest issues as professional and dedicated. DHS simply needs 

additional expertise to address its responsibilities in the sector. In all of 

DHS, we encountered only nine staff who attend to post-harvest food 

defense issues as a significant portion of their duties. Two left the 

87 DHS, NIPP, June 30, 2006, p. 146. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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department during the course of our review. The remaining seven have 

more expertise in pre-harvest than post-harvest food issues, and almost all 

of them devote the bulk of their time to pre-harvest matters. 

Without an internal audience that is receptive to post-harvest food issues 

and is knowledgeable in the field, much of the related work being done on 

the department’s behalf will not be developed or leveraged to its full 

potential. In our view, the paucity of qualified and engaged DHS staff has 

contributed to the internal and external coordination and prioritization 

challenges discussed in this report. 

Several individuals we interviewed saw the large contractor contingent 

within DHS’ food sector staff as a detriment. They expressed frustration 

that contractors who were not able to speak on DHS’ behalf were their 

principal points of contact for the department. Because DHS contractors 

did not have the authority to command the department’s resources, they 

were perceived to have little to offer in interagency forums. Some 

representatives of other departments added that they had concerns about 

the potential for high turnover among DHS’ contractor base. Finally, one 

government representative outside DHS said that he thought some of 

DHS’ contractors were overstating threats to food and agriculture in order 

to ensure the renewal of their contracts. These perceptions have damaged 

DHS’ relationship with its food sector partners. 

We recommend that the Assistant Secretary for Infrastructure Protection, 

Under Secretary for Science and Technology, and Chief Medical Officer: 

Recommendation #10: Pursue the recruitment, hiring, and retention of 

several additional staff with expertise in matters of post-harvest food 

defense. 

Opportunities for Additional Work 

While DHS must position itself better to address its full range of food 

defense responsibilities, it also could take steps to support food defense in 

areas in which the department has established core competencies and skill 

sets. If DHS takes action in these areas it could contribute usefully where 

other federal partners may have less developed programs. These areas 

include food imports, food in transit, consequence modeling and 

simulation, exercise support, situational awareness, and protective 

measure initiatives. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Food Imports 

USDA trade data suggest that the United States imported $76.7 billion in 

food for human consumption 2005. That year, more than 4.5 million 

shipments of food entered the United States from abroad. These imported 

foods account for approximately 11% of food consumed in the United 

States according to USDA Economic Research Service estimates.88 

Imported foods have been linked to a number of significant foodborne 

illness outbreaks in the United States. In 2003, hundreds of restaurant 

patrons in four states became ill with hepatitis A after consuming 

contaminated green onions from Mexico.89 In 1996 and 1997, 

Guatemalan raspberries were linked to more than 2,500 Cyclospora 

infections throughout the United States and Canada. Salmonella from 

Mexican cantaloupes afflicted about 25,000 Americans in 1989.90 

Beyond their public health effects, foodborne illness outbreaks have 

economic repercussions. And the adverse economic effects of foodborne 

illness outbreaks from imported foods are frequently distributed across all 

producers of the food product and its agricultural inputs, both domestic 

and foreign. A USDA examination of three cases of foodborne illness 

from imported foods found that: "In each case, damage was not limited to 

the producers of the contaminated product. Anyone producing a product 

for the U.S. market, including U.S. growers, may be caught in the 

consumer backlash against a product ...”91 

The risk of contamination of imported foods is increased by the potential 

for product tampering and adulteration. Terrorists could adulterate foods 

for U.S. consumption without entering the country. Indeed, many food 

imports originate or transship through countries with well-articulated 

terrorist organizations. CBP reports that there were 203,403 commercial 

entries92 of food products from “special interest countries” – countries that 

present a potential terrorist threat to national security – into the United 

88 Jerardo, Andy. Import Share Of U.S. Food Consumption Stable At 11 Percent, FAU-79-01, July 2003, p. 1. 89 CDC, “Hepatitis A Outbreak Associated with Green Onions at a Restaurant --- Monaca, Pennsylvania, 2003,” 

MMWR Weekly 52(47), November 28, 2003. pp. 1155-1157. 90 FDA, “Risk Assessment for Food Terrorism and Other Food Safety Concerns,” October 13, 2003. 

(http://www.cfsan.fda.gov/~dms/rabtact.html).

91 USDA, Economic Research Service. International Trade and Food Safety: Economic Theory and Case Studies. 

November 2003. p. 93. 92 In this context, a “commercial entry” refers to an “entry line,” or single shipment of merchandise that importers

submit to CBP for release into U.S. commerce. These entries may take the form, for example, of a cargo container 

off a ship or lesser quantities of goods filling a portion of a container or a mailed parcel. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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States in 2005.93 According to CBP statistics, the volume of food products 

imported from these nations has increased 77% since 2000. 

While threat of contaminated food products entering the United States 

from abroad is worth noting, it can be overstated. Limitations on the 

survivability of some possible threat agents, security measures to prevent 

product theft abroad, and careful quality controls for many imported 

goods, combine to reduce vulnerabilities. In addition, imported food items 

are often subject to extensive processing before they reach American 

consumers. 

CBP addresses the risks posed by imported foods through activities in at 

least four areas. First, as discussed earlier, CBP has taken an active role in 

supporting FDA and USDA in targeting imported foods for additional 

scrutiny and inspection. CBP assisted in the creation of targeting rules for 

FDA’s prior notice requirement, and for USDA’s Animal and Plant Health 

Inspection Service. In addition, CBP is moving forward with the 

development of another rule set for the Food Safety and Inspections 

Service, which was to have been piloted recently. 

CBP has also supported federal food partners with trade data and systems 

access. CBP worked closely with FDA to establish its Prior Notice 

Center, which is co-located with CBP’s National Targeting Center. CBP 

also has been active in an interdepartmental Food Safety Working Group 

to develop an integrated food import process and information systems to 

address related hazards, including those presented by intentional 

contamination. 

Additional food defense activities may develop under CBP’s Director of 

Agricultural Bioterrorism Countermeasures within its Office of Field 

Operations. Preliminary plans reportedly call for CBP’s Agricultural 

Bioterrorism Countermeasures program to speed the development of 

additional food targeting criteria, and help train inspectors to enhance their 

ability to recognize and interdict bioterrorism threats. 

Other CBP opportunities to improve food defense rest with a major private 

sector trade partnership initiative. Through the Customs-Trade 

93 This figure reflects the number of commercial entries of food products for human consumption. Food products 

for human consumption were identified using Harmonized Tariff Schedule codes associated with imported 

merchandise. The OIG, in consultation with a CBP agriculture trade specialist, developed a list of Harmonized 

Tariff Schedule codes representing products for human consumption by adjusting an FDA listing of import codes 

subject to prior notification requirements. The OIG modified this listing to ensure the inclusion of all products for 

human consumption, including those regulated by USDA, and the exclusion of products that principally serve as 

animal feed. A listing of the tariff codes used in this analysis is available from the OIG upon request. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Partnership Against Terrorism, CBP is attempting to improve supply chain 

security and reduce the chance that dangerous cargo enters the United 

States. In exchange for expedited processing and more limited inspection, 

private sector participants provide CBP with supply chain security profiles 

and commit to implement agreed to security measures. Launched in 

November 2001, the Customs-Trade Partnership Against Terrorism now 

has more than 5,700 certified members, including importers, customs 

brokers, terminal operators, carriers and foreign manufacturers.94 

Customs-Trade Partnership Against Terrorism members account for a 

significant share of total food imports. In 2005, members were associated 

with 18% of imported foods. That year, Customs-Trade Partnership 

Against Terrorism members also accounted for 23% of food imports from 

special interest countries. 

While the Customs-Trade Partnership Against Terrorism provides generic 

guidance and specifications for supply chain security, the program could 

do more to help secure the food industry’s supply chain. At present, 

Customs-Trade Partnership Against Terrorism security guidelines are less 

detailed and targeted than optimal from a food defense perspective. 

Available FDA and Food Safety and Inspections Service guidelines are 

more detailed than the Customs-Trade Partnership Against Terrorism 

guidance on the actions importers can take to improve security of the food 

supply. FDA, for example, lists 11 different management actions that can 

be taken to prepare for possible tampering events. These include various 

strategies for dealing with a food contamination event, such as internal and 

external communication plans and maintenance of floor and food flow 

plans in a secure location.95 The Customs-Trade Partnership Against 

Terrorism could use these or other similar guidelines as the basis for a 

separate program guideline for food importers. To ensure consistency 

with the Customs-Trade Partnership Against Terrorism mission of 

countering terrorist threats, rather than improving food safety, such 

guidance should focus on preventing and addressing food adulteration or 

the intentional introduction of animal or zoonotic disease. 

Short of the elaboration of separate security guidelines for food importers, 

the Customs-Trade Partnership Against Terrorism program could include 

references to existing food security guidelines in its security profile 

guidance. Program materials currently recommend training programs on 

94 CBP, “Remarks of Acting Commissioner Deborah J. Spero,” Customs-Trade Partnership Against Terrorism 

Conference, March 1, 2006. 

(http://www.cbp.gov/xp/cgov/newsroom/commissioner/speeches_statements/03012006_ctpat_conf.xml)

95 FDA, “Guidance for Industry - Importers and Filers: Food Security Preventive Measures Guidance,” March 21, 

2003. (http://www.cfsan.fda.gov/~dms/secguid7.html) 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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security, but do not list USDA and FDA food importer guidelines as a 

training resource. At minimum, Customs-Trade Partnership Against 

Terrorism should expand awareness of these products. 

We recommend that the Commissioner of Customs and Border Protection: 

Recommendation #11: Consider the elaboration of food-specific criteria 

and guidelines for Customs-Trade Partnership Against Terrorism food 

industry firms in collaboration with FDA and USDA. 

Food in Transit 

Homeland security officials appreciated early that the transportation of 

food products represented a point of particular vulnerability in the food 

supply chain. In February 2003, the White House Office of Homeland 

Security noted that the food sector depends on “transportation system 

owners and operators ... to meet the safety and security standards 

necessary to protect food products in transit.”96 A security failure in this 

area could have significant consequences, as food products in transit are 

sometimes distributed to a number of locations. 

Findings from a recent report by the American Transportation Research 

Institute highlight the need for additional work in this area. In January 

2005, the Research Institute released a USDA-funded report on food 

transit security and the perspectives of food carriers, including a survey of 

motor carrier firms. The American Transportation Research Institute 

reported that a leading concern among survey respondents was security at 

rest stops and parking areas. Some carriers, especially those using a 

higher percentage of contracted drivers, also labeled personnel issues as a 

major concern. Indeed, the Research Institute noted that some trucking 

companies have 100% annual staff turnover.97 Weaknesses in rest stop 

and personnel security provide openings for the deliberate contamination 

of food products. Further, contamination at these points in the supply 

chain could be difficult to trace or attribute. 

DHS seeks to improve personnel security in the transportation arena 

through its Transportation Worker Identification Card program. The 

Transportation Worker Identification Card program aims to create a secure 

credential for transportation workers to use in accessing key transportation 

96 The White House, Office of Homeland Security. The National Strategy for the Physical Protection of Critical

Infrastructure and Key Assets, February 2003, p. 39. 97 American Transportation Research Institute, Identifying Vulnerabilities and Security Management Practices in

Agricultural and Food Commodity Transportation, January 2005, pp. 4, 6, 8, and 9. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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facilities, including seaports, airports, trucking, and rail facilities. In 

exchange for the Transportation Worker Identification Card credential, 

transportation workers who enroll in the program provide documentation 

to verify their identity and submit to a security threat assessment. By 

providing a more secure credential and performing threat assessments on 

transportation workers through the Transportation Worker Identification 

Card program, DHS expects to reduce unapproved individuals’ access to 

key facilities. The Transportation Worker Identification Card program is 

currently in its initial roll out phase targeting workers who access 

maritime facilities. 

DHS has another program with the potential to improve rest stop and 

parking area security for food transporters. A current DHS program 

targeting motor carrier operators and other highway professionals, 

Highway Watch, provides a possible means for increasing awareness and 

reporting in this area. Highway Watch is a national transit security 

program funded though a cooperative agreement with TSA. Outreach and 

training about security risks are key features of the program. Another 

central feature of the program is its National Call Center, which handles 

calls from highway professionals who report suspicious activity or safety 

concerns. 

Although Highway Watch currently devotes no specific attention to 

threats to food in transit, it has potential to improve the protective status of 

food in transit. By using current training and outreach activities to raise 

awareness of the potential for food adulteration, for example, Highway 

Watch could improve transporter reporting of suspicious activities in the 

vicinity of tankers and freighters carrying food items. If increased 

sensitivity in this area were coupled with commodity-specific call center 

statistics, DHS could develop valuable leads about efforts to infiltrate food 

shipments and potentially prevent the theft or adulteration of food 

products in transit. 

DHS also can do more to study and disseminate information on the 

application of tracking and seals technologies to the transportation of food. 

DHS is currently sponsoring a related effort at the University of Kentucky. 

Funded by S&T, this project explores means of tracking milk product 

through the early stages of the supply chain for the purpose of increasing 

security. Additional research into the ways that other technologies can be 

applied to the security of food in transit may help increase the adoption of 

these technologies by food industry transporters and reduce vulnerability 

to food adulteration at a number of points in the supply chain. 

We recommend that the Under Secretary for Preparedness: 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Recommendation #12: Study ways to integrate food defense awareness 

into existing transportation security programs fully and consider additional 

research to improve the security of food in transit. 

Exercise Support 

Food contamination exercises provide key learning opportunities for food 

sector representatives, and generate valuable lessons about how the 

response to a food-related incident is likely to proceed. Sector 

Coordinating Council and Government Coordinating Council 

representatives said that they found food contamination exercises to be 

very instructive. Meanwhile, experts in infrastructure modeling reported 

that exercises provide them with important information about how 

different groups are likely to respond in an event, and that this information 

critically informs their modeling and simulation efforts. 

DHS has extensive experience in the conduct, facilitation, and support of 

homeland security exercises. As of June 2006, Grants and Training had 

provided direct support for 1,149 exercises through its Exercise and 

Training Division, and provided financial support for an additional 299 

exercises through its Urban Areas Security Initiative and State Homeland 

Security Program grants. In addition, Grants and Training sponsors and 

coordinates a major biennial top officials (TOPOFF) exercise drawing in 

representatives from a broad sweep of federal, state, and local agencies 

and the private sector. In total, Grants and Training has expended more 

than $317 million on Urban Areas Security Initiative, State Homeland 

Security Program, and TOPOFF exercises since DHS’ formation. It also 

provides technical support and sets standards for exercises through its 

Homeland Security Exercise and Evaluation Program. 

In the context of its extensive overall exercise support program, DHS has 

provided little direct support for or attention to exercises relating to food 

contamination. Since 2003, DHS has provided direct support for only four 

post-harvest food-related exercises through Grants and Training’s 

Exercise and Training Division. DHS has sponsored six additional postharvest food contamination table-top exercises through the Multi-State 

Partnership for Security in Agriculture. And while the June 1, 2006 

National Exercise Schedule listed a total of 226 exercises over the 

following year, it did not register a single post-harvest food-related 

exercise. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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By devoting more attention to post-harvest food exercises, DHS can 

capitalize on valuable opportunities to gather information and improve 

preparedness. Participants in the exercises DHS has sponsored reported 

that their participation paid dividends in a number of areas. Exercise 

participants develop a richer understanding of the consequences of an 

event and their related decisions, identify preparedness needs, and learn 

about alternative responses. 

In pursuing additional food contamination exercises, DHS should present 

scenarios that test the quality and extent of coordination that occurs when 

contamination events cross jurisdictional lines. Contaminated foods are 

frequently distributed across a broad geographic range before they are 

consumed. Food contamination incidents like this trigger mobilization 

and response from widely scattered local and state authorities in agencies 

with public health, food inspection, and agricultural missions. Research 

on foodborne illness outbreaks has demonstrated that outbreak 

investigations involving multiple jurisdictions result in slower responses 

than those conducted by a single jurisdiction. Food contamination 

exercises that involve a range of local, state, and federal authorities can 

help isolate factors that slow multi-jurisdictional response and identify 

solutions. 

We recommend that the Under Secretary for Preparedness: 

Recommendation #13: Expand efforts to sponsor food contamination 

event exercises with an emphasis on exercises spanning multiple state and 

local jurisdictions. 

Consequence Modeling and Simulation 

Effective modeling and simulation of homeland security incidents can 

improve our understanding of their consequences, and provide key 

information support to decision-makers during a related event. Modeling 

and simulation of food contamination incidents, however, has not 

developed to the extent desirable. In a 2002 report that advocated 

additional modeling and simulation of bioterrorism events, the Institute of 

Medicine reported that major uncertainties in our understanding of the 

impacts of a biological attack on food remained.98 

98 Institute of Medicine, National Research Council of the National Academies. Countering Bioterrorism: The Role 

of Science and Technology. Washington, DC: The National Academies Press, 2002. p. 29. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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DHS has access to modeling tools and expertise that can be applied to 

understand food sector consequences better. DHS currently funds 

modeling and simulation efforts of the Critical Infrastructure Protection 

Decision Support System, the National Infrastructure Simulation and 

Analysis Center, and the National Center for Food Protection and Defense. 

These programs have developed promising models in several areas of the 

food supply chain. One of the National Labs, for example, has developed 

advanced models for the beef and corn production, processing, and 

distribution chains, including a wide array of corn-based products. 

Meanwhile, the NCFPD has developed food contamination models that 

predicted clinical illness within six hours of actual clinical data from a 

recent E. coli outbreak. 

Collectively, related modeling initiatives have charted a fraction of the 

food industry. At the time of our fieldwork, these DHS-sponsored 

programs had developed detailed models or contamination scenarios for 

only the beef, dairy, corn, and fresh vegetable supply chains. Further, 

experts in all three of the programs acknowledged that their models for 

these supply chains needed further refinement, and could not account for 

the second- and third-order impacts of a major food contamination 

incident. 

Because DHS models of food supply chains and simulations of food 

contamination events are not fully developed, the department cannot fully 

appreciate the consequences of an incident of this type. Indeed, even 

preliminary simulations of food contamination events affecting most food 

products have not been developed. As a result, the department’s ability to 

assist decision-makers in many types of food contamination events is 

limited. 

To understand sector dynamics more fully and provide better decision 

support tools for government officials and private sector leaders, existing 

food sector models should be expanded to additional product lines and 

different logistical pathways, to include the import and export processes. 

According to food system modelers we interviewed, existing modeling 

efforts could also benefit by a more in-depth understanding of the likely 

public health response to a large-scale food contamination event, as well 

as variations in this response across jurisdictions. 

Consequence modelers should tap into ongoing food-related efforts in 

other areas to advance their food sector models and simulations. Modelers 

should participate, for instance, in the continuing Strategic Partnership 

Program Agroterrorism vulnerability assessments and exercises, in 

addition to working closely with biosurveillance programs. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Modeling efforts undertaken by the Critical Infrastructure Protection 

Decision Support System, the National Infrastructure Simulation and 

Analysis Center, and the NCFPD should complement one another. To this 

end, modelers at the NCFPD and the National Labs should collaborate 

formally, share information on modeling and simulation techniques, and 

exchange data on food product distribution, product consumption, and 

possible public health effects and responses. 

We recommend that the Under Secretary for Science and Technology, and 

the Assistant Secretary for Infrastructure Protection: 

Recommendation #14: Expand food sector modeling to other portions of 

the food supply chain for the purpose of improving food contamination 

event consequence assessment and decision support. 

Situational Awareness 

A recent end-to-end biodefense assessment conducted by the Homeland 

Security Council identified early warning and surveillance system 

development as a top priority for the nation.99 Early warning could 

significantly reduce morbidity and mortality from a food contamination 

incident if the public is immediately notified about contaminated food 

products and less contaminated product is consumed. 

DHS has the potential to increase situational awareness and early warning 

capabilities in this area through the National BioSurveillance Information 

System. A core component of the President’s National Biosurveillance 

Initiative, the National Biosurveillance Integration System is designed to 

improve national biosurveillance capabilities by drawing in information 

from various existing federal information systems. In particular, the 

National Biosurveillance Integration System is “to combine and analyze 

information collected from human, animal and plant health, food and 

environmental monitoring systems.”100 Plans for the National 

Biosurveillance Integration System call for this information, in turn, to be 

interpreted by subject matter experts from several agencies, and ultimately 

melded with intelligence data. 

99 Elsa A. Murano, Under Secretary for Food Safety, USDA, Testimony before the Agriculture, Rural Development,

and Related Agencies Subcommittee on the FY05 Appropriations for Programs Under its Jurisdiction, April 1, 2004. 

and DHS, Budget in Brief, Fiscal Year 2005, p. 51. 

(http://www.dhs.gov/interweb/assetlibrary/FY_2005_BIB_4.pdf) 100 Office of Management and Budget, The Budget of the United States Government, Fiscal Year 2006, February 7, 

2005, p. 37. 

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If properly implemented, the National Biosurveillance Integration System 

could help speed the characterization of foodborne illness outbreaks, 

reduce the detection time following an incident, and aid with agent 

identification. CDC officials report that, at present, “unusual but naturally 

occurring” food contamination events may not be seen by public health 

experts as intentional attacks for some time. When foodborne illness 

reports are coupled with intelligence information available to the National 

Biosurveillance Integration System, deliberate food contamination events 

may be recognized sooner. 

The National Biosurveillance Integration System also has singular 

potential to identify contamination events affecting both animal and 

human health – a capability that could be especially valuable under certain 

contamination scenarios. In the case of contamination of foods that are 

used in both animal feed and fare for human consumption, for example, 

the National Biosurveillance Integration System may be able to accelerate 

the process of linking resulting animal and human illnesses and identifying 

the point of contamination. 

While the National Biosurveillance Integration System has the potential to 

improve federal efforts to reduce the effect of adverse food-related events, 

at the time of our fieldwork it was not well-positioned to realize this 

promise due to its early stage of development. To fulfill its potential in 

this area, the National Biosurveillance Integration System must secure the 

active participation of experts from other federal agencies in monitoring 

incoming information. As of June 2006, however, the National 

Biosurveillance Integration System had secured the participation of only 

one detailee from a federal agency outside of DHS. Effective surveillance 

of food-related information will be aided by the engagement of FDA, 

CDC, and Food Safety and Inspections Service staff, none of which have 

committed representatives. DHS staff knowledgeable about the program 

reported that related negotiations with USDA were nearing completion, 

but that discussions with CDC and FDA about sharing information and 

providing staff support were still in their early stages. 

In addition to securing qualified staff support from other agencies, the 

National Biosurveillance Integration System must integrate information 

from the full range of federal systems that monitor foodborne illness. 

Early plans for the National Biosurveillance Integration System only 

reflected the inclusion of information from two food-related health 

monitoring systems – a Food Safety and Inspections Service consumer 

complaint monitoring system and a system with data from food 

laboratories. Without information from other federal foodborne illness 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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monitoring systems, the National Biosurveillance Integration System may 

miss opportunities to identify and link related illness patterns. Other 

federal foodborne illness monitoring systems like the CDC’s FoodNet, 

PulseNet, the Electronic Foodborne Outbreak Reporting System, and the 

USDA’s Food and Agriculture Biosurveillance Integration System may be 

appropriate for inclusion in the National Biosurveillance Integration 

System. These systems support the reporting and surveillance of 

foodborne illnesses, tracking of and information sharing on illness-causing 

organisms, and health department advisories.101 

We recommend that the Chief Medical Officer: 

Recommendation #15: Evaluate the advisability and feasibility of 

integrating additional federal foodborne illness reporting, surveillance, and 

detection systems into the National Biosurveillance Integration System. 

Protective Measure Initiatives 

Food industry and government representatives reported that there is a need 

for additional guidance on specific food-related protective measures. One 

representative of a major food company said that she sought more 

detailed, specific information on possible protective measures. Other 

industry representatives said that they wanted guidance on what protective 

measures to put in place to address their greatest vulnerabilities and sought 

protective measures guidance they could provide smaller producers and 

suppliers. 

DHS has issued food industry protective measure guidance at both the 

asset and subsystem levels. This guidance could be modified to satisfy the 

informational needs of food industry representatives more completely. 

DHS has issued two types of asset-level protective measure guidance 

products – Buffer Zone Plans and Site Assistance Visits. Buffer Zone 

Plans are products of the Buffer Zone Protection Program, a joint effort 

between Grants and Training and the Office of Infrastructure Protection. 

Public and private infrastructure owners and state and local authorities 

develop Buffer Zone Plans with the assistance of Office of Infrastructure 

Protection field staff. The resulting plans identify vulnerabilities 

associated with facility buffer zones, and analyze and categorize the level 

of risk linked to these vulnerabilities. Seven Buffer Zone Plans have been 

101 For more information on these systems, see: http://www.cdc.gov/foodnet/, http://www.cdc.gov/pulsenet/, and 

http://www.cdc.gov/foodsafety/fsactivities.htm 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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completed on food sector assets. Perhaps because they focus on threats 

“outside the fence,” in the areas surrounding facilities, Buffer Zone 

Protection Program reports on food sector assets do not always account for 

the threat of contaminating food within the facilities. As a result, the 

program’s potential for mitigating threats to the food supply is greatly 

constrained. In any case, food sector assets represent less than one percent 

of the Buffer Zone Protection Program sites DHS had funded as of 

January 2006. 

Site Assistance Visits combine vulnerability assessment and protective 

measure guidance. Between October 2003 and May 2005, DHS 

conducted six Site Assistance Visits of food sector assets. These reports 

describe general vulnerabilities and mitigation strategies for covered 

facilities. Possible biological contamination of food products is discussed 

in more detail than in reports produced under the Buffer Zone Protection 

Program. As a result, Site Assistance Visit reports are likely to be more 

valuable to food industry firms from a protective measures standpoint. 

Because they are facility-specific and usually classified, though, they offer 

little to the food industry at large. 

DHS has also prepared and distributed two types of subsystem-specific 

reports relating to food sector protective measures. Potential Indicators of 

Terrorist Activity reports offer information about detecting possible 

terrorist activity, while Protective Measure reports identify suggested 

actions and best practices to diminish potential threats. These reports are 

distributed by DHS to state and territorial Homeland Security Offices, and 

are to be shared, in turn, with asset owners and law enforcement 

personnel. 

Protective Measure and Potential Indicators of Terrorist Attack reports we 

reviewed were not fully developed in the area in which they had the 

potential to offer most to industry – in the recommendation of customized 

protective measures. The protective measures guidance we reviewed often 

proposed generic security measures and provided little or no information 

about specific steps that could be taken by firms with facilities in a 

particular subsector. In cases in which more specific guidance was 

provided, it was largely derivative. A Protective Measures report on the 

transportation of food and agricultural commodities, for example, 

repeatedly referred to published FDA and USDA guidance for transporters 

and added little new information. While these documents might provide 

useful information to law enforcement on the basic elements of food 

industry subsystems, information of this kind is not valuable to industry 

representatives who already have an intimate understanding of their 

operations. Perhaps as a result, even though these documents were 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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distributed with instructions to share them widely, private sector experts 

we spoke with reported very limited familiarity with them. 

DHS should use its relationships with the Sector Specific Agencies, other 

government agencies, and industry to develop vibrant informational and 

analytical products that meet food industry interests and needs. To this 

end, DHS could identify food industry protective measure models and best 

practices and disseminate these more widely to improve the protective 

environment across the food industry. These products could also highlight 

useful technologies and methods to be applied to improve security at the 

operational level. 

DHS could develop written products that fit this mold by building on 

asset-specific knowledge and tapping into ongoing assessment efforts. 

Although a senior Office of Infrastructure Protection manager said that no 

additional Site Assistance Visits are planned for the food sector in the 

foreseeable future, improved protective measures guidance could also 

glean from Site Assistance Visit reports covering new parts of the sector. 

Additional supporting analysis could be derived from work under the 

Strategic Partnership Program Agroterrorism program, the Homeland 

Infrastructure Threat and Risk Analysis Center, the National Center for 

Food Protection and Defense, and further engagement with the USDA, 

FDA, and the private sector. 

We recommend that the Assistant Secretary for Infrastructure Protection: 

Recommendation #16: Continue to develop and disseminate information 

about food subsystem-specific operational protective measures and 

operational best practices in collaboration with FDA and USDA. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Conclusion 

While there is no consolidated DHS leadership attention to food defense 

and critical infrastructure protection, one unit in the department monitors 

and rates the food sector’s progress in achieving some related objectives. 

The Office of Infrastructure Protection monitors the progress of critical 

infrastructure protection efforts in each of the federally recognized critical 

infrastructure sectors. The Office of Infrastructure Protection’s evaluation 

of sector progress is captured in part in a sector report card, that tracks 

basic progress in laying the foundation for future critical infrastructure 

protection success in the sector. In its December 2005 report card, the 

Office awarded the food and agriculture sectors the highest performance 

rating in all three of its major sector status categories, and a “green light” 

for 19 of 22 sector metrics. Office of Infrastructure Protection officials 

have added to this warm assessment with statements that the food and 

agriculture sectors have “created the blueprint” in the critical 

infrastructure protection arena. This positive assessment does not coincide 

with the difficulties we encountered. 

To improve overall U.S. food defense and critical infrastructure 

protection, DHS must execute its related responsibilities more effectively. 

Disjointed DHS work on defense of the food supply caused by the absence 

of a clear leader brought confusion in cases in which DHS made good 

faith efforts to work with partners. Confusion also prevailed when 

partners or potential partners made efforts to reach out to DHS on 

information sharing, consultation, and other coordination efforts. The 

recommendations in this report are designed to improve the department’s 

internal and external food sector activities. By taking the steps 

recommended, DHS will be able to more fully address the vulnerabilities 

of the nation’s food sector. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Management Comments and OIG Analysis 

In August 2006, we shared a draft of this report with the Offices of 

Infrastructure Protection, Grants and Training, Chief Medical Officer, 

S&T, and CBP, and subsequently met with staff in each of these units to 

gather their feedback. Each office provided general and technical 

comments on the draft report, and responses to the draft’s 

recommendations. The Preparedness Directorate consolidated these 

comments and responses and provided them to us in the last days of 

November. We considered each of these comments and responses, and 

additional documentation provided, and made responsive edits and 

additions to some sections of the report. 

Since we issued our draft report for the department’s review and comment, 

we have removed one recommendation (formerly recommendation #6). In 

it, we had recommended that the department publish a final rule on its 

Protected Critical Infrastructure Information program. Shortly after we 

issued our draft report, the department published its final rule. 

In its appraisal of our remaining recommendations to enhance DHS’ 

performance and improve the security of the food supply, the department 

generally concurred. Of this report’s 16 recommendations, the department 

concurred with 12. Of the remaining 4 recommendations, one has been 

amended in line with the department’s comments, and we anticipate that 

DHS will concur with it in its final form. The department did not concur 

with the remaining 3 recommendations and we have not amended them. 

We will continue to monitor the department’s progress in implementing 

these recommendations, and will close them when the department has 

established that it has taken appropriate corrective actions. 

We have summarized the department’s responses to this report’s 

recommendations below, along with our analysis. 

Recommendation #1: Identify a single senior DHS official to be 

accountable for coordinated implementation of all DHS food sector 

responsibilities, and provide this official with clear authorities and 

adequate staffing to perform this function. 

DHS Response: The department expressed general agreement with this 

recommendation, and indicated that this senior manager would be “most 

appropriately located” within the Preparedness Directorate. In the 

department’s view, this senior manager should be at the Deputy Assistant 

Secretary level or higher so that he or she is at a level commensurate with 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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similar leaders at USDA and FDA. Further, the department acknowledged 

the need for this official to have the authority to oversee the coordination 

of efforts within several DHS components. 

OIG Evaluation: We believe that the effective implementation of this 

recommendation will help enhance DHS performance in the areas of food 

defense and critical infrastructure protection. We look forward to the 

designation of a senior DHS official to be accountable for coordinated 

implementation of all DHS food sector responsibilities. Upon his or her 

designation, we will assess the appropriateness of the authorities and staff 

support he or she has been provided. This recommendation is resolved – 

open. 

Recommendation #2: Restore communication with the Food ISAC by 

re-establishing a DHS point of contact and creating food-industry-specific 

products for ISAC distribution. 

DHS Response: The department did not agree to restore communication 

with the ISAC. DHS responded that the ISAC had been subsumed into the 

Sector Coordinating Council, and that the Sector Coordinating Council is 

“responsible for the appropriate means or entity for information sharing.” 

The department also wrote that the ISAC Council and Partnership for 

Critical Infrastructure Security, which includes Food and Agriculture 

Sector Coordinating Council representation, were currently working to 

“determine the most appropriate information sharing framework for the 

sector.” 

While the department took issue with restoring communication with the 

Food ISAC, it noted that it has created food and agriculture related 

products in the past and said it will continue to do so. In particular, the 

department highlighted three Homeland Infrastructure Threat and Risk 

Analysis Center product types it will use in the future to address private 

infrastructure stakeholders, including those in the food and agriculture 

sectors. 

OIG Evaluation: The organization that manages the Food ISAC 

participates in the Sector Coordinating Council, but that should not 

preclude it from having a productive role outside of participation on the 

Council. Nor should its engagement with the Sector Coordinating Council 

constitute a reason not to maintain a point of contact with it. That the 

department has resisted a step as basic as maintaining a point of contact 

with the Food ISAC is troubling. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Communication with the ISAC continues to be important because the 

other information sharing mechanisms DHS has established are still in 

early stages of development. Whereas the reach of other DHS information 

sharing methods remains limited, the ISAC can potentially access a 

significantly larger audience. At minimum, if DHS were to leverage this 

greater informational reach, it could improve communication with the 

sector in a crisis. This recommendation is unresolved. 

Recommendation #3: Seek out improvement in DHS’ relationship with 

food sector partners through: 

• Better attention to the demands and information flow related to 

coordinating council comments on DHS initiatives; 

• Higher level DHS official attendance at council meetings; and 

• Increased responsiveness to council requests for information, 

briefings, and presentations by other DHS components. 

DHS Response: DHS concurred with this recommendation and provided 

two examples of its work in this area: discussions with the Sector 

Coordinating Council about the content of the Homeland Security 

Information Network, and the Assistant Secretary’s attendance at sector 

council meetings. 

OIG Evaluation: In reviewing the department’s progress in this area, we 

will seek specific information about measures in each of the three areas for 

improvement identified in the recommendation. This recommendation is 

resolved – open. 

Recommendation #4: Expand National Infrastructure Coordinating 

Center outreach efforts to include outreach targeted to the food sector, and 

actively seek to increase information flow related to the food sector. 

DHS Response: The department concurred with this recommendation, 

and highlighted recent National Infrastructure Coordinating Center 

outreach and information sharing activities that touch on the food and 

agriculture sector. According to the department, the National 

Infrastructure Coordinating Center will work through the Homeland 

Security Information Network Food and Agriculture portal to facilitate 

information sharing in areas of interest to the Sector Coordinating 

Council. According to the department, FDA and USDA are encouraged to 

send representatives to the National Infrastructure Coordinating Center 

during major incidents and events. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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OIG Evaluation: The NIPP describes the National Infrastructure 

Coordinating Center as “a centralized mechanism and process for 

information sharing and coordination between the government, [Sector 

Coordinating Councils], [Government Coordinating Councils], and other 

industry partners.”102 In order for the Center to effectively serve in this 

capacity, its interaction with the sector must be more proactive. In 

reviewing the department’s corrective action plan, we look forward to 

learning about National Infrastructure Coordinating Center outreach 

activities that specifically target the food sector. In addition, we hope to 

learn the details of new efforts to increase information flow to the food 

sector. This recommendation is resolved-open. 

Recommendation #5: Evaluate the feasibility of providing financial 

support for and otherwise facilitate detailing state or local government and 

private sector representatives to support Office of Infrastructure Protection 

food sector efforts with an emphasis on Homeland Security Information 

System’s Food and Agriculture Portal. 

DHS Response: The department concurred with this recommendation, 

and noted the Government Coordinating Council’s call for state assistance 

and the Assistant Secretary for Infrastructure Protection’s support for this 

action. 

OIG Evaluation: The department concurs with this recommendation and 

some responsive efforts have been undertaken. In evaluating the 

department’s corrective action plan we will consider the Office of 

Infrastructure Protection’s progress in enlisting the support of a state 

representative in this area. We will also assess whether the Office of 

Infrastructure Protection has studied the feasibility of detailing local 

government and private sector representatives with ties to the food sector. 

Recommendation #6: Develop and maintain, in collaboration with the 

Office of Grants and Training and Office of Infrastructure Protection, a 

comprehensive report on DHS food sector research and education 

initiatives to be shared with FDA and USDA on a regular basis. 

DHS Response: The department agreed with this recommendation. In its 

response, the department wrote that S&T and the Offices of Grants and 

Training and Infrastructure Protection will develop comprehensive annual 

reports on food and agriculture sector research and education initiatives, 

102 DHS, NIPP, June 30, 2006, p. 64. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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and that these reports will be shared with FDA and USDA. These reports 

will build off an existing report on food and agriculture sector education 

initiatives developed by Grants and Training’s Agriculture Working 

Group. 

OIG Evaluation: The department’s plan to develop a comprehensive 

annual report on food and agriculture research and education initiatives 

fits squarely with our vision in this area. We will close this 

recommendation when we receive this report and can establish that it has 

been provided to FDA and USDA. Until then, this recommendation is 

resolved – open. 

Recommendation #7: Develop a grant process to support non-urban, 

multi-jurisdictional preparedness programs on a regional level. 

DHS Response: DHS did not concur with this recommendation. The 

department wrote that it could not comply with this recommendation 

because it did not have congressional authorization to alter the current 

Urban Areas Security Initiative program to support non-urban, multijurisdictional preparedness programs on a regional basis. 

OIG Evaluation: The department’s response appears to reflect a 

misreading of our recommendation. We did not recommend any changes 

to the Urban Areas Security Initiative, or the development of a new grant 

program. Instead, we recommended that Grants and Training develop a 

process for non-urban, regional preparedness programs to compete for 

funds. We believe that improvements in this regard are consistent with the 

stated priorities of the National Preparedness Goal, and congressional 

interest in encouraging support for regional initiatives.103 In a future 

response, Grants and Training can provide evidence that it has created a 

grant process more accessible to regional, non-urban programs by making 

adjustments in the State Homeland Security Program grant application 

process. 

Recommendation #8: Work with HHS and USDA to prepare an 

integrated food defense budget plan for Fiscal Year 2009 using a process 

that satisfies Homeland Security Presidential Directive 9 requirements. 

103 H.R. Conf. Rep. No. 109-241, at 69 (2005) for FY 2006; H.R. Conf. Rep. No. 109-699, at 153 (2006) for FY 

2007. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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DHS Response: DHS did not concur with this recommendation in its 

original form, and asserted that it called for activities beyond the 

department’s authority. The department observed that implementation of 

this Homeland Security Presidential Directive 9 provision called for the 

agreement and cooperation of government agencies outside of DHS – 

USDA and FDA, and noted that Homeland Security Council initially 

directed DHS to delay implementation of this requirement. 

Notwithstanding these concerns, DHS reported that it will submit an 

integrated budget plan for defense of the U.S. food system for FY 2009. 

OIG Evaluation: We have amended this recommendation to properly 

reflect our aim that the department satisfy its obligations under Homeland 

Security Presidential Directive 9. We now recommend that the 

department work with HHS and USDA to prepare an integrated food 

defense plan. In addition, we have changed the fiscal year we recommend 

the department to take this action from FY 2008 to FY 2009. Because the 

FY 2008 budgeting process is now drawing to a close, in our judgment it 

is no longer reasonable to expect DHS to comply with this requirement for 

that fiscal year. 

We expect to learn from DHS’ corrective action plan whether it concurs 

with the new wording of this recommendation, and look forward to 

reviewing evidence of the department’s collaborative work to prepare an 

integrated food defense budget plan. In the meantime, we consider this 

recommendation unresolved. 

Recommendation #9: Expedite the review of existing food sector 

assessments to determine their suitability for use in comparative risk 

analysis, and collaboratively identify the role of these assessments in the 

sector-specific risk methodology. 

DHS Response: DHS management concurred with this recommendation. 

The department acknowledged present consensus among five federal 

agencies that CARVER+Shock is currently the base available tool for use 

in the food and agriculture sector. It also noted that S&T is funding the 

development of a new assessment tool for the sector. 

OIG Evaluation: The department’s acknowledgement of 

interdepartmental consensus that CARVER+Shock is presently the “best 

available” assessment tool for use in the sector is an important step. We 

expect that the department will make consistent use of CARVER+Shock 

in its future sector assessment efforts until a new tool is developed. S&T’s 

support for the development of a new sector-specific assessment tool is 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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also a welcome development. We look forward to reviewing progress in 

this area in the coming year. This recommendation is resolved - open. 

Recommendation #10: Pursue the recruitment, hiring, and retention of 

several additional staff with expertise in matters of post-harvest food 

defense. 

DHS Response: DHS agreed with this recommendation, but took issue 

with its exclusive focus on the cultivation of expertise in the post-harvest 

food arena. The department recognized a need for additional staff with 

experience in the food and agriculture sector, and stressed that these 

additional staff will have to engage both pre- and post-harvest aspects of 

the sector. It also wrote that efforts were underway to expand DHS 

expertise in the sector by “leveraging” Food and Agriculture Government 

and Sector Coordinating Council expertise, and through a Homeland 

Infrastructure Threat and Risk Analysis Center initiative to designate 

private sector specialists to work with the program. 

OIG Evaluation: We appreciate the rich interconnectedness of pre- and 

post-harvest aspects of the food and agriculture sectors and note in this 

report that together they represent a complex system characterized by 

numerous interdependencies. Despite the vital linkages between these 

parts of the sector, they are also distinct in important ways and can be 

considered separately to positive effect. The pre- and post-harvest parts of 

the sector are occupied by different industry groups, and have many 

distinct stakeholders. This is evident in the structure of the Sector 

Coordinating Council, which has separate subcouncils for pre-harvest 

animal and plant production and agricultural inputs. Perhaps more 

importantly from a human resources standpoint, however, is that they 

often rely on different skill sets and expertise. Thus, veterinary expertise 

does not clearly translate into a working knowledge of the food sciences 

and related biochemistry. 

This recommendation was not intended to suggest that DHS’ pre- and 

post-harvest balance of expertise is askew. Indeed, we could not arrive at 

such a judgment without first evaluating the department’s pre-harvest staff 

expertise; something beyond the scope of this review. Rather, this 

recommendation relates our clear sense that DHS has insufficient staff 

expertise in the post-harvest arena. 

In reviewing the department’s 90-day action plan, we expect to learn about 

specific steps the department has taken to recruit, hire, and retain staff 

with post-harvest food sector expertise. Until we can confirm that the 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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department has taken action in these areas, this recommendation will be 

resolved – open. 

Recommendation #11: Consider the elaboration of food-specific criteria 

and guidelines for Customs-Trade Partnership Against Terrorism food 

industry firms in collaboration with FDA and USDA. 

DHS Response: DHS did not concur with this recommendation. In 

disagreeing with it, the department held that implementation of this 

recommendation would shift the Customs-Trade Partnership Against 

Terrorism away from its current “macro” focus and move toward a 

program dealing with the safety of products in individual shipping 

containers. According to the department, the program is intended to 

improve supply chain security, but not attest to the safety of individual 

products shipped through the supply chain. The department also writes 

that the program’s security specialists do not have the knowledge or skills 

to identify and prevent food adulteration or the introduction of animal or 

zoonotic diseases in the food manufacturing process. 

OIG Evaluation: According to the Customs-Trade Partnership Against 

Terrorism strategic plan, the program supports CBP’s priority mission of 

preventing terrorists and terrorist weapons from entering the country. As 

this report discusses, intentionally contaminated foods can be used as a 

weapon by terrorists. Because food products could be contaminated at 

different points in the supply chain before they arrive in the United States, 

and because the Customs-Trade Partnership Against Terrorism is designed 

to ensure that partnering firms improve their supply chain security 

practices, the program should consider measures to reduce the risk of a 

terrorist attack on imported foods. 

Current Customs-Trade Partnership Against Terrorism security criteria 

can be refined to address this risk more effectively. CBP can use existing 

USDA and FDA non-mandatory security guidance for food importers to 

help refine the program’s security criteria or develop separate guidance for 

program participants who handle food shipments. USDA and FDA 

standards in this area provide more detailed physical security, personnel 

oversight, and operational management guidance than existing CustomsTrade Partnership Against Terrorism criteria. We anticipate that if CBP 

were to implement changes in these areas, current CBP security specialists 

would be able to monitor these new criteria without any additional 

knowledge or technical expertise. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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CBP can satisfy this recommendation by demonstrating that it has 

weighed adjustments to its Customs-Trade Partnership Against Terrorism 

criteria in light of the risk of the deliberate contamination of imported 

foods. To do so, CBP would have to study possible refinements to its 

current Customs-Trade Partnership Against Terrorism criteria in light of 

USDA and FDA work in the area. CBP could then conduct cost-benefit 

analyses and risk assessments to determine whether it is appropriate to 

adopt any related refinements. CBP could then determine whether to 

apply these new criteria uniformly to all program participants or simply 

those handling food products. Because the department has indicated that it 

is unwilling to consider elaborating guidance and criteria to respond to this 

risk, however, this recommendation is currently unresolved. 

Recommendation #12: Study ways to integrate food defense awareness 

into existing transportation security programs fully and consider additional 

research to improve the security of food in transit. 

DHS Response: The department concurred with this recommendation, 

but recommended that it be redirected to the Transportation Security 

Administration. 

OIG Evaluation: We have directed this recommendation to the Under 

Secretary for Preparedness because of the Preparedness Directorate’s role 

in funding and managing training and transportation security grant 

programs, including Highway Watch. 

In reviewing the department’s corrective action plan for this 

recommendation, we will look for evidence that the department has 

examined ways to expand awareness of food security in the context of 

transportation security programs. We will also look for indications that 

the department has considered research initiatives related to food in 

transit. This recommendation is resolved – open. 

Recommendation #13: Expand efforts to sponsor food contamination 

event exercises with an emphasis on exercises spanning multiple state and 

local jurisdictions. 

DHS Response: DHS concurred with this recommendation and noted the 

need for exercises of this type to be coordinated with USDA and FDA. 

OIG Evaluation: The department has embraced this recommendation. 

We hope to review evidence of DHS support for exercises of this kind, 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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including exercise after-action reports, when we receive the department’s 

corrective action plan. This recommendation is resolved – open. 

Recommendation #14: Expand food sector modeling to other portions of 

the food supply chain for the purpose of improving food contamination 

event consequence assessment and decision support. 

DHS Response: DHS concurred with this recommendation, and 

highlighted additional work the department has sponsored in this area. 

OIG Evaluation: We look forward to learning more about the 

department’s modeling of additional portions of the food supply chain, 

when available. This recommendation is resolved – open. 

Recommendation #15: Evaluate the advisability and feasibility of 

integrating additional federal foodborne illness reporting, surveillance, and 

detection systems into the National Biosurveillance Integration System. 

DHS Response: DHS concurred with this recommendation. 

OIG Evaluation: The department’s receptiveness to this 

recommendation is a positive sign. We will monitor progress in this area 

during the course of our ongoing review of the National Biosurveillance 

Integration System. Before closing this recommendation, we will look for 

evidence that National Biosurveillance Integration System program 

managers have fully considered integrating the food-related information 

systems we reference in this report. For now, this recommendation is 

resolved – open. 

Recommendation #16: Continue to develop and disseminate information 

about food subsystem-specific operational protective measures and 

operational best practices in collaboration with FDA and USDA. 

DHS Response: DHS concurred with this recommendation and indicated 

that efforts in this area are currently being pursued through a collaborative 

effort between the Government and Sector Coordinating Councils. 

OIG Evaluation: We welcome the active engagement of public and 

private sector stakeholders in the process, and look forward to reviewing 

DHS contributions to this effort. This recommendation is currently 

resolved - open. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix A 

Purpose, Scope, and Methodology 

Purpose, Scope, and Methodology 

We conducted this review to determine whether DHS has effectively 

executed its responsibilities in the areas of food defense and critical 

infrastructure protection. We framed our review around three objectives: 

identifying DHS’ related responsibilities, determining how the department 

had operationalized those responsibilities, and assessing the quality of 

related programs and initiatives. To supplement our assessments in this 

area, we solicited expert opinions from representatives of other federal and 

state agencies, the private sector, and academia. 

Our fieldwork was conducted from November 2005 to April 2006. During 

this period, we conducted more than 80 interviews. Among those 

interviewed were a number of staff and contractors working for S&T, the 

Office of Infrastructure Protection, Office of Grants and Training, CBP, 

and Office of the Chief Medical Officer. We also met with representatives 

of departments of public health and agriculture from six states and 

localities, and personnel from other federal agencies including the USDA, 

FDA, CDC, FBI, and Office of the Director of National Intelligence. 

Finally, we interviewed academics and researchers in the food security 

and defense arena, quality assurance and security experts from food 

industry firms, and officials from industry associations representing food 

processors, distributors, retailers, and food service concerns. To ensure 

that we received the perspectives of representatives of a range of private 

and public sector views, we spoke with representatives of all four Sector 

Coordinating Council subcouncils pertaining to post-harvest food, as well 

as representatives of seven of the organizations on the Food and 

Agriculture Government Coordinating Council. 

We supplemented these interviews with extensive document review and 

analysis efforts. We studied DHS concept papers, grants, statements of 

work, project schedules, review panel analyses, and performance 

information. We also reviewed government threat assessments, 

vulnerability assessments, consequence assessments, protective plans for 

facilities, and security guidelines. Lastly, we examined reports from 

GAO, the Congressional Research Service, the Homeland Security 

Institute, and academic and research institutions, and reviewed relevant 

speeches, testimony, and news articles. 

This review was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections issued by the President’s Council on Integrity and Efficiency. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix B 

Recommendations 

Recommendations 

Recommendation #1: Identify a single senior DHS official to be 

accountable for coordinated implementation of all DHS food sector 

responsibilities, and provide this official with clear authorities and 

adequate staffing to perform this function. 

Recommendation #2: Restore communication with the Food ISAC by 

re-establishing a DHS point of contact and creating food-industry-specific 

products for ISAC distribution. 

Recommendation #3: Seek out improvement in DHS’ relationship with 

food sector partners through: 

• Better attention to the demands and information flow related to 

coordinating council comments on DHS initiatives; 

• Higher level DHS official attendance at council meetings; and 

• Increased responsiveness to council requests for information, 

briefings, and presentations by other DHS components. 

Recommendation #4: Expand National Infrastructure Coordinating 

Center outreach efforts to include outreach targeted to the food sector, and 

actively seek to increase information flow related to the food sector. 

Recommendation #5: Evaluate the feasibility of providing financial 

support for and otherwise facilitate the detailing of state or local 

government and private sector representatives to support Office of 

Infrastructure Protection food sector efforts with an emphasis on the 

Homeland Security Information Network’s Food and Agriculture Portal. 

Recommendation #6: Develop and maintain, in collaboration with 

Office of Grants and Training and Office of Infrastructure Protection, a 

comprehensive report on DHS food sector research and education 

initiatives to be shared with FDA and USDA on a regular basis. 

Recommendation #7: Develop a grant process to support non-urban, 

multi-jurisdictional preparedness programs on a regional level. 

Recommendation #8: Work with HHS and USDA to prepare an 

integrated food defense budget plan for Fiscal Year 2009 using a process 

that satisfies Homeland Security Presidential Directive 9 requirements. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix B 

Recommendations 

Recommendation #9: Expedite the review of existing food sector 

assessments to determine their suitability for use in comparative risk 

analysis, and collaboratively identify the role of these assessments in the 

sector-specific risk methodology. 

Recommendation #10: Pursue the recruitment, hiring, and retention of 

several additional staff with expertise in matters of post-harvest food 

defense. 

Recommendation #11: Consider the elaboration of food-specific criteria 

and guidelines for Customs-Trade Partnership Against Terrorism food 

industry firms in collaboration with FDA and USDA. 

Recommendation #12: Study ways to integrate food defense awareness 

into existing transportation security programs fully and consider additional 

research to improve the security of food in transit. 

Recommendation #13: Expand efforts to sponsor food contamination 

event exercises with an emphasis on exercises spanning multiple state and 

local jurisdictions. 

Recommendation #14: Expand food sector modeling to other portions of 

the food supply chain for the purpose of improving food contamination 

event consequence assessment and decision support. 

Recommendation #15: Evaluate the advisability and feasibility of 

integrating additional federal foodborne illness reporting, surveillance, and 

detection systems into the National Biosurveillance Integration System. 

Recommendation #16: Continue to develop and disseminate information 

about food subsystem-specific operational protective measures and 

operational best practices in collaboration with FDA and USDA. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Management Comments on the Draft Report 

Management Comments on the Draft Report 

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Management Comments on the Draft Report 

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Management Comments on the Draft Report 

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Page 122 
Appendix D 

Farm-to-Table Continuum 

Farm-to-Table Continuum 

This graphic provides a general overview of food processing across the 

production and supply chain. It is not intended to represent all stages or 

specific processing steps for all foods, rather the important links between 

the food and transportation sectors are noted at each phase of the 

continuum. 

Figure 2. Farm-to Table Continuum 

 Overview of the Farm-to-Table Continuum 

Crops & Plant 

Production 

Livestock & 

Animal Production

Pre-Harvest 

Post-Harvest 

Processing 

Packaging 

Wholesale 

Retail Food Service 

Storage 

Storage 

Harvest Slaughter 

Consumer 

TransportationTransportation 

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Appendix E 

Federal Food Sector Regulatory Oversight 

Federal Food Sector Regulatory Oversight 

Nine federal agencies have a regulatory role in the food sector. FDA and 

USDA’s Food Safety and Inspections Service are the two primary entities 

with an oversight role. Summaries of the roles played by each of these 

nine agencies are provided below, as are examples of foods regulated by 

FDA and Food Safety and Inspections Service. 

Federal Food Regulatory Agencies 

Agriculture Marketing Service, USDA 

The Agricultural Marketing Service includes six commodity programs--

Cotton, Dairy, Fruit and Vegetable, Livestock and Seed, Poultry, and 

Tobacco. The programs employ specialists who provide standardization, 

grading and market news services for those commodities. The agency 

enforces such federal laws as the Perishable Agricultural Commodities 

Act and the Federal Seed Act. 

Alcohol and Tobacco Tax and Trade Bureau, Department of the Treasury 

Established as part of the Homeland Security Act, this new bureau 

assumed some functions historically done by the Bureau of Alcohol, 

Tobacco, and Firearms. The agency also collects alcohol, tobacco, 

firearms and ammunition excise taxes, to ensure that these products are 

labeled, advertised and marketed in a legal manner. 

Customs and Border Protection, DHS 

In the discharge of its import protection role, CBP has a variety of contact 

with the food and agriculture sector. As discussed in this report, CBP 

works with FDA and USDA on import targeting. CBP also conducts 

inspections of agriculture imports, a function that was performed by the 

Animal and Plant Health Inspection Service prior to the creation of DHS. 

Environmental Protection Agency 

Although the Food and Drug Administration regulates most aspects of 

food production and consumption in the United States, the EPA is 

responsible for regulating the use of pesticides on food. In cooperation 

with the states, the agency carefully regulates pesticides to ensure that 

their use does not compromise food safety. In particular, the federal 

pesticide program is designed to ensure that pesticides can be used without 

posing harm children and infants. The agency also provides information 

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to the public about possible food contamination dangers, such as mercury 

in fish. 

Federal Trade Commission 

The agency’s enforcement of truth-in-labeling laws examines the claimed 

benefits of food and other commodities. Additionally, review of anticompetitive practices focuses on key aspects of the economy, like the food 

sector. 

Food and Drug Administration, HHS 

FDA regulates most of the food consumed in the United States. FDA’s 

inspection activities are not continuous, unlike the Food Safety and 

Inspections Service. Another major FDA mission is to protect the safety 

and wholesomeness of food. The agency's scientists test samples to see if 

any substances, such as pesticide residues, are present in unacceptable 

amounts. If contaminants are identified, FDA takes corrective action. 

FDA also sets labeling standards to help consumers know what is in the 

foods they buy. FDA also ensures that medicated feeds and other drugs 

given to animals raised for food do not threaten consumer health. 

Food Safety and Inspection Service, USDA 

The Food Safety and Inspections Service performs continuous onsite 

inspection of U.S. meat, poultry, and processed egg facilities. The agency 

sets requirements for meat and poultry labels and for certain slaughter and 

processing activities, such as plant sanitation and thermal processing. The 

Food Safety and Inspections Service tests for microbiological, chemical, 

and other types of contamination and conducts epidemiological 

investigations in cooperation with CDC. In addition, the Food Safety and 

Inspections Service conducts enforcement activities to address situations 

where unsafe, unwholesome, or inaccurately labeled products have been 

produced or marketed. Another important Food Safety and Inspections 

Service activity is the re-inspection of imported products. 

Grain Inspection, Packers and Stockyards Administration, USDA 

This agency facilitates the marketing of livestock, poultry, meat, cereals, 

oilseeds, and related agricultural products, and promotes fair and 

competitive trading practices for the overall benefit of consumers and 

American agriculture. 

National Marine Fisheries Service, National Oceanic and Atmospheric 

Administration, Department of Commerce 

Under this agency, a voluntary seafood inspection program is conducted. 

The program provides vessel and plant sanitation, product inspection, 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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grading, certification, and other services. Participants may use official 

marks on compliant products, indicating the items were federally 

inspected. Additional work includes reviewing compliance with fisheries 

regulations and reduction of wasteful fishing practices. 

Complex Web of Federal Food Oversight 

One challenge in coordinating food defense is the division of regulatory 

responsibility between FDA and the Food Safety and Inspections Service 

on food safety inspections. The absence of a single food safety agency has 

helped foster the development of overlapping and close connections in 

regulating the post-harvest food sector. The different intensity of effort in 

FDA and Food Safety and Inspections Service inspection regimens can 

also result in differences in the vulnerability of food products. 

Figure 3. Regulatory Oversight of Sample Food Products 

Sample of Foods Regulated 

by USDA and FDA 

USDA FDA 

3⁄4 Domesticated

 turkey 

3⁄4 Chicken noodle

 soups 

3⁄4 Chicken nuggets 

3⁄4 Meatball

 spaghetti sauce 

3⁄4 Pepperoni pizzas 

3⁄4 Open-faced

 ham sandwiches 

3⁄4 Processed eggs 

3⁄4 Beef jerky 

3⁄4 Beef 

3⁄4 Wild turkey 

3⁄4 Vegetable soups 

3⁄4 Alligator nuggets 

3⁄4 Mushroom

 spaghetti sauce 

3⁄4 Cheese pizzas 

3⁄4 Closed-faced

 ham sandwiches 

3⁄4 Shell eggs 

3⁄4 Venison jerky 

3⁄4 Bison meat 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix F 

Critical Infrastructure Sectors and Designated Sector-Specific Agencies 

Critical Infrastructure Sectors and Designated 

Sector-Specific Agencies 

Table 4. Critical Infrastructure Sectors and Sector-Specific Agencies 

Critical Infrastructure Sectors 

Critical Infrastructure Sector Sector-Specific Agency 

Agriculture and Food* USDA and HHS/FDA 

Banking and Finance Department of the Treasury 

Chemical DHS 

Commercial Facilities** DHS 

Dams** DHS 

Defense Industrial Base Department of Defense 

Emergency Services DHS 

Energy Department of Energy 

Government Facilities** DHS 

Information Technology DHS 

National Monuments and Icons** Department of the Interior 

Nuclear Reactors, Materials, and Waste** DHS 

Postal and Shipping DHS 

Public Health and Healthcare HHS 

Telecommunications DHS 

Transportation DHS 

Water Environmental Protection Agency 

* Agriculture and Food were initially treated as separate infrastructure sectors.104 In February 

2003, however, The National Strategy for the Physical Protection of Critical Infrastructures 

and Key Assets redefined the two as a single infrastructure sector.105 

** These sectors are considered key assets or key resources rather than critical infrastructure 

sectors. 

104 Executive Office of the President, Office of Homeland Security, National Strategy for Homeland Security, 

July 2002, p. 30. 105 Executive Office of the President, Office of Homeland Security, National Strategy for the Physical Protection of

Critical Infrastructures and Key Assets, February 2003, p. xii. 

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Appendix G 

DHS Food Sector Responsibilities 

DHS Food Sector Responsibilities 

Table 5. DHS Food Sector Responsibilities and Their Origins 

DHS Responsibilities in Food Defense and Critical Infrastructure Protection 

Role Responsibility Statutory Basis 

Critical Infrastructure Protection Management and Coordination 

Lead 

Collaborative 

Support 

3⁄4 Lead, integrate, and coordinate critical infrastructure protection 

efforts by federal, state and local governments, and the private sector 

Homeland Security 

Presidential Directive 7 (12) 

3⁄4 Establish uniform policies, approaches, guidelines, and 

methodologies for infrastructure protection and risk management 

Homeland Security 

Presidential Directive 7 (14) 

3⁄4 Outline critical infrastructure protection goals, objectives, 

milestones, and key initiatives 

Homeland Security 

Presidential Directive 7 (27) 

3⁄4 Establish metrics and criteria for related programs Homeland Security 

Presidential Directive 7 (14) 

3⁄4 Submit integrated budget plan for U.S. food system defense Homeland Security 

Presidential Directive 9 (26) 

3⁄4 Provide specific expertise and assistance in addressing critical 

infrastructure protection 

NIPP , p. 18-19 

Asset Identification & Mapping 

Lead 3⁄4 Identify critical infrastructure and maintain a national inventory of 

critical infrastructure assets 

Homeland Security 

Presidential Directive 7 (13); 

NIPP , p. 31 

3⁄4 Develop a program to geospatially map, image, analyze, and sort 

critical infrastructure 

Homeland Security 

Presidential Directive 7 (31) 

Information Sharing, Threat Awareness, & Warning 

Lead 

Collaborative 

3⁄4 Establish systems, mechanisms, and procedures to share critical 

infrastructure threat information with federal, state and local 

governments, and the private sector 

Homeland Security 

Presidential Directive 7 (28) 

3⁄4 Establish an effective information sharing and analysis mechanism 

for food and agriculture 

Homeland Security 

Presidential Directive 9 (19) 

3⁄4 Develop a national indications and warnings architecture for 

infrastructure protection 

Homeland Security 

Presidential Directive 7 (33) 

3⁄4 Identify and assess the nature and scope of threats, provide threat 

scenarios and assessments, 

NIPP , p. 19 

3⁄4 Develop biological threat awareness capacity for detection of attacks 

on food 

Homeland Security 

Presidential Directive 9 (10) 

3⁄4 Conduct assessments of the evolving biological weapons threat Homeland Security 

Presidential Directive 10 

3⁄4 Develop and enhance intelligence operations and analysis 

capabilities for the food sector 

Homeland Security 

Presidential Directive 9 (9) 

3⁄4 Facilitate information sharing on physical and cyber threats and 

incidents 

Homeland Security 

Presidential Directive 7 (25) 

* Homeland Security Presidential Directive 10 paragraph citations refer to paragraphs in the published version of the document. 

(http://www.whitehouse.gov/homeland/20040430.html) 

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DHS Responsibilities in Food Defense and Critical Infrastructure Protection** 

Role Responsibility Statutory Basis 

Vulnerability Assessment 

Lead 

Collaborative 

3⁄4 Conduct vulnerability assessments and analyses, and 

test vulnerabilities 

Homeland Security Act, 

§201(d)(2) and §201(d)(2)(6) 

3⁄4 Establish uniform approaches to vulnerability assessment Homeland Security 

Presidential Directive 7 (14) 

3⁄4 Expand and conduct vulnerability assessments for the food sector Homeland Security 

Presidential Directive 9 (11) 

3⁄4 Facilitate sharing of information about vulnerabilities Homeland Security 

Presidential Directive 7 (25) 

3⁄4 Develop analyses to understand weaknesses that may be exploited 

by adversaries 

Homeland Security 

Presidential Directive 10 

Consequence Assessment & Modeling 

Lead 3⁄4 Model the implications of exploitation of infrastructure 

vulnerabilities 

Homeland Security 

Presidential Directive 7 (32) 

3⁄4 Create and maintain models of critical infrastructure systems USA PATRIOT Act, §1016 

(d)(2)(B) 

Protective Measures & Prioritization 

Lead 

Collaborative 

3⁄4 Prioritize and coordinate the protection of critical infrastructure Homeland Security 

Presidential Directive 7 (13) 

3⁄4 

Identify priorities for protective and support measures 

Homeland Security Act, 

§201(d)(3) 

3⁄4 Recommend measures to protect critical infrastructure Homeland Security Act, 

§201(d)(6) 

3⁄4 Develop and implement mitigation strategies to protect vulnerable 

critical food and agriculture production nodes 

Homeland Security 

Presidential Directive 9 (12) 

3⁄4 Expand development of common screening procedures for food 

items entering the United States 

Homeland Security 

Presidential Directive 9 (13) 

3⁄4 Facilitate sharing of information about potential protective measures 

and best practices 

Homeland Security 

Presidential Directive 7 (25) 

* Homeland Security Presidential Directive 10 paragraph citations refer to paragraphs in the published version of the document. 

(http://www.whitehouse.gov/homeland/20040430.html) 

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DHS Food Sector Responsibilities 

DHS Responsibilities in Food Defense and Critical Infrastructure Protection** 

Role Responsibility Statutory Basis 

Research & Development 

Lead 

Collaborative 

3⁄4 Establish a university-based center of excellence in food security Homeland Security 

Presidential Directive 9 (25); 

Homeland Security Act, 

§308(b)(2)(B)(vi) 

3⁄4 Coordinate research and development of methods for detection, 

prevention technologies, agent characterization, and dose response 

relationships for high-consequence agents in the food supply 

Homeland Security 

Presidential Directive 9 (23) 

3⁄4 Coordinate interagency research and development to enhance the 

protection of critical infrastructure 

Homeland Security 

Presidential Directive 7 

(22)(e) 

3⁄4 Prepare an annual critical infrastructure protection research and 

development plan 

Homeland Security 

Presidential Directive 7 (30) 

Education, Outreach, Training & Preparedness 

Lead 

Collaborative 

Support 

3⁄4 Establish a university-based center of excellence in food security Homeland Security 

Presidential Directive 9 (25); 

Homeland Security Act, 

§308(b)(2)(B)(vi) 

3⁄4 Ensure adequate response capabilities for terrorist attack, disease 

outbreak, or other disaster impacting food infrastructure 

Homeland Security 

Presidential Directive 9 (14) 

3⁄4 Establish opportunities for professional development and specialized 

training in food protection 

Homeland Security 

Presidential Directive 9 (22) 

3⁄4 Support the development of inter-disciplinary higher education 

programs to prepare food defense professionals 

Homeland Security 

Presidential Directive 9 (21) 

** Excluding response and recovery responsibilities. 

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Appendix H 

DHS Food-Sector-Related Programs and Initiatives 

DHS Food-Sector-Related Programs 

DHS operates a number of programs and initiatives with food defense and 

critical infrastructure protection features. Some of these programs serve 

critical infrastructure protection efforts at large, and only engage the food 

sector as part of one of these infrastructures, to a limited degree. Related 

DHS programs and activities are arrayed across five different DHS 

organizational entities: the Offices of Infrastructure Protection, Grants 

and Training, and the Chief Medical Officer, S&T, and CBP. The 

following section provides brief descriptions of the related programs and 

initiatives within each of these four DHS components. 

Office of Infrastructure Protection Programs and Initiatives 

Food and Agriculture Government Coordinating Council 

Officially organized in 2004, the Food and Agriculture Government 

Coordinating Council is the government’s primary resource for the 

coordination of inter-departmental work on food security. DHS, USDA, 

and FDA rotate as the Government Coordinating Council chair on an 

annual basis. Three state and local associations and several other federal 

entities, including the Departments of Defense and Commerce, as well as 

the EPA, are part of the Government Coordinating Council. In addition to 

its active participation in the Government Coordinating Council, DHS 

provides funding for the Government Coordinating Council’s 

administrative support requirements. DHS support for the Government 

Coordinating Council Secretariat totals approximately $155,000 a year. 

Food and Agriculture Sector Coordinating Council 

The Food and Agriculture Sector Coordinating Council is the private 

sector’s counterpart to the Government Coordinating Council. Also 

organized in 2004, the Sector Coordinating Council includes a variety of 

members across the food and agriculture sectors. Although dozens of 

companies and organizations participate, seven subcouncils of three 

members each lead the Sector Coordinating Council. Joint meetings 

facilitate communication between the Sector Coordinating Council and the 

Government Coordinating Council. DHS provides funding for the Sector 

Coordinating Council’s administrative support requirements. DHS 

support for the Sector Coordinating Council Secretariat totals 

approximately $180,000 a year. 

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Homeland Security Information Network Food and Agriculture Portal 

The Homeland Security Information Network Food and Agriculture Portal 

is an internet-based tool for sharing threat and analytical information for 

sector participants. Initial discussions on portal design began in October 

2004. Representatives from the Government Coordinating Council and 

Sector Coordinating Council helped establish the online layout of the 

system, which is currently in the pilot stage. The portal is designed for 

sharing information, facilitating response to events, and expanding 

dialogue in the food and agriculture sectors. DHS support for Homeland 

Security Information Network Food and Agriculture portal development 

and related sector outreach and requirements development efforts has 

totaled approximately $430,000. 

National Infrastructure Coordinating Center 

A 24/7 watch operations center, the National Infrastructure Coordinating 

Center reports to DHS’ Office of Infrastructure Protection, but is 

considered an “operational extension” of the DHS National Operations 

Center. The primary missions of the National Infrastructure Coordinating 

Center are to “maintain operational and situational awareness” of critical 

infrastructure issues and to provide “a centralized mechanism and process 

for information sharing and coordination.”106 The National Operations 

Center is the source of most requests for information handled by the 

National Infrastructure Coordinating Center. The National Infrastructure 

Coordinating Center issues four types of finished products: suspicious 

activity reports, spot reports, current situation reports, and a daily sector 

pulse. As the food sector is a critical infrastructure sector, these products 

may address related issues. 

Homeland Infrastructure Threat and Risk Analysis Center 

The Homeland Infrastructure Threat and Risk Analysis Center, which 

originated in January 2005, provides industry and government a better 

understanding of threats to critical infrastructure. The center is located 

within and jointly staffed by the Office of Intelligence and Analysis and 

the Office of Infrastructure Protection. It considers threat, risk, and 

consequence in the creation of various notices and warnings. The center, 

which has developed some food sector products, regards the private sector 

as its primary customer. 

Protected Critical Infrastructure Information Program 

Established in Section 214 of the Homeland Security Act, the Protected 

Critical Infrastructure Information program is designed to increase the 

106 DHS, NIPP, June 30, 2006, p. 64. 

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amount of critical infrastructure information by providing private industry 

with an alternative means to share voluntarily their sensitive and 

proprietary business information with the federal government. Private 

sector infrastructure information submitted under the program has greater 

protections from disclosure than other government information, and it may 

not be released, for example, in response to Freedom of Information Act 

requests. DHS, which is charged with guarding this information, is to use 

information deemed Protected Critical Infrastructure Information to 

improve the protective environment of all infrastructure sectors. The food 

industry has provided information under the Protected Critical 

Infrastructure Information program. 

DHS Educational Reports 

DHS has created three types of reports on critical infrastructures. These 

reports are distributed to state and territorial Homeland Security Offices, 

and are designed for sharing with asset owners and law enforcement 

personnel. 

Characteristics and Common Vulnerabilities Reports 

These reports meld information on characteristics, vulnerabilities 

and consequences, along with possible warning signs of an attack, 

to facilitate protective measures, detection and prevention for each 

infrastructure sector. DHS had completed five Characteristics and 

Common Vulnerability Reports on the food and agriculture sectors 

as of December 2005. 

Potential Indicators of Terrorist Activity Reports 

These reports offer suggestions on how to detect possible terrorist 

activity in areas adjoining critical infrastructure. They have 

content similar to the characteristics and common vulnerabilities 

reports discussed above. DHS had completed five Potential 

Indicators of Terrorist Activity reports on the food sector by 

December 2005. 

Protective Measure Reports 

Protective Measure reports are designed to inform states and 

infrastructure owners about best practices and other possible means 

to defend particular sectors against terrorist acts. The reports 

suggest ways to remedy vulnerabilities discussed in Common 

Characteristics and Potential Indicators reports. DHS had 

completed six of these reports on the food sector as of December 

2005. 

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Site Assistance Visits 

Site Assistance Visits are designed to aid in filling gaps in private sector 

vulnerability assessments. A Site Assistance Visit is a one- or two-day 

“inside the fence” review of an asset’s vulnerabilities. Written reports are 

created as a product of this review. These reports discuss baseline threats, 

vulnerabilities, and protective measures. DHS has concentrated Site 

Assistance Visit efforts on sector components of “particular concern.” As 

of December 2005, DHS had conducted eight Site Assistance Visits of 

food sector assets. 

Buffer Zone Plans 

Buffer Zone Plans are products of the Buffer Zone Protection Program, a 

joint effort between the Office of Infrastructure Protection and Office of 

Grants and Training. State and local authorities in conjunction with public 

and private infrastructure owners develop Buffer Zone Plans under the 

guidance of Office of Infrastructure Protection staff. Among other things, 

the plans identify vulnerabilities associated with facility buffer zones – 

extensions of protection beyond the gates of critical facilities – and 

analyze and categorize the level of risk associated with these 

vulnerabilities. A limited number of Buffer Zone Plans have been 

completed on food sector assets. 

Strategic Partnership Program for Agroterrorism Initiative 

Announced in July 2005, this initiative is an FBI-funded effort to develop 

a comprehensive perspective on food and agricultural vulnerabilities. 

Strategic Partnership Program Agroterrorism is designed to gather 

vulnerability information on food and agricultural product types, 

commodities, and activities, rather than particular firms or facilities. FDA 

or USDA representatives serve as facilitators, while DHS, FBI, and state 

and local departments of health and agriculture typically participate 

alongside private sector representatives.107 

National Asset Database 

The National Asset Database is to serve as a “comprehensive catalog of 

the assets, systems, and networks that comprise” the country’s critical 

infrastructures.108 Overseen by the Office of Infrastructure Protection, the 

National Asset Database is housed and maintained at Oak Ridge National 

Laboratory. Food sector assets are represented in the National Asset 

Database. 

107 Center for Food Safety and Applied Nutrition, “Strategic Partnership Program Agroterrorism (SPPA) Initiative: 

A Joint Effort of the FBI, DHS, USDA, and FDA to Help Secure the Nation's Food Supply,” August 2005; and 

Center for Food Safety and Applied Nutrition, “SPPA Initiative Questions and Answers,” September 23, 2005. 108 DHS, NIPP, June 30, 2006, p. 159. 

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National Infrastructure Simulation and Analysis Center 

Originally part of the Department of Energy’s Office of Energy 

Assistance, the National Infrastructure Simulation and Analysis Center is 

now overseen by the Office of Infrastructure Protection. The National 

Infrastructure Simulation and Analysis Center is a partnership of Sandia 

National Laboratories and Los Alamos National Laboratory. It provides 

advanced modeling and simulation capabilities for the analysis of critical 

infrastructures, including the food sector, and their interdependencies, 

vulnerabilities, and complexities. 

Office of Grants and Training Programs 

Multi-State Partnership for Security in Agriculture 

Iowa, the lead sponsor in the Multi-State Partnership for Security in 

Agriculture, received $2.0 million in 2002 for its Agriculture 

Counterterrorism Project. Under the project, the Multi-State Partnership, 

which includes 10 states in the Central United States, facilitates interstate 

agro-security planning and the development of asset protection programs 

for the food supply chain. The project also assists the food industry’s 

development of vulnerability assessments and effective security strategies. 

University of California - Davis Training Support 

The Western Institute for Food Safety and Security at UC Davis received a 

$4.7 million training grant. The Institute’s focus is on developing a 

training process to enhance preparedness against weapons of mass 

destruction targeted at food and agriculture. The program has seven 

training courses in its agroterrorism-preparedness curriculum. These 

courses address issues of awareness, team building, preparedness, risk 

communication, detection and investigation, response, and recovery. The 

program plans to train 1 million first responders through courses and 

performance-testing exercises. 

University of Tennessee Training Support 

In October 2005, the University of Tennessee College of Veterinary 

Medicine received a grant of $2 million to develop and deliver a national 

16-hour agricultural vulnerability assessment training program for state 

and local officials and agricultural managers. The program aims to 

strengthen the ability of state and local communities to improve the 

intelligence and operational capabilities for prevention and deterrence of 

terrorist acts against the sector by providing courses to 300,000 first 

responders. 

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DHS Food-Sector-Related Programs and Initiatives 

Louisiana State University Course Development 

The National Center for Biomedical Research and Training at Louisiana 

State University received $1.4 million for food and agriculture course 

development. Training targets those involved in food and agriculture with 

supervisory responsibilities and provides information on the prevention 

and deterrence of a terrorist attack on food and agriculture. Participants 

engage in several scenarios involving planning and case studies and 

conduct a table-top exercise based on a vulnerability in their region. 

Exercise Support 

Grants and Training’s Exercise and Training Division provides food 

defense exercise support in at least two ways. First, it has provided direct 

support for three food sector-related exercises. Second, it helps state and 

local jurisdictions create, conduct, and evaluate exercise programs through 

its Homeland Security Exercise and Evaluation Program. The goal of this 

program is to standardize exercises, and related policies, definitions, and 

requirements across government. 

State Homeland Security Program 

Grants and Training supports food defense activities at the state level 

through the State Homeland Security Program. This program began in 

Fiscal Year 2003 with $566 million in funding for grants. For Fiscal Year 

2006, the program awarded grants totaling $544.5 million. This program 

was designed to assist states and localities build capabilities to address 

state homeland security strategies and develop all-hazard target 

capabilities. The State Homeland Security Program provides support for 

state and local planning, training, exercising, and equipment. These 

activities enhance state and local capabilities to prevent, protect, respond 

to and recover from a range of catastrophes and adverse events, including 

food-related incidents. 

Office of the Chief Medical Officer Program 

National Biosurveillance Integration System 

The National Biosurveillance Integration System, which was launched in 

December 2005, is part of a national biosurveillance initiative. The 

system is designed to augment national biosurveillance capabilities 

through coordination of various systems in existence at federal agencies. 

By accessing information from human and animal health, food and 

environmental monitoring systems, the National Biosurveillance 

Integration System seeks to reduce detection time following an event, 

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speed determinations about the cause of biological events, and advance 

recovery efforts. 

S&T Programs 

National Center for Food Protection and Defense 

The NCFPD is a university-based Homeland Security Center of 

Excellence established in 2004. Based at the University of Minnesota, the 

NCFPD will receive $15 million over its first three years of operation. 

The Center’s mission is to reduce the likelihood of deliberate 

contamination of the food chain, develop rapid detection methodologies, 

enhance strategies for effective and efficient response to and mitigation of 

intentional attacks, and expand the pool of experts in food security. In 

conducting food defense activities, the Center collaborates with many 

industry, academic, federal, state, and local entities. 

Food Biological Agent Detection Sensor 

The Food Biological Agent Detection Sensor program was established in 

2005. This program focuses on developing a rapid, portable detection 

technology for Clostridium botulinum toxin in a beverage matrix. Once 

the technology is developed and tested, the focus will move to other liquid 

food matrices, as well as other select agents. Awards for the first phase of 

the program, which will culminate in the testing of pre-production model 

sensors, totaled $3.6 million. 

National BioDefense Analysis and Countermeasures Center 

The National BioDefense Analysis and Countermeasures Center is a 

resource established by S&T in 2003 to serve as a research and 

information hub for the federal government at large. Construction is 

underway at Fort Detrick, Maryland for a permanent laboratory facility. 

The Center studies current and future biological threats, assesses 

vulnerabilities, determines potential consequences, and provides a forensic 

analysis capability. It is comprised of three entities: a Biological Threat 

Characterization Center, the Biological Defense Knowledge Center, and a 

Biological Forensic Analysis Center, which is the lead federal entity for 

performing forensic analysis on biological samples. During Fiscal Years 

2003 and 2004, the facility allocated $5.5 million in support of threat 

assessments, detection, and viability studies for biological, chemical, and 

toxic agents that could threaten food. 

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DHS Food-Sector-Related Programs and Initiatives 

University of Kentucky Tracking System 

The University of Kentucky, in collaboration with the University of 

Louisville and Western Kentucky University, has received approximately 

$1.5 million in funding to develop a wireless milk tracking system using 

satellite technology. The system is expected to take two to three years to 

develop. 

Critical Infrastructure Protection Decision Support System 

The Critical Infrastructure Protection Decision Support System is an equal 

collaboration between Argonne, Los Alamos, and Sandia National 

Laboratories. The program’s budget for Fiscal Year 2005, which is 

equally divided among the three labs, was $7.5 million. The system 

develops interdependent infrastructure models to assess the consequences 

of disruptions in any of the infrastructure sectors. Critical Infrastructure 

Protection Decision Support System models attempt to simulate disruption 

scenarios, evaluate consequences, and assess the effectiveness of 

mitigation actions. The program uses information from the models to 

support a “risk-informed” decision-support tool to identify activities to 

best reduce overall risk.109 

CBP Initiative 

Notification and Targeting Support 

CBP has collaborated with FDA in developing prior notification 

requirements for imported foods and currently shares a watch center 

facility with FDA’s Prior Notice Center. Also, CBP has supported the 

development of targeting criteria to aid FDA and USDA in targeting highrisk food imports. Finally, CBP has provided FDA and USDA with key 

access to information systems, and designed and developed a prior notice 

submission interface with the primary customs trade information system, 

the Automated Commercial System. 

109 S&T, Parney Albright, “Critical Infrastructure Protection Decision Support System,” August 4, 2004. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix I 

The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

The Food Sector in Frameworks for Infrastructure Protection, 

National Preparedness, and Incident Management 

Much of DHS’ mission and many of its related responsibilities can be 

traced to three key policy frameworks, those for: infrastructure protection, 

national preparedness, and incident management. To a large extent, these 

policy frameworks mark their beginnings with different Homeland 

Security Presidential Directives. Federal infrastructure protection and 

preparedness activities, the focus of much of this review, were outlined in 

Homeland Security Presidential Directives 7 and 8. Homeland Security 

Presidential Directive 5, in turn, discusses federal policy and 

responsibilities relating to incident management. 

According to the NIPP, these frameworks collectively amount to a 

“common, holistic approach to achieving the homeland security 

mission.”110 Each of these frameworks contain elements relating to the 

food sector, but it is unclear how they correspond with one another to form 

a holistic approach. 

In this section, we outline each of these frameworks – infrastructure 

protection, national preparedness, and incident management – and their 

applicability to the food sector. In addition, we examine how effectively 

the food sector elements of these frameworks link together. 

Infrastructure Protection Framework 

In February 2003, the White House published The National Strategy for 

the Physical Protection of Critical Infrastructure and Key Assets. The 

National Strategy discussed the government’s plan to secure critical 

infrastructures, and counted the food industry as part of a critical 

infrastructure sector – the food and agriculture sector. 

Homeland Security Presidential Directive 7 clarified roles and 

responsibilities set forth in the National Strategy with the aim of 

enhancing the protection of critical infrastructures from terrorist threats. It 

identified DHS as the overall lead and coordinator of federal infrastructure 

protection activities, and designated Sector-Specific Agencies for each 

critical infrastructure sector. According to Homeland Security 

Presidential Directive 7, Sector Specific Agencies are responsible for 

working with DHS to augment security for their respective sectors. 

110 DHS, NIPP, June 30, 2006, p. 74. 

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The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

Homeland Security Presidential Directive 7 designated USDA and HHS’s 

FDA as the dual Sector Specific Agencies for the food and agriculture 

sector. 

In addition to assigning sector-specific roles, Homeland Security 

Presidential Directive 7 mandated that DHS lead the development of a 

plan for infrastructure protection. This plan, the National Infrastructure 

Protection Plan was released in June 2006. It describes missions, goals, 

and standards for protection of the infrastructure sectors. The NIPP 

outlines actions to be taken by DHS and the Sector Specific Agencies to 

increase the protection of critical infrastructures. 

The NIPP sets the stage for common risk-reduction activities across 

infrastructure sectors, and lays the foundation for activities to be 

undertaken by individual infrastructure sectors. According to the plan, the 

following risk management activities are to be conducted for each critical 

infrastructure sector: setting security goals; identifying assets, systems, 

networks, and functions; assessing risks; prioritizing; implementing 

protective programs; and measuring effectiveness.111 The NIPP signals 

that these activities are to be conducted independently for each sector and 

to be performed in all-hazards context. This all-hazards orientation is 

significant in that it extends the reach of critical infrastructure protection 

activities beyond the scope initially envisioned in Homeland Security 

Presidential Directive 7, which exclusively focused on protecting critical 

infrastructures from terrorism. 

The NIPP also calls for the elaboration of Sector Specific Plans for each 

infrastructure sector. These Sector-Specific Plans are to “detail the 

application of the NIPP framework specific to each ... sector.”

112 The 

Sector-Specific Agencies are charged with completing their respective 

Sector-Specific Plans in 2006, and reviewing them on an annual basis.113 

As discussed in the main body of the report, coordinating councils are the 

key voice for government and industry for each sector. The Government 

Coordinating Councils and Sector Coordinating Councils are the bridge 

between DHS’ national framework and sector experts within DHS. 

In addition to the NIPP, DHS is charged with preparing a National Plan 

for Research and Development in Support of Critical Infrastructure 

Protection. This plan sets forth research and development priorities, 

goals, and objectives relating to critical infrastructure protection. As noted 

111 DHS, NIPP, June 30, 2006, p. 4. 112 Ibid., p. 105. 113 Ibid., pp. 76, 147.

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The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

earlier in the report, however, the most recent iteration of the National 

Plan for Research and Development in Support of Critical Infrastructure 

Protection does not include any explicit reference to research and 

development support for the food sector in particular. 

Preparedness Framework 

Homeland Security Presidential Directive 8 designates the DHS Secretary 

as “the principal Federal official for coordinating the implementation of 

all-hazards preparedness in the United States,” and directs the 

development of a domestic all-hazards national preparedness goal.114 

DHS issued an Interim National Preparedness Goal on March 31, 2005. 

This goal sets national preparedness priorities and establishes a system for 

assessing the state of overall national preparedness. 

The preparedness framework laid out in the National Preparedness Goal is 

centered around preparedness capability development and assurance. This 

framework uses representative planning scenarios to develop an allhazards preparedness task list. The task list is, in turn, used to construct a 

list of targeted capabilities. Among these targeted capabilities, the Interim 

National Preparedness Goal identified four as national priorities. The 

National Preparedness Goal also set out three additional overarching 

priorities: implementation of the National Incident Management System 

and National Response Plan, expanded regional collaboration, and 

implementation of the NIPP. Following Hurricane Katrina, DHS adopted 

an additional national priority capability. While improvements in these 

priority areas may indirectly benefit the preparedness posture with respect 

to an attack on the food supply, none of the eight priorities focuses 

primarily on food.115 One, however – Chemical, Biological, Radiological, 

Nuclear, and Explosive Detection – includes a “capability measure” that 

applies to the ability to monitor food for these threats.116 The push to 

build on another overarching priority, Implementing the NIPP, may also 

bear positively on food critical infrastructure protection, as the NIPP 

recognizes the food sector as a part of a critical infrastructure sector. 

While food defense and critical infrastructure protection activities are not 

a direct priority under the National Preparedness Goal at this time, they 

register throughout DHS’ national preparedness framework. The National 

114 Homeland Security Presidential Directive 8: National Preparedness, December 17, 2003, paragraphs 4 and 5. 115 Grants and Training notes that the National Preparedness Goal priorities do not specify targeted action in several 

critical infrastructure sectors, including the nuclear, chemical, or transportation sectors. 116 DHS, Target Capabilities List: Volume 1.1, May 23, 2005, p. 41. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

Planning Scenarios, for example, which were designed to represent the 

“scope, magnitude, and complexity” of catastrophic events that may occur 

for the purpose of identifying “core prevention and response 

requirements” to aid in preparedness planning,117 include an intentional 

food contamination scenario involving the contamination of ground beef 

with liquid anthrax.118 

The December 2005 iteration of the Universal Task List includes an array 

of tasks that are food-related. Teams of experts identified the tasks in the 

Universal Task List as the steps necessary to prepare to address the 

national planning scenarios. These tasks are intended to form the basis of 

a “common language and reference system” to drive training, exercises, 

operational planning undertakings, and preparedness assessments.119 

Some of the Universal Task List’s food-related tasks support prevention, 

like collecting information on threats to the food supply, while others 

address protection and focus, for example, on developing standardized 

training courses for food-related incidents.120 Still others concern 

response and recovery tasks related to food. In total, the Universal Task 

List contains 53 tasks that explicitly relate to food. In addition to food 

sector specific tasks, the Universal Task List has other broad-based tasks 

with an effect on the food sector. 

The Target Capabilities List identifies 37 capabilities that DHS has 

determined are essential for different levels of government to effectively 

prepare for terrorist attacks and other major disasters.121 These target 

capabilities were distilled from critical tasks identified in the Universal 

Task List and are similarly grouped into their support for the different 

preparedness mission areas – prevention, protection, response, and 

recovery. One such target capability relates directly to food. Among the 

nine targeted “protection” capabilities is the “capability to identify and 

defend against pathogens, chemical and biological contaminants, and other 

hazards that affect the safety of food and agriculture products.”122 Other 

target capabilities only relate to food defense as part of a larger set of 

activity, like those concerning risk assessment, critical infrastructure 

117 DHS, National Preparedness Guidance, Homeland Security Presidential Directive 8: National Preparedness, 

April 27, 2005, pp. iii, 3. 118 DHS, National Planning Scenarios, Version 20.2 Draft, April 2005, p. 13-1. 

119 DHS, Target Capabilities List: Volume 1.1, May 23, 2005, p. 3. 120 These are listed as tasks “Pre.A.2.5” and “Pro.C.1.7.15” in DHS’ Universal Task List: Version 2.1, May 23, 

2005, pp. 23, 57. 121 DHS, National Preparedness Guidance, Homeland Security Presidential Directive 8: National Preparedness, 

April 27, 2005, p. iii. 122 DHS, Target Capability List: Version 1.1, May 23, 2005, p. 54. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix I 

The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

protection, epidemiological surveillance and investigation, and public 

health laboratory testing. 

Incident Management Framework 

Issued in February 2003, Homeland Security Presidential Directive 5 

required DHS to develop two major guidance documents, the National 

Incident Management System, and National Response Plan.

123 

The National Incident Management System sets out the principles for 

managing incidents at all levels – federal, state, and local – but does not 

present any information tailored to specific incident types. In establishing 

the doctrine for overall incident management, the National Incident 

Management System does not make any reference to food contamination 

incidents in particular. 

The National Response Plan identifies the structure and mechanisms for 

national domestic incident management efforts. Emergency Support 

Functions are a key ingredient in the National Response Plan incident 

management framework. Emergency Support Functions are the “primary 

means through which the federal government provides assistance” to other 

governmental elements in emergency situations.124 An Emergency 

Support Function outlines services needed to support recovery efforts, and 

represents part of a scalable response system that can be invoked as 

appropriate. 

Two Emergency Support Functions relate to food, Emergency Support 

Functions 6 and 11. Emergency Support Function 6 discusses the 

provision of supplies during incidents, including the provision of food. 

The Federal Emergency Management Agency is the lead for Emergency 

Support Function 6, but in this capacity it works with other entities, like 

USDA’s Food and Nutrition Service, to meet the nutritional needs of an 

affected population. The Food and Nutrition Service, and other supporting 

entities, are required to report to FEMA, the coordinator for Emergency 

Support Function 6, to ensure proper information sharing about ongoing 

specific recovery actions. 

Emergency Support Function 11 relates to agriculture and natural 

resources. USDA is the coordinator for Emergency Support Function 11, 

123 Homeland Security Presidential Directive 5: Management of Domestic Incidents, February 28, 2003, paragraphs

15 and 16. 124 DHS, Quick Reference Guide to the National Response Plan, Version 4.0, May 22, 2006, p. 14. 

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The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

which includes four primary functions. Two of these functions relate to 

post-harvest food – the provision of nutrition assistance, and the assurance 

of the safety and security of the commercial food supply. The Food and 

Nutrition Service is the lead for the former, while the Food Safety and 

Inspections Service is the lead agency for the latter. 

The National Response Plan also includes several incident annexes. 

These incident annexes are designed to guide federal activities during 

specific types of evolving incidents, in which the localized impact of the 

incident may grow in scope and severity over time.

125 One such incident 

annex is to relate to food and agriculture incidents. This incident annex is 

still under development, however. In the meantime, food contamination 

incidents may be addressed in line with the Biological Incident Annex. 

The Biological Incident Annex, which lists HHS as the coordinating 

agency and FDA as a participant, presents general policies for federal 

management of biological incidents. 

Linkages Between Food Sector Elements of Infrastructure Protection, 

National Preparedness, and Incident Management Frameworks 

DHS considers these infrastructure protection, national preparedness, and 

incident management frameworks to be complementary, but their 

compatibility is difficult to decipher at the sector level. Although these 

frameworks theoretically interconnect, the linkages between these 

processes for the food sector need more development. 

Figure 4. Food Sector Elements of Homeland Security Frameworks 

DHS Framework for Homeland Security Efforts 

Executive 

Directive 

Related

Guidance

Food Sector

Elements

Presidential Directive 7 

Critical Infrastructure 

Protection 

 Protection 

3 Nat’l. Strategy for

 Physical Protection of

 Critical Infrastructure 

3 Nat’l. Infrastructure

 Protection Plan 

y Food and Agriculture

 Sector Specific Plans 

Preparedness 

Presidential Directive 8 

National Preparedness 

3 Nat’l. Prep. Goal 

3 Planning Scenarios 

3 Universal Task List 

3 Target Capability List 

y One Planning Scenario 

y 53 Tasks 

y One Target Capability 

Response 

Presidential Directive 5 

Management of Domestic

Incidents

3 National Response

Plan 

3 National Incident

 Management System 

y Support Function 6 & 11 y BI and CI Annexes 

y Food and Agriculture

 Annex (under devel.) 

125 DHS, National Response Plan, December 2004, p. 27. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix I 

The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

DHS has asserted that the National Response Plan and NIPP are 

“complementary plans.”126 DHS’ considers the NIPP to provide “steady 

state” infrastructure protection efforts that can be folded into the National 

Response Plan effort as Homeland Security Advisory System127 levels 

dictate.128 Indeed, parallels between the two frameworks should facilitate 

such a transition from NIPP-driven food sector critical infrastructure 

protection activities and food sector incident management. The National 

Response Plan, like the NIPP, bundles food and agriculture activities, and 

is ultimately to have a food and agriculture incident annex to parallel the 

food and agriculture Sector-Specific Plan developed under the NIPP. 

Until the food and agriculture incident annex is developed, however, it is 

not possible to determine how effectively food sector incident 

management will leverage critical infrastructure protection activities. 

Questions regarding the role of FDA, which is not mentioned in 

Emergency Support Functions 6 and 11, for example, need to be resolved 

if food sector critical infrastructure protection efforts are to be fully 

exploited during an incident. 

While the NIPP has and National Response Plan will have a clear place 

for food sector activities, the role of the food sector is not as clear within 

the national preparedness framework. The national preparedness 

framework clearly accounted for the food sector in its examination of 

national capability requirements, but the end product of that process does 

not prominently single out food sector activities. Although a number of 

targeted capabilities may indirectly support food preparedness, only 1 of 

37 does so in a direct way, and this target capability has not been 

identified as a priority capability. Without a major food sector 

preparedness capability focus, it is difficult to determine how preparedness 

activities align with food sector infrastructure protection and incident 

management efforts. 

Tracking food sector activities across the range of incident preparedness 

and response frameworks is difficult, as these are not fully developed or 

clearly aligned. Further clarification may be helpful to show, for example, 

how preparedness activities conducted under Homeland Security 

Presidential Directive 8 support the food sector infrastructure protection 

responsibilities established under Homeland Security Presidential 

Directive 7. Differences like these can create difficulties in defining 

126 DHS, NIPP, June 30, 2006, p. 74. 127 The Homeland Security Advisory System is a color-coded system that communicates a threat-based view of the 

likelihood of an attack so measures can be taken to lessen the chance or impact of an incident. 128 DHS, NIPP, June 30, 2006, p. 74. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix I 

The Food Sector in Frameworks for Infrastructure Protection, National Preparedness, and 

Incident Management 

priorities and monitoring resource allocation. Improved integration of 

infrastructure protection, national preparedness, and incident management 

frameworks has the potential to reinforce the prevention, protection, 

response, and recovery posture of the food sector. 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix J 

Chronology of Significant Events 

Chronology of Significant Events 

1996 

July 15, 1996 Executive Order 13010: Critical Infrastructure 

Protection issued 

1998 

May 22, 1998 Presidential Decision Directive 63: 

Critical Infrastructure Protection issued 

2001 

September 11, 2001 Terrorist attacks on World Trade Center and 

Pentagon 

October 8, 2001 Executive Order 13228: Establishing the Office of 

Homeland Security and the Homeland Security 

Council issued 

October 16, 2001 Executive Order 13231: Critical Infrastructure 

Protection issued 

October 24, 2001 USA PATRIOT Act signed 

2002 

June 12, 2002 Bioterrorism Act signed 

July 2002 National Strategy for Homeland Security published 

November 25, 2002 Homeland Security Act signed 

December 15, 2002 Fourth Gilmore Commission Report released 

2003 

January 1, 2003 Provisions of Homeland Security Act go into effect 

February 2003 National Strategy for the Physical Protection of 

Critical Infrastructure and Key Resources 

published 

February 28, 2003 Homeland Security Presidential Directive 5: 

Management of Domestic Incidents issued 

March 1, 2003 All components transition into DHS; 

DHS stood up 

December 17, 2003 Homeland Security Presidential Directive 7: 

Critical Infrastructure Identification, Prioritization, 

and Protection issued 

December 17, 2003 Homeland Security Presidential Directive 8: 

National Preparedness issued 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

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Appendix J 

Chronology of Significant Events 

2004 

January 30, 2004 Homeland Security Presidential Directive 9: 

Defense of United States Agriculture and Food 

issued 

April 28, 2004 Homeland Security Presidential Directive 10: 

Biodefense for the 21st Century issued 

April 28, 2004 Grants and Training awards $2 million to the MultiState Partnership for Security in Agriculture 

May 25, 2004 Grants and Training-funded exercise involving 

intentional food contamination at a G-8 Summit 

takes place in Georgia 

March 1, 2004 National Incident Management System Document 

June 16, 2004 First meeting of the Food and Agriculture 

Government Coordinating Council 

June 16, 2004 S&T awards National Center for Food Protection 

and Defense $15 million over three years 

June 29, 2004 Grants and Training-funded table-top exercise on 

intentional contamination of food with anthrax takes 

place in Minnesota 

July 6, 2004 National Center for Food Protection and Defense 

launched 

August 23, 2004 Grants and Training awards UC Davis $4.7 million 

to develop an agroterrorism preparedness training 

curriculum 

August 25, 2004 Second Grants and Training-funded exercise on 

intentional contamination of food with anthrax takes 

place in Minnesota 

September 15, 2004 National Infrastructure Protection Plan, Draft Base 

Plan issued 

October 15, 2004 First meeting of the Agro-Terrorism Training 

Working Group 

December 2004 National Response Plan published 

2005 

February 2005 Interim National Infrastructure Protection Plan 

released 

April 8, 2005 National Plan for Research & Development in 

Support of Critical Infrastructure Protection (2004 

edition) published 

March 31, 2005 Interim National Preparedness Goal released 

April 2005 Draft National Planning Scenarios, Version 20.2 

released 

May 23, 2005 Universal Task List, Version 2.1 released 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 148 
Appendix J 

Chronology of Significant Events 

May 23, 2005 Target Capabilities List, Version 1.1 released 

July 22, 2005 S&T awards Food Biological Agent Detection 

Sensor cooperative agreements 

July 26, 2005 Strategic Partnership Program Agroterrorism 

Initiative announced 

August 8, 2005 Grants and Training awards the University of 

Kentucky (in collaboration with the University of 

Louisville and Western Kentucky University) 

$1.5M to develop a wireless milk tracking system 

September 30, 2005 Grants and Training provides Louisiana State 

University with $1.4 million to develop a course on 

preparedness and response to terrorist incidents 

relating to the food supply 

September 30, 2005 Grants and Training awards the University of 

Tennessee $2.0 million to develop a vulnerability 

assessment training course 

November 2, 2005 Draft National Infrastructure Protection Plan, Base 

Plan released 

December 1, 2005 DHS launches National Biosurveillance Integration 

System pilot system 

2006 

June 1, 2006 Grants and Training provides exercise support for a 

bottled water contamination exercise in North 

Carolina 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 149 
Appendix K 

Major Contributors to this Report 

Justin Brown, Inspector (Team Leader) 

Darin Wipperman, Inspector 

Levar Cole, Inspector 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 150 
Appendix L 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Under Secretary for Science and Technology 

Commissioner for U.S. Customs and Border Protection 

Under Secretary for Preparedness 

Assistant Secretary for Infrastructure Protection 

Assistant Secretary for the Office of Grants and Training 

Chief Medical Officer 

Assistant Secretary for Policy 

Assistant Secretary for Public Affairs 

Assistant Secretary fro Legislative and Intergovernmental Affairs 

Chief of Security 

DHS OIG Audit Liaison 

S&T Audit Liaison 

CBP Audit Liaison 

Preparedness Audit Liaison 

Office of Infrastructure Protection Audit Liaison 

Grants and Training OIG Liaison 

Chief Privacy Officer 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS Program Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

DHS’ Role in Food Defense and Critical Infrastructure Protection 

Page 151 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4100, fax your request to (202) 254-4285, or visit the OIG 

web site at www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind 

of criminal or noncriminal misconduct relative to department programs or 

operations, call the OIG Hotline at 1-800-323-8603; write to Department of 

Homeland Security, Washington, DC 20528, Attn: Office of Inspector 

General, Investigations Division – Hotline. The OIG seeks to protect the 

identity of each writer and caller.