Homeland Security: Much Is Being Done to Protect Agriculture from a Terrorist Attack, but Important Challenges Remain
Published: 2005-03-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: U.S. agriculture generates more than $1 trillion per year in economic activity and provides an abundant food supply for Americans and others. Since the September 11, 2001, attacks, there are new concerns about the vulnerability of U.S. agriculture to the deliberate introduction of animal and plant diseases (agroterrorism). Several agencies, including the U.S. Department of Agriculture (USDA), the Department of Homeland Security (DHS), the Department of Health and Human Services (HHS), the Environmental Protection Agency (EPA), and the Department of Defense (DOD), play a role in protecting the nation against agroterrorism. GAO examined (1) the federal agencies' roles and responsibilities to protect against agroterrorism, (2) the steps that the agencies have taken to manage the risks of agroterrorism, and (3) the challenges and problems that remain.
section_title: What GAO Found
paragraphs: After the terrorist attacks of September 11, 2001, federal agencies' roles and responsibilities were modified in several ways to help protect agriculture from an attack. First, the Homeland Security Act of 2002 established DHS and, among other things, charged it with coordinating U.S. efforts to protect against agroterrorism. The act also transferred a number of agency personnel and functions into DHS to conduct planning, response, and recovery efforts. Second, the President signed a number of presidential directives that further define agencies' specific roles in protecting agriculture. Finally, Congress passed legislation that expanded the responsibilities of USDA and HHS in relation to agriculture security. In carrying out these new responsibilities, USDA and other federal agencies have taken a number of actions. The agencies are coordinating development of plans and protocols to better manage the national response to terrorism, including agroterrorism, and, along with several states, have conducted exercises to test these new protocols and their response capabilities. Federal agencies also have been conducting vulnerability assessments of the agriculture infrastructure; have created networks of laboratories capable of diagnosing animal, plant, and human diseases; have begun efforts to develop a national veterinary stockpile that intends to include vaccines against foreign animal diseases; and have created new federal emergency coordinator positions to help states develop emergency response plans for the agriculture sector. However, the United States still faces complex challenges that limit the nation's ability to respond effectively to an attack against livestock. For example, USDA would not be able to deploy animal vaccines within 24 hours of an outbreak as called for in a presidential directive, in part because the only vaccines currently stored in the United States are for strains of foot and mouth disease, and these vaccines need to be sent to the United Kingdom (U.K.) to be activated for use. There are also management problems that inhibit the effectiveness of agencies' efforts to protect against agroterrorism. For instance, since the transfer of agricultural inspectors from USDA to DHS in 2003, there have been fewer inspections of agricultural products at the nation's ports of entry.

section_title: Letter
paragraphs: U.S. agriculture annually generates more than $1 trillion in economic  activity, including more than $50 billion in exports, and provides an  abundant and economical supply of food for Americans and others around  the world. Protecting agriculture is therefore critically important to the  well-being of Americans and the U.S. economy. While the United States has  never experienced a terrorist attack against agriculture, this important  industry is vulnerable for a variety of reasons, including the relative ease  with which livestock and crop diseases could be obtained and  disseminated. Many of these diseases are endemic in other parts of the  world and can be extracted from common materials, such as soil. Farms in  general are easily accessible because they are located in rural areas and  have minimal security, especially crop farms. Moreover, the highly  concentrated breeding and rearing practices of our livestock industry make  it a vulnerable target for terrorists because diseases could spread rapidly  and be very difficult to contain. For example, between 80 and 90 percent of  grain-fed beef cattle production is concentrated in less than 5 percent of  the nation’s feedlots. Therefore, the deliberate introduction of a highly  contagious animal disease in a single feedlot could have serious economic  consequences.
Most experts believe that the major effect of an attack on agriculture would  be economic. While many animal diseases are not transmissible to  humans, others are, and when this occurs there could be serious human  health consequences. For example, one of these transmissible diseases,  avian influenza, has caused 42 human deaths in Asia since January 2004,  when accidental outbreaks infected poultry flocks. Experts also believe  that livestock and poultry are more likely to be targets of a terrorist attack  than crops because deliberately spreading plant diseases is inherently more  difficult, requiring, among other things, favorable weather conditions such  as wind. One scenario of particular concern is the intentional introduction  of foot and mouth disease, a highly contagious livestock disease that does  not typically affect humans. The 2001 accidental outbreak of the disease in  the United Kingdom caused approximately $5 billion dollars in losses to the  food and agriculture sector, as well as comparable losses in the tourism  industry. By the time this disease was eradicated, over 4 million animals  had been slaughtered and burned, and the nation was banned from  exporting livestock and animal products that could transmit the virus.  Numerous other animal and plant diseases are also of concern, including  classical swine fever and soybean rust. Appendix III provides information  on the animal and plant diseases of primary concern that the U.S.  Department of Agriculture (USDA) believes could be used in an attack  against agriculture.
In 1998, we reported that the United States did not have a process in place  to detect and respond to a terrorist attack against agriculture and that if  such an attack were to occur, the country would rely on the process used to  respond to naturally occurring diseases. Specifically, we reported that  USDA—the agency primarily responsible for responding to major  outbreaks of disease involving livestock, poultry, and crops—lacked a  comprehensive, national strategy for responding to a widespread attack.  Among the problems we identified were concerns about the ability of  farmers, local veterinarians, and other experts to detect, correctly identify,  and report cases of disease in a timely manner. We also found that some  states had not developed or tested emergency response plans.
Since we last reported, the terrorist attacks of September 11, 2001, have  heightened concerns about agriculture’s vulnerability to terrorism,  including the deliberate introduction of livestock, poultry, and crop  diseases. Attacks targeted at agriculture are commonly referred to as  agroterrorism. For the purposes of this report, “agroterrorism” refers to the  deliberate introduction of animal and plant diseases at the farm level, prior  to further processing or production. Although other definitions of  agroterrorism can be broader and include the entire food chain, our  definition does not refer to the deliberate contamination of manufactured  food items, which was outside the scope of this review. In this context, you  asked that we address (1) changes that have taken place since September  2001 in the roles and responsibilities of federal agencies to protect against  agroterrorism, (2) specific steps that the United States has taken to manage  the risks of agroterrorism, and (3) what challenges and problems remain.
To identify the changes in agencies’ roles and responsibilities to protect  against agroterrorism, we reviewed laws, regulations, and presidential  directives prior to and after the terrorist attacks of September 11, 2001. We  also interviewed officials from the Department of Homeland Security  (DHS); the USDA; the Food and Drug Administration (FDA) and Centers  for Disease Control and Prevention (CDC) within the Department of Health  and Human Services (HHS); the Environmental Protection Agency (EPA);  the Department of Defense (DOD); and the Department of Justice. To  examine the specific steps that the United States has taken to manage the  risks of agroterrorism, we reviewed and analyzed unclassified agency  documents and contacted federal and state offices of Inspectors General to  assess what work has been done in relation to agroterrorism. We also  conducted structured interviews in person or via telephone with officials in  five states, selected in part for their leading role in producing agricultural  commodities sold before processing. These officials included  representatives from state departments of agriculture, emergency  management, and homeland security offices; agricultural inspectors from  DHS and USDA; and veterinarians, plant health, and other officials from  regional USDA and FDA offices. We examined the steps taken by the  agencies in the context of our work on homeland security risk management. To determine what challenges may remain, we conducted  structured interviews with experts from academia, private think tanks, and  other research institutions. We also reviewed an extensive body of relevant  literature, attended conferences, and spoke with industry and agency  officials. Additional details about the scope and methodology of our review  are presented in appendix I. We conducted our review from February 2004  through January 2005 in accordance with generally accepted government  auditing standards.
subsections: section_title: Background
paragraphs: Experts believe that the deliberate introduction of animal and plant  diseases at the farm level would cause severe economic disruption given  that agriculture accounts for 13 percent of the U.S. gross domestic product  and 18 percent of domestic employment. In the event of agroterrorism,  losses to farmers could result from decreases in the price of livestock,  poultry, and crops; reductions in sales due to a decline or halt in  productivity; inability to move animals to the market; and costs associated  with disease control, including disposal of contaminated animals or plants.  Losses could be particularly severe in states where animal and crop  production is concentrated. For example, three states produce 53 percent  of the total U.S. hog production and three states produce 39 percent of the  total U.S. soybean production. (See figs. 1 and 2.) Substantial losses could  also arise from halting exports; the value of U.S. agricultural exports in  fiscal year 2003 exceeded $56 billion.
Livestock production generated $106 billion in farm  revenue, or more than one-half of all farm revenue  in 2001. Intensive livestock production in which  large numbers of poultry, swine, and dairy and beef  cattle are held in confinement facilities accounted  for about $80 billion of this revenue. As a result, a  few areas contain a very large population of animals  that are at risk.
Following the terrorist attacks of 2001, Congress and the President  modified the roles and responsibilities of federal agencies to better protect  against agroterrorism. Congress passed the Homeland Security Act of   2002,establishing the Department of Homeland Security as the chief  coordinating agency for efforts to protect the United States from terrorist  acts, including agroterrorism. To outline agency goals and tasks for  protecting against agroterrorism, the President issued four Homeland  Security Presidential Directives. Congress also passed legislation that  clarifies USDA’s responsibilities over agriculture and food security.
subsections: section_title: The Department of Homeland Security Is Responsible for Coordinating Efforts to Protect against Agroterrorism and Has Absorbed Staff and Functions from Other Agencies
paragraphs: The Homeland Security Act of 2002 created the Department of Homeland  Security and assigned the new agency lead coordinating responsibility for  protecting the nation against terrorist acts, including agroterrorism. The  act transferred functions and personnel from other agencies to DHS, which  allowed it to accomplish this role. For example, the Homeland Security Act  of 2002 transferred the functions and personnel of FEMA, which had been  responsible for mitigating, planning for, and responding to natural  emergencies and major disasters, into DHS to support the new agency’s  responsibility for protecting the United States from terrorist attacks. In  addition, DHS is responsible for consolidating federal response plans for  various emergencies, including agroterrorism, into a single coordinated  plan, which is called the National Response Plan. DHS is also responsible,  through FEMA, for providing emergency response to terrorist attacks,  including managing the response, coordinating federal response resources,  and aiding recovery. Under federal law, once the President makes an  official declaration of an emergency or a major disaster, DHS is authorized  to direct federal agencies to support state and local efforts; coordinate  relief assistance; provide technical and advisory assistance to state and  local governments for management, control, and reduction of immediate  threats to public health and safety; and provide financial assistance.
The Homeland Security Act of 2002 transferred most of USDA’s  responsibility for conducting agricultural import inspections to DHS, which  provided DHS with the capability to recognize and prevent the entry of  organisms that may be used for agroterrorism. The act also authorized the  transfer of no more than 3,200 inspector positions from USDA’s Plant  Protection and Quarantine Unit to DHS. DHS and USDA signed an  interagency Memorandum of Agreement that, among other things, further  clarified the responsibilities of both agencies at the border. Pursuant to this  agreement, USDA may request the use of DHS inspectors during a major  animal or plant health incident of national significance—whether  intentional or natural. DHS acquired USDA’s authority to inspect  passenger declarations and cargo manifests, international passengers,  baggage, cargo, and conveyances, and hold suspect articles for quarantine  to prevent the introduction of plant or animal diseases. (See fig. 3.) USDA  retained its traditional authorities to conduct veterinary inspections of live,  imported animals; establish policy for inspections and quarantine  functions; provide risk analysis; develop and supervise training on  agriculture for DHS and USDA inspectors; conduct specialized inspections  of plant or pest material; and identify agricultural pests. Under DHS' usual  practices, a DHS inspector who comes across a questionable agricultural  product should hold it and turn the item over to USDA inspectors for a  more thorough analysis of its potential threat to U.S. agriculture.
The Homeland Security Act of 2002 also consolidated research efforts in  chemical, biological, and nuclear defense by transferring a number of  research facilities to DHS, including USDA’s Plum Island Animal Disease  Center. The center is the only place in the United States where certain  highly infectious foreign animal diseases are studied, including FMD. Since  the transfer, DHS has assumed responsibility for the security and  management of the facility. Although USDA still administers its own  research and diagnostic programs on the island, DHS and USDA have  established a Senior Leadership group at the center to integrate research  efforts in general and to coordinate the management for joint research  projects. For example, this group integrates USDA and DHS research  efforts on FMD.
The Homeland Security Act of 2002 transferred the Office for Domestic  Preparedness and its grant-making functions from the Department of  Justice’s Office of Justice Programs to DHS. This transfer established DHS  as the primary source of much federal homeland security funding to state  and local governments. In fiscal year 2005, DHS will distribute formula and  discretionary grants to the states through the Homeland Security Grant  Program. These grants have 2-year performance periods and support  expenditures, which include planning, organizing, equipment, training, test  exercises, and management and administration. DHS gives states the  flexibility to choose which emergency “disciplines”—such as law  enforcement, hazardous material response, and public works—to fund,  using the grants. Most DHS grant programs require states to obligate not  less than 80 percent of the total grant award to local units of government.  In the program application kit, DHS provides guidance on the types of  expenditures that are allowable. Beginning in fiscal year 2004, DHS  provided states with examples of resources, which could be acquired with  grant funds for prevention, response, and recovery efforts related to  agricultural and/or food security preparedness. These resources include  agricultural response equipment, and agriculture-related test exercises and  training.
Finally, the Homeland Security Act of 2002 created the Information  Analysis and Infrastructure Protection Directorate in DHS and transferred  intelligence, law enforcement, and vulnerability assessment functions from  other agencies into the directorate. Congress and the President have  tasked DHS, through this directorate, with developing a comprehensive  national plan to secure critical infrastructure sectors of the United States.  Accordingly, DHS has developed its interim National Infrastructure  Protection Plan, which includes strategies for securing the agriculture  sector. In addition to developing the plan, DHS is responsible for assessing  and identifying the nature and scope of terrorist threats to the homeland  based on information received and analyzed by other government agencies.  To do so, DHS receives information from the Federal Bureau of  Investigations, the Central Intelligence Agency, and other intelligence  agencies and assesses whether the combined information indicates a threat  to critical infrastructures.
section_title: Presidential Directives Define Agency Responsibilities for Protecting against Agroterrorism
paragraphs: Following the creation of DHS, the President issued four directives that  further define agencies’ roles and responsibilities for protecting against  terrorism. The most important of these directives in relation to agriculture  is HSPD-9, which was released in January 2004. The directive establishes a  national policy to defend the agriculture and food system against terrorist  attacks, major disasters, and other emergencies. Specifically, HSPD-9  outlines goals and assigns lead and supporting roles to agencies to achieve  these goals. (See fig. 4.) There are seven categories outlined in HSPD-9:  awareness and warning; vulnerability assessments; mitigation strategies;  response planning and recovery; outreach and professional development;  research and development; and budget. Federal agencies, especially DHS,  USDA, and HHS, are assigned lead responsibilities to achieve the stated  goals. To accomplish the tasks outlined in the seven categories, lead  agencies often must coordinate with secondary or supporting agencies and,  in some instances, with states and private industry as well. For example,  HSPD-9 directs DHS to improve awareness and warning capabilities by  coordinating with other agencies to develop a biological threat awareness  capacity that will enhance detection and characterization of agroterrorism.
The directive also designates DHS as the lead agency in ensuring that the  combined federal, state, and local response capabilities are adequate to  respond quickly to a terrorist attack or other emergencies affecting  agriculture or food. HSPD-9 also directs DHS to oversee a national  biological surveillance system that will combine surveillance information  collected from several agencies with threat and intelligence information to  allow DHS to characterize threats more quickly. According to DHS officials,  this interagency effort will help them differentiate between natural and  intentional outbreaks.
Likewise, HSPD-9 assigns lead tasks to USDA and HHS for agriculture and  food matters, respectively. Specific tasks for USDA and HHS include  developing safe, secure, and state-of-the-art agriculture laboratories that  research and develop diagnostic capabilities for foreign animal and  zoonotic diseases. Also under HSPD-9, USDA and HHS, in coordination  with EPA and DHS, are the lead agencies responsible for improving  existing recovery systems that will stabilize agriculture production and  rapidly remove and dispose of contaminated animals, plants, and food  products, and decontaminate premises following an agroterrorism attack.
HSPD-9 builds upon and augments tasks outlined in prior Homeland  Security Presidential Directives. HSPD-5 directs DHS to coordinate  development of the new National Response Plan that incorporates national  prevention, preparedness, response, and recovery plans into a single, all- hazard plan. USDA, in collaboration with other agencies including DHS,  were tasked with writing the sections of the National Response Plan  guiding U.S. efforts to respond to an attack on U.S. agriculture. HSPD-5  also directs DHS to consult with other federal agencies, state, and local  governments to implement a common National Incident Management  System, which standardizes planning, communications, and public  information during an incident in which multiple federal and state agencies  are involved. A key component of the National Incident Management  System is the Incident Command System, which is designed to allow  multiple agencies to coordinate the command, operations, planning,  logistics, finances, and administration during an incident. HSPD-5 further  directs agencies to require the adoption of the National Incident  Management System as a condition for states to receive federal  preparedness assistance.
HSPD-7 defines USDA and HHS as “sector-specific agencies” with  responsibilities for securing the agriculture and food sectors. These  agencies, in coordination with DHS, are tasked with collaborating with  federal, local, and state governments, as well as private industry and other  stakeholders to help protect their respective critical infrastructure sectors,  including agriculture. Among other things, HSPD-7 directs DHS to establish  systems, mechanisms, and procedures to share homeland security  information relevant to threats and vulnerabilities in critical infrastructures  with other federal departments and agencies, state and local governments,  and private industry in a timely manner.
Finally, HSPD-8 sets out a national preparedness goal for all hazards,  including agriculture. The directive calls on federal agencies to establish  readiness priorities, to deliver federal assistance to state and local  governments effectively and expeditiously, and to ensure that first  responders are prepared to respond to major events. The directive outlines  criteria for federal preparedness assistance to the states based on  assessments of population concentrations, critical infrastructure, and other  risk factors such as terrorism threats.
section_title: Other Legislation Has Expanded USDA’s and HHS’s Traditional Responsibilities to Protect against Agroterrorism
paragraphs: The traditional responsibilities of USDA and HHS have been augmented  through Congress’ passage of the Bioterrorism Act of 2002. This act made  USDA and HHS responsible for requiring companies, laboratories, and  other entities to register materials that could be dangerous to agriculture  production and human health. It also required USDA and HHS to develop  an inventory of potentially dangerous agents and toxins that cause animal,  plant, or human diseases. Furthermore, individuals who possess or use  such materials must register with the Secretary of Agriculture or HHS and  submit to a background check by the U.S. Attorney General. Also, the act  directed USDA and HHS to take a number of steps to improve surveillance  for such materials. Specifically, the act directed USDA and HHS to  coordinate surveillance activities to detect zoonotic diseases. The act also  authorized USDA to conduct and support research into the development of  an agricultural bioterrorism early warning system. The system would  enhance the capacity of and coordination between state veterinary  diagnostic laboratories, federal and state agricultural research facilities,  and public health agencies. The act also gave USDA the authority to  coordinate with the intelligence community to better identify research  needs and evaluate materials or information acquired by the intelligence  community relating to potential threats to U.S. agriculture.
section_title: Since the Terrorist Attacks of 2001, Federal Agencies Have Taken Steps to Manage the Risks of Agroterrorism
paragraphs: In carrying out their new roles and responsibilities, federal agencies have  taken steps to manage the risks of agroterrorism, including the  development of a comprehensive national strategy that did not exist before  September 11, 2001. As part of this strategy, DHS has overseen the  development of national plans and the adoption of standard protocols that  will help agencies coordinate in protecting against and responding to  agroterrorism. Federal and state officials are also conducting joint  exercises to test the new plans and protocols. In addition, federal agencies  are taking a number of specific actions to protect against agroterrorism,  including those summarized as follows.
subsections: section_title: National Plans Are Being Prepared, Emergency Protocols Have Been Adopted, and Test Exercises Are Being Conducted
paragraphs: DHS coordinated with other agencies to create an interim “National  Infrastructure Protection Plan” to guide the efforts of federal, state, and  local governments and private industry to protect critical infrastructure  sectors, including agriculture, against terrorist attacks. The overall plan  incorporates sector-specific plans that include processes, guidance, and  mitigation strategies that address how DHS and other agencies will work  with state and local governments, private industry, and foreign  governments to safeguard the sectors. Additionally, the plan includes  initiatives for sharing warning data with state and local governments and  the private sector. (See app. V for more details about these plans.)
To outline how the nation will respond in the aftermath of an emergency or  major disaster such as a terrorist attack, DHS released a “National  Response Plan” in January 2005. The National Response Plan differs from  earlier federal emergency plans in that it describes the roles and outlines  the responsibilities for federal, state, and local responders in addressing  the national response to outbreaks or other emergencies in the food and  agriculture sector. DHS coordinated with USDA, HHS, and EPA to develop  the appendixes contained in the plan that pertain to protecting agriculture  and the food supply in emergencies, from first detection to the response  and recovery phase.
To further improve the response to emergencies such as agroterrorism,  DHS established the “National Incident Management System” in March  2004. A key component of the National Incident Management System is the  “Incident Command System,” which is designed to coordinate the  communication, personnel, and procedures of different agencies and levels  of government within a common organizational structure during an  emergency that requires the resources of multiple federal, state, and local  responders. HSPD-5 directs federal agencies to require that states become  compliant with the National Incident Management System in fiscal year  2005 as a condition for receiving federal grant aid for emergency  preparedness. To support this directive, DHS has established a number of  minimum requirements for states to implement during fiscal year 2005. A  DHS official noted that as of December 2004, most states had already  implemented the Incident Command System and other components of the  National Incident Management System. (See app. V for more information  on the National Incident Management System.)
Soybean rust is a serious disease, causing crop  losses.  Wind-borne spores contaminate plants,  causing infected tan and reddish brown lesions and  yellowing of leaves. Fungicides can be used to  control the spread of the disease. However, if left  untreated or treated too late, a soybean field's yield  losses can surpass 80 percent. Since November 10,  2004, when soybean rust was first discovered in  Louisiana, the disease has been discovered in  Alabama, Arkansas, Florida, Georgia, Mississippi,  Missouri, and South Carolina. The United States  produced about 70 billion acres of soybeans in  2002.
To test response capability, including aspects of the National Incident  Management System, federal and state agencies have collaborated in  conducting test exercises to simulate outbreaks of foreign animal and plant  diseases. For example, USDA, along with numerous other agencies,  conducted a 1-day exercise in September 2002 called “Crimson Sky,” which  simulated the intentional introduction of the FMD virus in five different  locations across the United States. Exercises have also been conducted to  test response capability to address plant diseases. For example, USDA and  Minnesota, with the assistance of Iowa, simulated an outbreak of soybean  rust using the Incident Command System in September 2004. Two months  later, there was an apparently natural outbreak of soybean rust in Louisiana  and other southern states, and USDA officials told us that the lessons  learned from the test exercise in coordinating their communications were  incorporated in response to the real outbreak. Federal, state, and industry  officials whom we interviewed said that these test exercises in general  have been useful in allowing players to better understand their roles and  responsibilities in a real-life event, to uncover shortfalls they had not  necessarily foreseen in planning, and to test solutions. For instance,  exercises have shown that some areas of agencies’ jurisdiction needed to  be better defined. Many participants have written unclassified “after- action” reports incorporating the lessons they learned and raising key  issues to be resolved. (See app. V for more information on test exercises.)
section_title: A Number of Agency- Specific Actions Are Under Way
paragraphs: In addition to the broad national planning efforts discussed, other specific  actions that federal agencies responsible for protecting against  agroterrorism have taken since 2001 include the following:  FDA and USDA are in various stages of developing vulnerability  assessments of the agriculture and food sectors, as called for in HSPD-9.  As part of a continuing effort to anticipate threats to farm products, FDA  has conducted vulnerability assessments of different categories of food  for which FDA has statutory responsibility, to identify those products  most vulnerable to deliberate contamination. Similarly, USDA is  assessing vulnerabilities in USDA-regulated products but had not  completed its preliminary assessments at the time of our review. Such  assessments are generally not consistent across program areas because  different maximum values for the impact of terrorist events are  sometimes used. (See app. V for more details about FDA and USDA  vulnerability assessments.)
To increase early warning and monitoring capabilities, USDA and HHS  have created laboratory networks to integrate existing federal, state,  and university laboratory resources. These networks are intended to  link laboratories that screen for animal, plant, and human health  diseases across the nation and help to provide diagnostic surge capacity  in the event of a disease outbreak. Within each network, the laboratories  use standardized diagnostic protocols and procedures to ensure  consistent results. For example, USDA provided funding and leadership  for two networks that serve the nation: the National Animal Health  Laboratory Network, which originally consisted of 12 state and  university veterinary laboratories nationwide, and the National Plant  Diagnostic Laboratory Network, which consists of 5 laboratories  located at land grant universities. By December 2004, the National  Animal Health Laboratory Network had expanded to 47 laboratories in  39 states surveying domestic and foreign animal diseases. When these  network laboratories find positive test results for foreign diseases,  USDA’s own federal laboratories in Ames, Iowa; Plum Island, New York;  and Beltsville, Maryland, still conduct their own diagnostic tests to  confirm results before USDA announces the outbreak of a disease.  Meanwhile, FDA, in conjunction with other agencies including USDA’s  Food Safety and Inspection Service, developed and have continuously  expanded, the Food Emergency Response Network to integrate 93 local,  state, and federal laboratories for the detection of biological, chemical,  and radiological agents in food. Likewise, the CDC has expanded its  Laboratory Response Network to address public health emergencies.  This network now enlists the technology and capacity of 138  laboratories across the United States and abroad in the event of a  suspected or known release of biological or chemical agents. These  federal laboratory networks have operated during animal, plant, and  human health emergencies in the past few years. For example, USDA’s  animal and plant laboratory networks tested samples in the 2002-2003  exotic Newcastle disease outbreak in poultry and in the sudden oak  death outbreak in California in 2004.
Agencies are also working to enhance coordination and communication  among multiple stakeholders. In particular, DHS, USDA, and other  agencies have established numerous interagency working groups to  coordinate their efforts to protect against agroterrorism. These working  groups are, in turn, coordinated through a Government Coordinating  Council, which DHS finalized in the fall of 2004. DHS, USDA, and HHS  alternately chair the Government Coordinating Council on a rotating  basis. DHS also helped the food and agriculture industry to establish  the Food and Agriculture Sector Coordinating Council to facilitate the  flow of alerts, plans, and other information between the federal and  state governments and industry groups. Through the Food and  Agriculture Sector Coordinating Council, DHS has been seeking the  expertise of the industry groups to develop national guidance, such as  the interim National Infrastructure Protection Plan. In turn, this plan is  intended to provide industry with a blueprint to develop strategies to  protect their assets. (See app. V for more details about interagency  working groups.)
USDA has established a steering committee, which includes  representatives from FDA and CDC, to guide efforts to develop a  National Veterinary Stockpile that, among other things, is intended to  address vaccines needed to respond to animal diseases most damaging  to human health and the economy. The steering committee will also  identify such things as reagents, personal protection equipment that  would be needed, how to obtain vaccines, as well as prioritizing a  stocking schedule for the National Veterinary Stockpile. This stockpile  is being developed for foreign animal diseases other than FMD, since  there is already a North American FMD Vaccine Bank. USDA is also  creating a separate vaccine bank for certain strains of avian influenza  that will be completed by May 2005.
DHS, USDA, and HHS are funding research to enhance the nation’s  protection against agroterrorism. Of note, DHS is providing $33 million  over 3 years to establish two university-based Centers of Excellence to  oversee research into post-harvest food protection and diseases that  affect livestock and poultry. In addition, as of 2004, USDA is supporting  homeland security research, including university-based efforts to  evaluate contaminated carcass disposal efforts, assess animal and plant  disease test exercises, and analyze pathways by which foreign animal  and plant diseases can enter the United States. CDC has also provided  $1 million in annual funding to a university for developing a center for  food security and public health that will support efforts such as online  programs to educate veterinarians in foreign animal diseases. (See app.  V for more details about research efforts.)
USDA’s Veterinary Services has developed a National Animal Health  Emergency Management System that provides comprehensive guidance  on mitigating, preparing for, responding to, and recovering from an  animal health emergency, including a terrorist attack. USDA officials  believe the system’s guidance is more efficient than that provided by  previous animal health manuals. For example, rather than changing with  each disease, the roles of various emergency response personnel change  to fit only three scenarios: an outbreak of a highly contagious disease  (e.g., FMD); an outbreak of a disease spread by “vectors” such as  mosquitoes (e.g., Venezuelan equine encephalomyelitis); or an outbreak  of a disease that is not highly contagious (e.g., bovine spongiform  encephalopathy). USDA officials believe that this approach will speed  response times and be more effective in containing any outbreaks,  whether natural or intentional. (See app. V for more details about  USDA’s National Animal Health Emergency Management System.)
Since 2002, USDA has created 14 Area Emergency Coordinator positions  across the nation for animal health, and 2 Regional Emergency  Coordinator positions for plant health, to coordinate federal and state  efforts in the event of an emergency, including agroterrorism. Among  other duties, these coordinators have assisted states in developing  emergency response plans in keeping with federal guidelines, and  helped organize test exercises. For example, an Area Emergency  Coordinator was involved in developing Wisconsin’s Animal Health  Emergency Management System, the nation’s first statewide plan that  parallels the National Animal Health Emergency Management System  and outlines tasks and responsibilities of agencies and organizations in  an animal health emergency. The USDA emergency coordinators have  also responded to recent natural outbreaks of plant and animal diseases,  acting in key roles under the Incident Command System. For example,  an Area Emergency Coordinator served as the liaison officer to the  command staff for the widely reported bovine spongiform  encephalopathy case in Washington state in January 2004. The Western  Regional Emergency Coordinator helped respond to the soybean rust  outbreak in Louisiana in November 2004 and acted as a coach for the  incident management team.
section_title: The United States Still Faces Complex Challenges and Management Problems in Protecting against Agroterrorism
paragraphs: Although many important steps have been taken to prevent or reduce the  impact of agroterrorism, the United States still faces complex challenges  that limit the nation’s ability to quickly and effectively respond to a  widespread attack on animal agriculture. There are also some less complex  management problems that impair the effectiveness of federal agencies’  efforts to protect against agroterrorism.
subsections: section_title: The United States Faces Challenges in Quickly Responding to a Widespread Attack on Animal Agriculture
paragraphs: Experts we spoke with told us that to effectively control the spread of  highly contagious foreign animal diseases, such as FMD, it is critical to  quickly identify animals that may have the disease, promptly confirm the  presence of the disease with diagnostic tools, and rapidly vaccinate  animals in the surrounding area. However, the United States faces a  shortage of veterinarians trained in foreign animal diseases, does not use  rapid diagnostic tools at the site of an outbreak, and has insufficient  vaccine stockpiles. These complex challenges impair the nation’s ability to  contain the spread of animal diseases that are of potential use in  agroterrorism.
subsections: section_title: Many Veterinarians Lack Training in Foreign Animal Diseases
paragraphs: Many U.S. veterinarians lack training to recognize the signs of foreign  animal diseases, according to a 2004 report produced for USDA. The report  notes that while all U.S. veterinary schools offer information about foreign  animal diseases, only about 26 percent of the nation’s veterinary graduates  have taken a course specifically dedicated to foreign animal diseases.  According to the report, only 12 of the 28 veterinary schools in the United  States offer courses dedicated to foreign animal diseases. Further, among  the 12 veterinary schools that offer such courses, 5 offer them as electives  rather than as core courses. As a result, when federal or state veterinarians  are called to determine whether symptoms suggest the presence of a  foreign animal disease, they may not have the training or expertise needed  to identify it, and the disease could go undetected. According to USDA  officials, however, all veterinary students must take instruction in  infectious diseases and pathology which, according to these officials,  includes foreign animal diseases. USDA officials also told us they have  worked to develop Web and CD-Rom-based training to strengthen  veterinary student training in foreign animal diseases.
Another reason for this lack of expertise in foreign animal diseases is that  such training is not required to obtain USDA accreditation. More than 80  percent of veterinarians in the United States are USDA-accredited and are  intended to be instrumental in maintaining effective disease surveillance and monitoring by accurately diagnosing and reporting animal diseases.  To be accredited, an individual must have graduated from an accredited  school of veterinary medicine, submitted an application certifying the  ability to complete 16 tasks such as recognizing common breeds of  livestock, completed a core orientation session, and be licensed or legally  able to practice without supervision. USDA officials believe that because  an accredited veterinarian must be licensed, this is an indication that they  have received basic training in foreign animal diseases. However, this  accreditation process does not require veterinarians to demonstrate their  ability to recognize or diagnose basic clinical signs of foreign animal  diseases. Furthermore, once granted, accreditation is valid for life and no  continuing education is required. The Association of American Veterinary  Medical Colleges believes that this process could be more rigorous if, as a  condition of accreditation, veterinarians were required to demonstrate an  ability to recognize clinical signs of foreign animal diseases at the time of  accreditation and also periodically throughout their careers. USDA  recognizes the need to modernize its accreditation process and agrees that  continuing education is needed. APHIS drafted a rule to modify its current  program by developing a two-tiered National Veterinary Accreditation  program, which would have requirements for supplemental training in such areas as emergency management and foreign animal diseases; however,  after more than 2 years, it is still not in effect. According to the Chief of  Staff of Emergency Management and Diagnostics at APHIS, the draft rule  has been undergoing revisions but had to be set aside several times in an  effort to pursue the development of other more important draft regulations  and emergency regulations. According to this official, the draft rule is now  being reviewed by USDA’s Office of General Counsel. This official told us  that this review can take several months, but if no problems are  encountered, it is anticipated that the draft rule will be published as a  proposed rule in the Federal Register during the first or second quarter of  calendar year 2005. USDA officials told us that new efforts are also being  made to strengthen APHIS’ role in colleges of veterinary medicine to  provide information on various aspects of regulatory medicine.
Finally, expertise in foreign animal diseases is lacking because most  veterinarians work in private practice where this skill is not required.  According to the American Veterinary Medical Association, approximately  74 percent of practicing veterinarians in the United States work in private  practice. Similarly, the Association of American Veterinary Medicine  reports that only about 5,000 veterinarians work in public service, some of  whom play an essential role in the detection, prevention, and control of  foreign animal diseases. USDA officials told us they intend to increase the  number of veterinarians entering public service by making new efforts to  increase veterinary students’ awareness of potential careers in public  service.
section_title: USDA Does Not Use Rapid Diagnostic Tools on Site
paragraphs: Foot and mouth disease (FMD) is a highly  contagious viral disease of cloven-hoofed animals  such as cattle, swine, and sheep. Infected animals  develop a fever and blisters on their tongue, lips,  and between their hooves. Many animals recover  from an FMD infection, but the disease leaves  them debilitated and causes losses in meat and  milk production. FMD does not have human health  implications. In 2001, an FMD outbreak occurred in  the United Kingdom, resulting in mass slaughtering  and burial of animals and a loss of about $4 billion.   Similarly, if an outbreak were to occur in the United  States, the current U.S. policy requires all infected  and exposed animals to be immediately  slaughtered and disposed of by incineration, burial,  or rendering, a process that subjects animal tissue  to heat and chemicals to separate the fat from the  protein and mineral components.
Another complex challenge impairing the ability of the United States to  quickly contain an outbreak and limit the loss of animals is the inability to  rapidly diagnose diseases at the site of an outbreak. Currently, if an animal  is suspected of having a foreign disease, a sample would be collected from  the sick animal and a federal official would send it by Express Mail to one  of USDA’s reference laboratories--either the NVSL in Ames, Iowa, or the  Foreign Animal Disease Diagnostic Laboratory located on Plum Island,  New York. Using traditional techniques, USDA technicians would  generally diagnose the disease in 3 to 4 days. During this time, the affected  animals and other animals within the vicinity, or those that had recent  contact with the sick animal, would be quarantined. Should USDA officially  confirm the presence of a disease, such as FMD, the affected herd and all  cattle, sheep, goats, swine, and susceptible wildlife—infected or not— within a minimum 10-kilometer zone around the infected farm would be  killed. USDA would wait for confirmation before slaughtering animals to  avoid causing unnecessary panic among producers and severe market  fluctuations. If the disease were to spread beyond the initial zone,  authorities would continue to quarantine and kill animals until the disease  was “stamped out.” USDA’s “Crimson Sky” test exercise in 2002, estimated  that, under the current “stamping out” approach, FMD would spread  rapidly, necessitating the slaughter of millions of animals and cause  staggering financial losses—precisely the type of high-visibility destruction  that some experts told us terrorists seek.
According to the former Associate Administrator for Special Research  Programs at USDA’s Agricultural Research Service, the impact of a disease  such as FMD can be mitigated if rapid diagnostic tools are used on site to  speed diagnosis. In 2000, under the direction of this official, USDA  developed state-of-the-art, rapid diagnostic tools to detect FMD, classical  swine fever, African swine fever, Rinderpest, avian influenza, and  Newcastle disease. According to this official, the rapid diagnostic tools  are designed to yield results in less than an hour and are intended to be  used outside of specialized laboratories, at the site of an outbreak.  Importantly, the tools can detect disease before the animal shows clinical  signs of infection. According to USDA, symptoms of FMD may take up to 14  days to appear, or even longer in sheep and goats. In fact, animals may  show no symptoms at all. USDA’s draft guidance for controlling FMD warns  that if the first animal infected with FMD does not outwardly show clinical  signs, detection may be delayed. The guidance further states that potential  delays and difficulty in detection may complicate the decision-making  process regarding appropriate disease control measures. According to the  former Associate Administrator, rapid diagnostic tools would not only  allow for a rapid diagnosis but would also permit the monitoring of nearby  herds before symptoms appeared so that only infected herds would have to  be killed. Slaughter would, therefore, be based not on proximity but on  actual infection, thereby reducing the number of animals lost and lessening  the impact of the attack. Overall, rapid diagnostic tools would be helpful  because FMD would be detected in less than an hour, informed control  measures could be implemented, and herds in the area would be under  regular surveillance.
Traditional methods of diagnosing exotic Newcastle  disease involve isolating the virus and can take 6-12  days to obtain results (pictured on top). Rapid  diagnostic tools involve a polymerase chain reaction  (PCR) process that identifies a piece of a virus’  genetic material that acts as a signature and can be  identified in a test. The PCR distinguishes the  pathogen from near or distant relatives and can find  the pathogen in clinical samples. The PCR  technology used in California during the 2002-2003  outbreak produced results in 4-6 hours.
According to state officials, the use of these rapid tools on site would also  help prevent laboratories from becoming overwhelmed with test samples,  which would be an advantage if a terrorist attack involved the introduction  of disease at multiple locations. In 2003, California state officials used rapid  diagnostic tools to test animals for exotic Newcastle disease—a contagious  and fatal viral disease affecting birds of all species. (See fig. 5.) These state  officials told us that the tools used at the time allowed diagnostic results  within 6 hours and enabled them to test up to 1,500 samples per day, many  more samples than traditional testing methods. State officials also told us  that rapid diagnostic tools would be useful during a widespread outbreak  so that individual animals or herds could be tested in a temporary  laboratory at the site of an outbreak, rather than waiting for results while  samples were sent to laboratories distant from the outbreak.
USDA officials believe that rapid diagnostic tools can be useful, but they  told us most such technologies are not yet ready to be used at the site of an  outbreak. While USDA has employed some of its rapid diagnostic tools for  exotic Newcastle disease and avian influenza, it has done so only in select  laboratories within the National Animal Health Laboratory Network.
There are several reasons why USDA is reluctant to use the tools outside of  a laboratory setting. One reason is that samples put into the rapid  diagnostic tests may contain a live virus. For highly contagious diseases  such as FMD and classical swine fever, USDA believes that rapid diagnostic  testing must be conducted in a specialized laboratory setting where certain  procedures are taken to prevent the virus from escaping and infecting  livestock and wildlife. According to the former Associate Administrator for  Special Research Programs at ARS, this precaution is unnecessary. Once a  sample is taken, it is inserted into a tube containing reagents that inactivate  the virus if it is present. The tube, as well as the person who collected the  sample, can then be decontaminated using a common solution, such as  acetic acid in the case of FMD, and the sample can be tested using the rapid diagnostic tool in a mobile unit at, for example, the entrance to the farm.  USDA officials agree that samples can be taken in this manner but told us  that their current technique for collecting samples for the rapid diagnostic  tools that USDA uses in its laboratories does not inactivate the sample. For  that reason, samples of highly contagious diseases must be processed  under special laboratory conditions. USDA uses this sampling technique in  order to preserve the “live virus” sample necessary for the traditional  method of diagnosing diseases. USDA officials told us they have initiated  discussions about sampling using an “inactivation model” such as  discussed above, but the sample would still be diagnosed using a rapid  diagnostic tool located in a laboratory.
Unlike USDA, agencies within DOD are using rapid diagnostic tools in the  field to obtain quick results during emergency situations or when a  laboratory setting is not possible, such as in combat zones. For example,  the Army is using various types of rapid diagnostic tools in Iraq to detect  pathogens used in biological warfare, such as anthrax. DOD officials told  us that for samples that are a “true unknown,” such as chemical substances  they encounter in combat, they utilize many safety procedures, such as  wearing protective clothing and opening samples in safety cabinets. The  officials also told us that the reagents they use to detect agents used in  biological warfare will inactivate viruses, allowing the test to be safely  conducted without contaminating the surrounding area. A DOD official  noted that with animal diseases, if samples are positive for a disease, then  contaminating other animals within that herd is not a concern since these  animals would have to be destroyed anyway.
Another reason USDA is reluctant to use rapid diagnostic tools at the site of  an outbreak is that personnel need training to use the tools. According to  the former ARS Associate Administrator, however, the tests are designed to  be performed by persons with limited training, using quality-controlled  standardized reagents and protocols that are consistent with international  standards. DOD concurs that the tools are not difficult to use, but to  ensure that samples are not contaminated and results are rigorous, the U.S.  Army Medical Research Institute of Infectious Diseases requires personnel  to undergo a 4-week training program and follow strict procedures, such as  loading and capping pathogen samples before adding the control samples  to help eliminate cross-contamination. To help increase confidence in the  accuracy of the results, DOD also uses more than one type of rapid  diagnostic tool to test a sample if it comes back positive.
USDA officials told us that although the rapid diagnostic tools have been  developed, these tools still need to be validated before they can be used in  order to rule out diseases with similar clinical signs or protein sequences  that might result in a false positive result. Therefore, USDA would still  make an initial diagnosis using traditional test procedures and  confirmatory testing would still be done at NVSL in Ames, Iowa, or at the  Foreign Animal Disease Diagnostic laboratory on Plum Island in New York.  Once the initial diagnosis is confirmed, USDA believes there may be  opportunities to use validated rapid diagnostic tools to evaluate herd health  either on site or at a nearby laboratory. USDA further agrees that it is  important to evaluate the costs and benefits of developing and validating  these tools for use outside of a laboratory setting.
section_title: Vaccines Cannot Be Rapidly Deployed to Contain a Widespread Disease Outbreak
paragraphs: For several reasons, USDA would not be able to deploy vaccines rapidly  enough to contain a widespread animal disease outbreak caused by a  deliberate attack. First, USDA has very few supplies of vaccines. The only  vaccines currently stored in the United States against foreign animal  diseases are for various strains of FMD because this disease is so highly  contagious. In place of vaccination, USDA generally prefers to immediately  slaughter diseased animals because international rules that the United  States and other countries have agreed to abide by are designed to prevent  trade in infected or vaccinated animals. As a result, vaccine stockpiles have  traditionally not been needed to control natural outbreaks. Also, vaccines  have not yet been developed for all foreign animal diseases that USDA  considers to be of primary concern. For example, worldwide, there is no  vaccine currently available for African swine fever. USDA’s ARS is  researching new vaccines, but it is unlikely that vaccines will ever be  developed for all strains of these diseases because of the vast number of  strains and subtypes for each disease. For example, there are 7 different  types of FMD with more than 60 different subtypes. According to an expert  we consulted, it is not realistic to develop vaccines for all of these  subtypes. It is also conceivable that a terrorist could genetically engineer a  new strain.
Second, the only vaccines that are stockpiled in the United States— vaccines for FMD—cannot be rapidly deployed because they are not stored  in a “ready-to-use” state. Although HSPD-9 states that vaccines should be  capable of deployment within 24 hours, USDA’s stockpiles are concentrates  that require additives to become a vaccine. Because the additive for the  FMD vaccine is manufactured in the United Kingdom, USDA must first ship  the stock there for bottling and subsequent testing. It can take up to 3  weeks to transform the stock into a vaccine once the concentrate arrives in  the United Kingdom. Vaccines are not stockpiled in a ready-to-use state  because vaccines generally have a shelf life of only 1 or 2 years before they  must be used or destroyed, and replacing stocks on a regular basis would  be expensive.
Yet until animals are vaccinated, USDA will have no recourse but to  slaughter animals in a systematic manner to contain the spread of the  disease. While this approach may be adequate for containing a limited  outbreak, the recent USDA test exercise of an intentional introduction of  FMD in multiple locations suggests that this approach would have  catastrophic results. Although USDA officials raise concerns about the  use of vaccination to control an outbreak, such as the limited number of  fully trained personnel to administer the vaccine, it is now acknowledged  that the ability to vaccinate, in conjunction with culling, may be a necessary  measure to contain an FMD outbreak. A recent evaluation by the National  Audit Office in the United Kingdom reports that the government has  substantially increased stocks of vaccines for FMD to better contain the  spread of FMD should another outbreak occur. Furthermore, USDA’s draft  response plan for an outbreak of FMD disease or other highly contagious  animal disease notes that vaccines may be used strategically to create  barriers between infected zones and disease-free zones.
The Centers for Disease Control and Prevention faces similar challenges in  stocking vaccines used to protect humans. Because many animal diseases  can affect humans, CDC is participating in the steering committee to help  USDA create its National Veterinary Stockpile. An expert suggests, and  CDC officials agree, that USDA could contract with pharmaceutical  companies to supply a stockpile of ready-to-use vaccines. Once the shelf  life for those vaccines neared expiration, the contractor could replenish  the stock and then sell the supply of vaccines nearing expiration in the  commercial marketplace to countries that routinely vaccinate livestock.  Where the market would not support such sales, USDA could donate the  old, yet still effective, vaccines to other countries where the disease is  endemic and there is still a demand. USDA officials agree that it would be  useful to have the FMD virus vaccine available within 24 hours. They also  told us they have plans to consider options to cut some of the time delay  for obtaining finished, ready-to-use vaccines. One option could be storing  the frozen bulk antigen concentrate needed to produce the vaccine at the  site of the foreign manufacturer. While it is the responsibility of the steering  committee to consider options and recommend specific processes for each  of the foreign animal diseases of concern to the United States, it is not clear  if the steering committee will address the costs and benefits of developing  ready-to-use vaccines that can be quickly deployed against diseases of  primary concern.
Finally, even if USDA were to overcome the difficulties discussed above  and develop adequate stockpiles of ready-to-use vaccines, current USDA  policy would require a complex decision-making process to determine if  vaccines would be deployed in an outbreak. In 2000, USDA decided to use a  decision tree flowchart combined with decision matrices that evaluate  multiple factors to determine when and if to use vaccines to control an  outbreak. Because the use of vaccines would affect trade and have major  consequences for both USDA and producers, the decision tree is complex  and may not be designed for rapid decision-making, such as would be  needed during a terrorist attack. For example, it requires information on  the availability of human resources, public opinion and perception of  government, industry acceptance, and vaccination costs, as well as  slaughter and disposal capacity. USDA officials agree that this process is  lengthy, but this is because of the many variables, including the location of  the outbreak in relation to susceptible animal populations as well as trade  concerns and restrictions that impact this decision-making process. As  previously noted, HSPD-9 requires that vaccines be deployed within 24  hours of an outbreak, but such rapid deployment may not be achievable  under the current, complex decision-making process. USDA officials told  us they can explore the possibility of designing a more rapid decision- making process; however, they noted that it would take additional time to  select, deploy, equip, and direct vaccination crews in a manner that would  be advantageous to disease eradication and not cause the virus to spread  from farm to farm due to the vaccination process. Hastily applied  vaccination programs could prove detrimental. A USDA official also told us  that it is not possible to estimate how long it would take to determine  whether to use FMD vaccines based on the decision tree flow chart, due to  the many variables involved in the process.
section_title: Federal Agencies Have Not Addressed Several Management Problems
paragraphs: In addition to the complex challenges discussed above, federal agencies  are encountering management problems that further impair the  effectiveness of their efforts to protect against agroterrorism. First, since  the transfer of agricultural inspectors to DHS, inspections and  interceptions of prohibited agricultural products and pests have declined  nationally, and inspectors are less available to respond to agricultural  emergencies. Second, there are weaknesses regarding the flow of critical  information among key stakeholders. Third, USDA has not hired a  sufficient number of Area and Regional Emergency Coordinators to help  states prepare for an agricultural emergency. Fourth, DHS has not  developed controls to avoid duplication of effort among agencies. Finally,  federal agencies’ diagnostic laboratory networks are not yet integrated for  diseases of common concern.
subsections: section_title: Agricultural Inspections and Interceptions Have Declined, and Fewer Inspectors Are Available to Respond to Agricultural Emergencies since the Transfer of USDA Inspectors to DHS
paragraphs: Since the transfer of most USDA Plant Protection and Quarantine (PPQ)  inspectors to DHS in March 2003, government officials, reports, and data  indicate that the nation may be more vulnerable to the introduction of  foreign animal and plant diseases through ports of entry into the United  States. In addition, the transfer of inspectors has reduced USDA’s ability  to respond to agricultural emergencies.
Inspectors Have Performed Fewer Agricultural Inspections and Made  Fewer Interceptions of Prohibited Plant and Animal Products and Pests USDA officials, as well as agricultural inspectors who now work at DHS,  told us that inspections of agricultural products have decreased at some  land border crossings, airports, and maritime ports—including three major  ports that receive a high percentage of the nation’s agricultural imports and  international flights. USDA provided us with data showing an overall  decline in the number of inspections nationwide since 2002—the last year  when USDA had sole responsibility of agricultural inspections. This  decrease occurred at a time when imports and international air traffic have  increased. In fiscal year 2002, there were 40.9 million agricultural  inspections at ports of entry; in fiscal year 2003, the year when USDA  inspectors transferred to DHS, 35.0 million inspections were conducted;  and in fiscal year 2004, there were 37.5 million agricultural inspections.  USDA data also show that inspections have decreased at certain types of  ports and by certain modes of entry nationwide, such as passenger baggage  and cargo. In particular, USDA officials and DHS inspectors told us that  the number of agricultural inspections has declined at three specific air and  sea ports that receive a large proportion of international cargo and  passenger baggage. For example, at one of these ports, former and current  DHS agricultural inspectors told us they had cut their inspections in late  2004 by more than 50 percent, from an average of about 1,200 cargo  containers per week to 500 per week. These inspectors said they reduced  inspections, in part, because of an instruction by the DHS port director to  cut their “holds” of agricultural cargo and conduct fewer inspections of tile,  which are often packed in a regulated material that can contain pests such  as snails and beetles. In August 2004, this port intercepted a species of  live, wood-boring beetles as a result of holding and inspecting cargo tile  shipments. However, another shipment at this port that was not inspected  was later found to contain the same beetles, which belong to the Asian  longhorned beetle family and are costly to treat. These inspectors were  concerned that if DHS continued to decrease agricultural inspections at  that port, importers would direct more illegal shipments there. DHS  officials acknowledged that, since the transfer of inspectors, inspections  have declined overall. However, they also pointed out that some ports have  increased their inspections in the past 2 years. For example, USDA data  show that inspections at land border crossings increased from 21.2 million  agricultural inspections in fiscal year 2002 to 22.5 million such inspections  in fiscal year 2004.
USDA data also indicate a decline in the number of agricultural  interceptions—seizures of prohibited plant and animal products, and  agricultural pests—at ports of entry nationwide since the transfer of  inspectors to DHS. Interceptions dropped from 1.8 million in fiscal year  2002, when USDA had sole responsibility for inspections, to 1.6 million in  2004, when DHS had primary responsibility for agriculture inspections.  However, in 2003, a transitional year, interceptions totaled 1.8 million.  Interceptions of reportable pests in particular have declined each fiscal  year—from 77,886 in 2002, to 72,988 in 2003, and to 54,109 in 2004. USDA  officials told us that interceptions are a meaningful indicator of effective  inspections because the purpose of inspecting agricultural products is to  intercept prohibited items and pests. USDA is concerned that the decrease  in interceptions may indicate a decline in the quality of inspections or a  switch to less effective methods. For example, USDA and DHS officials told  us that while agricultural inspectors rove several ports of entry with  sniffing dogs—an effective method for detecting and therefore intercepting  prohibited items—they are now used less frequently. DHS and USDA  officials also noted that the number of interceptions can vary based on a  number of factors aside from inspection quality, including changes in the  amount or type of agricultural products entering the country and in  international passenger travel patterns. However, we found that both  agricultural imports and international air passengers entering the United  States had increased over the past 2 fiscal years. USDA officials told us  that the number of interceptions should generally increase accordingly. At  the time of our report, DHS officials told us they were not aware of changes  in inspection methods or the risk management approach used at ports that  could account for the decline in agricultural inspections and interceptions.  According to agency officials, neither USDA nor DHS has analyzed the  inspections and interceptions data to identify trends and potential areas for  improvement, but headquarters officials at both agencies told us they  would analyze the data in early 2005.
Although USDA and DHS officials have not begun an analysis to determine  the reasons for declining agricultural inspections, they believe that several  factors are responsible for the decline in agricultural inspections and  interceptions. First, there is a shortage of agricultural inspectors  nationwide. In March 2003, USDA transferred 1,517 full-time inspectors,  according to DHS officials. Recently, DHS has been able to hire new  agricultural inspectors, but numerous departures left DHS with 1,446  agricultural inspectors and 426 vacancies as of mid-October 2004. DHS  told us that the agency intends to hire more than 500 additional agricultural  inspectors by February 2006. However, DHS officials said the agency’s  ability to quickly hire new inspectors is impeded by the length of time  needed for conducting security background checks. These background  checks, which are required before a newly hired inspector can report for  duty, can take more than a year to process, by which time applicants might  find other work. Agricultural inspectors working at the ports suggested to  us that DHS could allow new inspectors to perform nonsensitive  procedures while background checks are pending. According to a DHS  headquarters official, the agency is allowing some new inspectors with  modified background checks to start work under certain circumstances  while their full background investigations are pending.
Second, DHS agricultural inspectors are sometimes used for other  purposes, such as helping reduce immigration lines at airports. For  example, a DHS supervisor of agricultural inspectors at a capital city  airport told us that his inspectors are regularly pulled from their  agricultural duties to inspect other types of cargo or to assist in clearing  passengers though immigration. DHS officials told us that they need the  flexibility to occasionally shift inspectors’ duties to respond to different  priorities and needs, such as searching for drugs rather than inspecting  agricultural products for diseases or pests. For this reason, all customs,  immigration, and agricultural inspectors are cross-trained to perform  aspects of each other’s work.
Third, DHS agricultural inspectors do not always receive timely  information about high-risk cargo that should be held for inspection. For  example, after Canada confirmed a case of bovine spongiform  encephalopathy in 2003, inspectors at one border crossing did not receive a  warning from USDA to hold shipments of Canadian beef in time to  intercept it, and let the shipment through. In another instance, DHS  inspectors at a sea port in a major agricultural state told us they did not  receive an alert in late 2004 about an outbreak of a strain of avian influenza  that can cause death in humans, until a week after the warning was  released. DHS headquarters officials told us that while some cargo alerts  issued by USDA do not get to every agricultural specialist in a timely  manner, these instances represent a small fraction of inspections. However,  these officials agreed that improvements can be made to improve the flow  of information. Agricultural inspectors and other port officials attributed  the delay in receiving information to the transfer of some inspection roles  and responsibilities from USDA to DHS. This transfer has created  additional layers of communication that have impeded the rapid delivery of  critical information to port inspectors. Whereas USDA used to  communicate critical information directly to its agricultural inspectors,  DHS inspectors told us that now they receive information indirectly  through DHS headquarters. While DHS officials told us this practice is not  the agency’s policy, they acknowledged that some ports follow a  hierarchical chain of command. The memorandum of agreement between  the two agencies, which is designed to delineate new roles and  responsibilities, does not detail how DHS should convey alerts, warnings,  directives, or guidelines that come from USDA.
Finally, DHS and USDA have different databases and information  technology systems, including email, which has further hindered their  ability to share information. For example, agricultural inspectors who  transferred to DHS have experienced difficulty in accessing USDA’s  intranet site, where the Work Accomplishment Data System, the primary  agricultural inspections database, can be viewed. DHS agricultural  inspectors told us they still cannot enter USDA’s electronic Emergency  Action Notification System, which was created after September 11, 2001, to  track problematic or prohibited imported goods at ports of entry. DHS  officials acknowledged technical problems in the integration of the two  agencies’ systems, but said that they are working with USDA to address  these problems.
As a related matter, some DHS inspectors we spoke with expressed  concern that the cross-training for “legacy” customs and immigration  inspectors on agricultural laws, policies, and inspection procedures is  insufficient—and that these legacy inspectors are thus not able to increase  the number of items they refer to agricultural inspectors for further  examination. For example, while legacy customs inspectors receive  weeks of cross-training on immigration functions, they receive only 3 hours  of computer-based training on agriculture. Inspectors told us that while the  computer-based training raises awareness of the importance of agriculture,  it has not enabled legacy customs and immigration inspectors to increase  the amount of prohibited items they refer to agricultural inspectors.  Furthermore, the training is not always supervised by an agricultural  inspector who could answer questions. DHS officials agree that training  for legacy customs and immigration inspectors should be enhanced, and  told us that much training enabling legacy officers to make referrals to  agriculture specialists has been accomplished. These officials also told us  that all inspectors will be required to take a new course on agriculture  procedures that will be launched in fiscal year 2005. This course, which will  combine 16 to 24 hours of classroom and on-the-job training, is intended to  help customs and immigration inspectors better screen and refer  suspicious items to agricultural inspectors.
Fewer Inspectors Are Available to Help USDA Manage Agricultural  Emergencies  In addition to the decline in inspections and interceptions, DHS has not  been able to loan sufficient numbers of inspectors to respond to  agricultural emergencies managed by USDA, according to USDA officials.  Since the transfer of agricultural inspectors to DHS, the memorandum of  agreement between the two agencies implementing the transfer provisions  of the Homeland Security Act of 2002 states that DHS and USDA agreed to  develop procedures for USDA use of DHS employees, but it does not detail  how many employees DHS must loan, or for what time period. While DHS  has dispatched some agricultural inspectors on temporary duty, USDA  officials said that compared to the assistance available prior to the transfer  to DHS, the number of such personnel and the length of time they were  available have been inadequate. For example, USDA’s Western Regional  Office requested 83 agricultural inspectors from DHS to help control and  contain the exotic Newcastle disease outbreak in California over 2 months  in 2003. DHS provided 26 employees, but declined USDA’s requests for  further assistance. As a result, USDA officials are concerned that DHS will  not loan a sufficient number of specialists to help treat and contain future  agricultural emergencies, including the likely infection of the 2005 soybean  crop with soybean rust—a plant disease identified by USDA pursuant to the Bioterrorism Act of 2002 as having the potential to pose a severe threat.  DHS officials told us they have not been able to loan greater numbers of  inspectors to USDA to respond to agricultural emergencies because of the  staff shortage. DHS officials also said their policy is to loan agricultural  inspectors with specific expertise, but the agency’s first priority is to clear  ports of entry. Once DHS feels the ports are adequately staffed with  agricultural inspectors, the agency will be in a better position to dispatch  agricultural inspectors to USDA for emergency purposes.
Experts say that routine inspections at ports of entry cannot, by  themselves, prevent the accidental or intentional introduction of diseases.  However, experience has shown that inspections can be successful in  intercepting harmful diseases. In 2004, for example, DHS and USDA  agricultural inspectors at a California mail facility prevented an outbreak of  citrus canker when they successfully intercepted an illegal package of  branch cuttings from Japan that were intended to start a new variety of  citrus groves. An outbreak of citrus canker—a highly contagious bacterial  disease—would threaten the state’s crop and billion-dollar citrus industry,  the second-largest in the nation. The state of Florida, for example, has lost  2.1 million citrus trees due to the spread of the disease since 1995.
section_title: There Are Weaknesses Regarding the Flow of Critical Information Among Key Stakeholders
paragraphs: Federal agencies face barriers to promptly and effectively sharing critical  guidance that is important to state and industry stakeholders to better  protect the agriculture sector. State and industry officials told us they did  not receive draft national guidance in a timely fashion; DHS may not be  providing states sufficient guidance to allocate homeland security grant  funding for agriculture; and after-action reports on test exercises and real  outbreaks are not routinely shared with many stakeholders who could  benefit from the lessons learned.
While efforts have been made to include agricultural stakeholders in the  development of national guidance through various working groups, state  and industry officials told us they were not given sufficient time to review  and comment on key draft national guidance from DHS pertaining to  protecting infrastructure and preparing for emergencies. Specifically,  officials said that they had as little as 3 days to review and submit  comments on both the draft National Response Plan and the draft National  Infrastructure Protection Plan, even though they will be expected to  implement critical sections of these plans. As a result, state and industry  officials we spoke with are concerned that these plans may set unrealistic  expectations. Although we asked, DHS officials did not explain to us how  they distributed the National Response Plan to stakeholders. When  distributing the National Infrastructure Protection Plan, DHS officials sent  the plan to the offices of State Homeland Security Advisors, which had the  responsibility to solicit comments from appropriate stakeholders within a  2-week period. DHS officials told us that they had no input over which state  agencies received the draft plan, and they believe that in some instances  state officials may have delayed distribution to state departments of  agriculture. DHS also distributed the draft plan for review through the  Government Coordinating Council and the Food and Agriculture Sector  Coordinating Council. DHS officials told us that limiting the comment  period to 2 weeks was necessary in order to meet the timelines set by  HSPD-7. DHS officials further noted that because of the limited time  allowed for initial review of the National Infrastructure Protection Plan,  they released the plan as an interim document, allowing public and private  stakeholders to have more input in the final plan. DHS officials  acknowledged that in the future, they will use different procedures to  distribute drafts for state and industry comments.
Furthermore, DHS may not be providing sufficient guidance to the states  on how to use the Homeland Security Grant Program to obtain federal  emergency preparedness assistance to support the agricultural sector.  Although states must fulfill a number of requirements to receive DHS  emergency preparedness grants, DHS gives leeway regarding which  disciplines—such as fire, law enforcement, or agriculture—states choose  to fund with DHS grants. However, according to federal and state officials,  in the past, states used grant funding mainly for “traditional” emergency  disciplines such as law enforcement. Prior to 2004, DHS grant application  kits did not refer to agriculture as a sector eligible for emergency  assistance. DHS grant program officials told us that, based on feedback  from the states, in 2004 they included agriculture as an emergency  discipline toward which states can apply DHS funding. However, despite  the inclusion of agriculture in the application guidance, state officials told  us that they have received limited funding from DHS relative to other  emergency disciplines. For example, one official from a major agriculture  state told us that in fiscal year 2004 the state had set aside less than  $600,000 for agroterrorism projects out of a total of over $20 million that  DHS had allocated to the state. The same state had received a $2-million  grant to head a multistate partnership to protect against agroterrorism in  fiscal year 2003, but because this amount was in the form of a directed  grant, it could not be used to purchase equipment or training for state or  local responders. Federal officials believe that agriculture continues to  receive limited emphasis in the fiscal year 2005 grant kit relative to other  funding priorities. For example, in several instances throughout the fiscal  year 2005 grant kit, agriculture does not appear in lists of other disciplines  that are eligible for funding. Federal officials told us that without additional  guidance or emphasis, state governments would continue to fund  traditional emergency preparedness disciplines without considering  agriculture.
Finally, state and industry officials told us that there is no mechanism to  share lessons learned from federal and other state or industry test  exercises or from real-life animal and plant disease outbreaks—such as the  exotic Newcastle disease outbreak in California or from the karnal bunt  outbreak in Texas. Several state and industry representatives expressed  interest in receiving after-action reports so they could benefit from lessons  learned. They also believe that lessons learned do not have to be industry- specific. For example, one crop industry group official told us it would be  helpful to learn from FMD exercises, as well as the real-life bovine  spongiform encephalopathy outbreak, about ways to better communicate  during an outbreak. DHS officials told us that they will soon deploy a  secure Web site for the food and agriculture sector as a component of DHS’  Homeland Security Information Network. According to these officials, this  new Web site, now in development, will provide government and industry  the capability for information sharing; disseminating alerts and warnings;  sharing best practices; and coordinating efforts between the states,  industry, and federal agencies in a protected environment. However, this  effort is still in its early stages, and to date the proposed Web site does not  include after-action reports. In addition, federal, state, and industry  officials we spoke with were apparently unaware of the Web site’s  development.
section_title: USDA Currently Has an Inadequate Number of Area and Regional Emergency Coordinators, Resulting in Insufficient Technical Assistance to the States
paragraphs: USDA faces another management challenge in helping states prepare for  animal and plant emergencies because of an insufficient number of Area  and Regional Emergency Coordinators. As a result, states are not receiving  sufficient federal assistance in developing emergency response plans and  other activities. In 2002, USDA created 14 Area Emergency Coordinator  positions for animal health issues, and 1 Regional Emergency Coordinator  position for each of the eastern and western regions for plant disease  outbreaks. By the time of our report, USDA had filled 13 of the 14  coordinator positions on the animal side, and both of the plant health  positions. However, 2 of the animal health emergency coordinator  positions—which together span six states, including the two biggest  agricultural states—were vacant until late 2004. Federal officials also told  us that the current number of emergency coordinator positions is  insufficient to cover their areas or regions, even if all the positions were  filled. This is because the emergency coordinators are responsible for large  geographic areas. On average, Area Emergency Coordinators cover 3  states, while Regional Emergency Coordinators are responsible for up to 27  states, plus territories. As a result of this heavy workload, USDA officials  said, states are not receiving the maximum benefit of a coordinator’s  guidance and assistance in preparing state emergency response plans and  other preparedness activities. For example, 10 states had not completed  their required planning documents to identify resources needed in a plant  health emergency, by the September 30, 2004, deadline. And of those  plans submitted, USDA found some to be of unsatisfactory quality. USDA  officials attributed these delays and deficiencies, in part, to the fact that the  Regional Emergency Coordinators cannot spend adequate time with state  and federal agricultural officials in each state. They added that if there  were a greater number of emergency coordinators, each coordinator would  have fewer states to cover and thus more time to devote to their advisory  responsibilities.
USDA is also struggling to attract an adequate number of qualified  applicants due to the heavy travel involved to cover their areas or regions.  In addition, the job requires traveling to animal or plant health emergency  locations anywhere in the United States with as little as 24 hours notice,  and for several weeks or more at a time. For example, one animal health  emergency coordinator made 29 trips away from his duty station in 14  months on the job, not including other meetings in his three-state area.  These trips were necessary for test exercises, conferences, regional FEMA  meetings, USDA meetings, and the exotic Newcastle disease outbreak,  which occurred in a state outside his area. USDA officials say that APHIS’  goal is to put an Area Emergency Coordinator in each of the 43 states  where there is an Area Veterinarian in Charge, and to increase the Regional  Emergency Coordinators for plant disease outbreaks.
section_title: Shortcomings Exist in DHS’ Coordination of Federal Working Groups and Research Efforts
paragraphs: Government and industry officials have expressed concern about  shortcomings in DHS’ coordination of national efforts to protect against  agroterrorism. Since the issuance of HSPD-9 in January 2004, DHS and  other federal agencies established several interagency working groups to  address the tasks set out in the directive. To oversee these working groups,  DHS recently established a Government Coordinating Council for  agriculture. According to DHS officials, the council’s charter outlines the  specific tasks for federal agencies and the numerous working groups that  have been established to address HSPD-9. However, other federal officials  have expressed concern that because the working groups were established  prior to the development of the council, activities under way are not well  coordinated. For example, according to agency officials, the task list  developed by the Government Coordinating Council Charter does not  correspond to the tasks outlined in other important national guidance  documents, such as the National Response Plan. This discrepancy could  lead to confusing implementation of national guidance. Furthermore, state  and industry officials we interviewed said they did not understand the roles  and responsibilities of these various groups and that no one seemed to be  tracking the specific purpose of various efforts.
In addition, DHS lacks controls to coordinate research efforts with other  agencies, even though HSPD-9 specifically designates DHS as the agency  responsible for coordinating research efforts to protect against  agroterrorism. For example, some of the DHS-supported activities at the  Centers of Excellence appear to duplicate research conducted by USDA’s  Agricultural Research Service and the Cooperative State Research,  Education, and Extension Service. Specifically, one center is developing  rapid diagnostic tools for FMD and other foreign animal disease research  that is apparently already under way at USDA. DHS officials told us that  while program staff at DHS, HHS, USDA, and other agencies have engaged  in some preliminary discussions, there is no overall departmental  coordination of policy and budget issues concerning agriculture and food  security within DHS and with other departments and agencies. USDA  officials stated that while they are not aware of any overlap in the programs  supported by USDA and DHS, they are also not aware of the full scope of  the activities of the Centers of Excellence. USDA officials agree that more  coordination and cooperation is needed between USDA and DHS regarding  research activities.
section_title: Agencies’ Diagnostic Laboratory Networks Are Not Yet Integrated
paragraphs: While the development of USDA and HHS national diagnostic laboratory  networks is a positive step, their effectiveness in sharing diagnostic  information about diseases is compromised because their databases are  not yet integrated. At the time of our review, USDA had not integrated the  databases of its own national laboratory networks due to compatibility and  confidentiality issues. Because the USDA-affiliated laboratories operated  independently prior to the creation in 2002 of the National Animal Health  Laboratory Network and the National Plant Diagnostic Network, the  member laboratories are still using their individual databases. USDA  officials say these individual databases use different codes and messaging  systems and thus do not communicate well with each other. For example,  each National Animal Health Laboratory Network facility enters animal  disease diagnostic information into its own database, but neither of the  other laboratories in the network nor USDA’s NVSL—which is responsible  for officially testing foreign animal diseases—can read that information.  Instead, USDA relies on traditional communication channels, such as  emails and phone calls, to relay test results and the recipients do not have  electronic access to the detailed data. This approach limits USDA’s ability  to look at diagnostic data from across the country, detect trends, and  implement a response as quickly as it could with an integrated, real-time  system. USDA officials told us that if their laboratories’ diagnostic  databases were linked to each other nationally, the agency would be able to  better monitor and respond more quickly to disease outbreaks. USDA  stresses that the ability to share diagnostic information quickly is  particularly important for diseases that spread rapidly, such as FMD,  because response time is critical in controlling the spread of the disease  and reducing the economic impact.
In addition, the Food Emergency Response Network, CDC’s Laboratory  Response Network, and USDA’s National Animal Health Laboratory  Network and National Plant Diagnostic Network have not yet linked their  databases to each other for diseases of common concern. USDA and HHS  officials say it is important for their agencies to rapidly share complete  diagnostic test results with each other regarding diseases of concern to all  of the agencies involved. For example, if USDA found a chicken with a  strain of avian influenza that is transferable to humans, it would be  important for CDC to immediately become aware of this information so  that it could take appropriate measures to protect human health. Similarly,  if USDA confirmed a cow with bovine spongiform encephalopathy, it would  be important for FDA to know quickly so that it could investigate whether  the infected products had entered the food chain and take any necessary  action. In addition, USDA officials say that an integrated diagnostic  information system would aid federal agencies’ ability to gather evidence in  investigations, including criminal ones, of disease outbreaks.
Federal agencies are aware of the importance of integrating databases and  are taking steps to link their networks. As authorized by the Bioterrorism  Act of 2002, USDA is currently working on integrating all of the National  Animal Health Laboratory Network facilities so that they are able to send  diagnostic information in real-time to a national, electronic database. This  new database will allow diagnostic information to be sorted and analyzed  by USDA’s Centers for Epidemiology and Animal Health to track animal  diseases across the United States and detect any trends. If a positive test  result from any of the laboratories enters this new database, it will  automatically trigger a series of events to notify relevant parties. USDA  officials say that while they will still rely on phone calls and other  communication channels, this integrated, real-time database will improve  accuracy and speed in the event of an emergency. So far, USDA has piloted  the integration of some of the National Animal Health Laboratory Network  facilities’ databases for two foreign animal diseases, and it plans to launch  the national database for one of those diseases in February 2005. By the  end of 2005, USDA plans to integrate information from 12 pilot National  Animal Health Laboratory Network laboratories into the database for the  eight diseases of highest concern if this project is fully funded. In  addition, USDA is planning to integrate its plant disease and pest databases  for use in the National Plant Diagnostic Network to monitor outbreaks  nationwide.
USDA officials told us that integrating the different laboratories’ databases  is a challenge because of the concern for the leak of information. This  concern arises because in the event of an outbreak, there would be  international trade repercussions, and USDA would be responsible for  reimbursing producers for animals that would have to be destroyed. Other  laboratories face similar security concerns. However, the member  laboratories within CDC’s Laboratory Response Network, which has been  in place since 1999, are able to securely share diagnostic results with each  other, and officials told us it is important for USDA to overcome this  problem. Similarly, FDA uses a secure data exchange vehicle to share  information across its diagnostic laboratory network. In an effort to  address security concerns, USDA has begun building firewalls and  developing a set of protocols to protect data and ensure confidentiality in  such an environment.
As called for in HSPD-9, USDA and HHS created an interagency working  group in late 2004 to begin the process of coordinating their networks for  zoonotic disease surveillance. For example, USDA and FDA are looking at  how they can share animal disease and food pathogen test results through a  secure data exchange. However, the agencies must also work out common  testing benchmarks and protocols in order to interpret each other’s  diagnostic information accurately. For instance, if CDC was aware of the  type of diagnostic tools that USDA was using, the agency would be better  able to interpret results and take appropriate action. Agency officials added  that DHS’ planned National Biosurveillance Integration System intends to  use information from the various federal laboratory networks and combine  this with threat and intelligence data to further improve surveillance efforts  for potential terrorist activity. DHS officials indicated that the National  Biosurveillance Integration System would have an initial capability for  integrating data from these laboratories by spring 2005.
section_title: Conclusions
paragraphs: Prior to the terrorist attacks of 2001, relatively little attention had been  focused on agroterrorism. Recently, however, agriculture is receiving more  attention as experts and government officials increasingly recognize the  need to reduce the vulnerability of this sector to the deliberate introduction  of animal or plant diseases. Federal and state agencies are investing  considerable resources to better identify and manage the risks of  agroterrorism and have ramped up planning and coordination efforts to  respond to such an event. There are still, however, several important  challenges that should be addressed to better equip our nation to manage  agroterrorism. First, the United States must enhance its ability to quickly  identify and control diseases. Until USDA requires accredited veterinarians  to be trained to recognize the clinical signs of foreign animal diseases, such  diseases may not be detected and confirmed as early as possible, wasting  valuable time that could be spent containing them. Similarly, until USDA  evaluates the costs and benefits of using rapid diagnostic tools at the site of  an outbreak, the agency may be missing an opportunity to reduce the  impact of agroterrorism. Without on-site diagnosis to help monitor  neighboring herds, animals would likely be slaughtered based on proximity  rather than confirmed infection, unnecessarily magnifying the impact of an  attack. Once diseases have been accurately diagnosed, the United States  needs to quickly decide whether vaccines should be used to control an  outbreak and have the ability to deploy ready-to-use vaccines within 24  hours. Otherwise, during an emergency, valuable time could be lost while  deliberating whether to use vaccines and waiting for vaccines to be  transformed into a ready-to-use state.
Several less complex managerial problems should also be addressed in the  short term to improve the nation’s ability to protect against agroterrorism.
Our nation’s ports could be unnecessarily vulnerable to the intentional  introduction of a disease or pest, unless agencies analyze the reasons for  declining agricultural inspections and streamline the flow of information  between USDA and DHS inspectors at ports of entry. Furthermore, states  and industry may not have the ability and information to fulfill their  assigned roles in protecting agriculture unless DHS provides them with  meaningful opportunities to comment on national guidance; agencies share  after-action reports of test exercises and real-life emergencies with these  stakeholders; and USDA identifies ways to fill and expand Area and  Regional Emergency Coordinator positions. Finally, until DHS ensures that  tasks outlining agency responsibilities are consistent with national plans  and guidelines and DHS develops a method to adequately track federally  funded research efforts, the United States will lack a coordinated national  approach to protect against agroterrorism, possibly resulting in gaps or  needless duplication of effort. By overcoming these challenges, the United  States will be in a better position to protect against and respond to a  disease outbreak, whether natural or intentional.
section_title: Recommendations for Executive Action
paragraphs: To address significant and complex challenges that limit the United States'  ability to quickly and effectively respond to a widespread attack on animal  agriculture, we recommend that the Secretary of Agriculture address the  following four challenges in the context of the agency's overall risk  management efforts:  expedite the review and issuance of the draft rule on USDA’s  accreditation process for veterinarians, which would require training in  recognizing foreign animal diseases;  evaluate the costs and benefits of using rapid diagnostic tools at the site   examine the costs and benefits of developing stockpiles of ready-to-use  vaccines that can be quickly deployed against animal diseases of  primary concern; and  simplify the decision-making process for determining if and/or when to  use vaccines to control an outbreak to ensure that rapid decisions can  be made in the event of a terrorist attack.
To address management problems that reduce the effectiveness of  agencies’ routine efforts to protect against agroterrorism, we recommend  the following seven actions:  the Secretaries of Homeland Security and Agriculture work together to  identify the reasons for declining agricultural inspections and to identify  potential areas for improvement;   the Secretaries of Homeland Security and Agriculture streamline the  flow of information between USDA and DHS agricultural inspectors,  and expedite the integration of the two agencies’ databases and  information technology systems at the port level;  the Secretary of Homeland Security develop a mechanism to promptly  and effectively seek input from key stakeholders on national guidance  that affects their roles in protecting agriculture and responding to an  emergency;  the Secretaries of Homeland Security, Agriculture, and Health and  Human Services, and the Acting Administrator of the Environmental  Protection Agency compile relevant after-action reports from test  exercises and real-life emergencies and disseminate the reports through  the Homeland Security Information Network that DHS is developing;   the Secretary of Agriculture develop a strategy to increase the number  of Area and Regional Emergency Coordinator positions so that the  agency faces less difficulty filling these positions and is better able to  assist states in preparing for an agriculture emergency, including a  terrorist attack;  the Secretary of Homeland Security work to ensure that task lists for the  various agencies and working groups engaged in securing agriculture  are consistent with national plans and guidelines; and  the Secretary of Homeland Security develop controls to better  coordinate and track federally funded research efforts with other  agencies to protect against agroterrorism.
section_title: Agency Comments and Our Response
paragraphs: We provided USDA, DHS, HHS, EPA, and DOD with a draft of this report for  their review and comment. We received written comments on the report  and its recommendations from USDA, DHS, and HHS. EPA and DOD  provided minor technical clarifications.
USDA commented that the report provided a number of appropriate and  insightful recommendations. In several instances, USDA said it could take  actions that relate to our recommendations. For example, USDA said that  the department could explore the possibility of speeding up its process for  deciding when to use vaccines and that it will consider options to cut some  of the delay in obtaining ready-to-use vaccines. The department also raised  some concerns regarding various aspects of our report. For example, as we  recommend, USDA noted that there may be opportunities to use rapid  diagnostic tools to help with diagnosis of animal diseases, but said that the  tools need to be validated. Further, USDA commented that the agency  would in all cases still require confirmation that relies on traditional testing  procedures. As stated in our report, we continue to believe that use of these  tools at the site of an outbreak would help reduce the impact of a terrorist  attack because, among other things, these tools would help prevent  laboratories from becoming overwhelmed with test samples. USDA’s  written comments and our detailed responses to their concerns appear in  appendix VI. USDA also provided technical comments that we  incorporated, as appropriate, throughout the report.
DHS generally concurred with the report’s recommendations and indicated  that the agency is in the process of taking several corrective actions  addressing two of our recommendations. For example, as we recommend,  DHS is working with USDA to identify the reasons for declining agriculture  inspections and to identify potential areas for improvement. Regarding our  recommendation that DHS and USDA streamline the flow of information  between the two agencies’ agricultural inspectors, DHS stated that it is  already working with USDA to enhance communication; that is, the two  agencies are working to finalize the section in the Memorandum of  Agreement governing the sharing of information. DHS also provided  technical comments that we incorporated as appropriate. DHS’s written  comments and our detailed responses appear in appendix VII.
Overall, HHS agreed with the report’s recommendations. In commenting on  our recommendation that the agencies compile relevant after-action  reports from test exercises and real-life emergencies and disseminate the  reports through the Homeland Security Information Network that DHS is  developing, HHS officials noted that CDC already has standardized after- action reporting procedures in place. HHS officials also noted that another  challenge in protecting the nation against agroterrorism is the shortage of  laboratory space to conduct trials for vaccine development. HHS’s written  comments appear in appendix VIII. HHS also provided technical comments  that we incorporated, as appropriate, throughout the report.
We are sending copies of this report to the Secretaries of Agriculture,  Homeland Security, Health and Human Services, and Defense; the Acting  Administrator of the Environmental Protection Agency; and interested  congressional committees. In addition, this report will be available at no  charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions concerning this report, I can be  reached at (202) 512-3841 or robinsonr@gao.gov. Major contributors to this  report are included in appendix IX.
section_title: Scope and Methodology
paragraphs: To determine what changes have taken place since September 11, 2001, in  federal agencies’ roles and responsibilities to protect against  agroterrorism, we reviewed the relevant laws and presidential directives in  force before and after September 11, 2001. Specifically, our Office of  General Counsel reviewed the Robert T. Stafford Disaster Relief and  Emergency Assistance Act of 1974, the Agriculture Risk Protection Act of  2000,  the Farm Security and Rural Investment Act of 2002, the Public  Health Security and Bioterrorism Preparedness and Response Act of 2002,  and the Homeland Security Act of 2002. We also reviewed presidential  directives that define agency roles in emergencies such as acts of  agroterrorism, including Homeland Security Presidential Directives 5, 7, 8,  and 9. Finally, we interviewed numerous agency officials from the U.S.  Department of Agriculture (USDA), the Department of Homeland Security  (DHS), the Department of Health and Human Services (HHS), the  Environmental Protection Agency (EPA), the Department of Defense  (DOD), and the Department of Justice.
To determine what steps the federal government has taken to protect  against agroterrorism, we examined (1) steps taken at the federal level, (2)  federal action to prepare the states, and (3) coordination with industry. To  determine what steps have been taken at the federal level, we reviewed  classified and unclassified agency documents, including vulnerability  assessments conducted by USDA and HHS for agricultural and food  products; the draft of the interim National Infrastructure Protection Plan  and the final version of the National Response Plan; and lists of interagency  working groups and coordinating committees. We also interviewed agency  officials involved in creating and enforcing U.S. policy concerning  agroterrorism, including officials from USDA’s Office of Homeland  Security, Animal and Plant Health Inspection Service (APHIS), Agricultural  Research Service, and the Cooperative State Research Education and  Extension Service; DHS’ Information Analysis and Infrastructure  Protection directorate, Emergency Planning and Response directorate,  Border and Transportation Security directorate, Science and Technology  directorate, and Office for Domestic Preparedness; HHS’ Food and Drug  Administration and Centers for Disease Control and Prevention; and EPA.  In addition, we contacted USDA’s Inspector General and state governments  to determine what prior work had been done in this area. To identify  federal actions to strengthen surveillance at the borders we visited or  spoke with officials at three maritime ports, three airports, one border- crossing, and one international mail facility, where we interviewed  inspectors in DHS’ Customs and Border Protection, USDA’s Plant  Protection and Quarantine, and USDA’s Veterinary Services. We also  reviewed documents obtained from officials and inspectors, including  samples of inspection records, training schedules, as well as interagency  agreements that clarify agency roles and responsibilities, such as the  Memorandum of Agreement between DHS and USDA. Finally, we spoke  with officials at DHS’ Customs and Border Protection headquarters in  Washington, D.C. To assess the federal government’s coordination of its  efforts to protect against agroterrorism, we considered the Office of  Management and Budget Circular A-123, Management Accountability and  Control, and the standards in GAO’s Internal Control: Standards for  Internal Control in the Federal Government.
To determine how the federal government is helping states to protect  against agroterrorism, we used structured interviews of state and federal  officials in three major agriculture states we visited between July and  October 2004. We selected these states in part because of their status as the  top three producers of agricultural commodities sold before processing,  according to data that we obtained from USDA’s Economic Research  Service. Additionally, prior to our visit to the major agricultural states, we  visited officials in another state to test our structured interview  methodology. In these four states, we interviewed officials from state  agencies overseeing agriculture, homeland security, and emergency  services; personnel from federal and state diagnostic laboratory networks  and research centers; and officials from the regional or state offices of  USDA and the Food and Drug Administration. In addition to the three top  producing agriculture states, we had selected a fourth state to visit to get a  wider geographic distribution, but due to severe weather during the fall of  2004, we were only able to interview officials from the state department of  agriculture by phone. We also reviewed documentation from state and  federal officials, including state agricultural emergency response plans,  after-action reports from disease outbreaks and test exercises, and federal  guidance to the states.
To determine how the federal government is coordinating with industry to  protect against agroterrorism, we reviewed federal guidance to industry.  We also interviewed officials from organizations representing agriculture  interests in Washington D.C., and officials from DHS, USDA, and HHS who  are involved in coordinating with industry. Finally, we attended  coordinating meetings in Washington, D.C., involving representatives from  the food and agriculture sector and federal agencies.
To determine what challenges remain to protect against agroterrorism, we  used knowledge gained in addressing our other objectives. Using  structured interviews, we consulted with nongovernment experts in the  fields of agricultural security and counterterrorism. We selected our  experts based on their professional and research qualifications and  experience in the field of agroterrorism. We then analyzed the content of  the experts’ responses to identify common themes. Finally, we analyzed the  content of relevant peer-reviewed journal articles to identify common  themes.
We conducted our work from February 2004 through January 2005 in  accordance with generally accepted government auditing standards.
section_title: List of Experts GAO Consulted and Summary of Observations
paragraphs: This appendix provides the names and affiliations of nongovernment  experts from academia and other research organizations that we  interviewed during our work and summarizes key observations they made.  The information presented in this appendix does not reflect absolute  consensus of opinion among the experts on each topic; however, it  summarizes their observations on issues where many of the experts held  similar views. The information contained in this appendix should not be  considered to be the views of GAO.
subsections: section_title: List of Experts Interviewed
paragraphs: Roger Breeze, B.V.M.S., Ph.D., M.R.C.V.S., CEO, Centaur Science Group,  Former Director, Plum Island Animal Disease Center; Corrie Brown, D.V.M., Ph.D., Professor and Coordinator of International  Activities, Department of Veterinary Medicine, University of Georgia; Rocco Casagrande, Ph.D. in Biology, Director, The Center for Homeland  Security, Abt Associates;  Peter Chalk, Ph.D. in Political Science, Security and Political Analyst,  the Rand Corporation, Santa Monica, California;  R. James Cook, Ph.D., Interim Dean, College of Agricultural, Human,  and Natural Resource Sciences, Washington State University, Pullman,  Washington;  Radford Davis, D.V.M., M.P.H., Assistant Professor of Public Health,  College of Veterinary Medicine, Department of Veterinary Microbiology  and Preventive Medicine, Iowa State University; Jacqueline Fletcher, Ph.D., Past President of the America  Phytopathological Society, Currently Sarkeys Distinguished Professor,  Department of Entomology and Plant Pathology, Oklahoma State  University;   David R. Franz, D.V.M., Ph.D., Director, National Agricultural  Biosecurity Center, Kansas State University;  Brian Jenkins, Senior Advisor to the President of the Rand Corporation,  Member of the Comptroller General of the United States’ Advisory  Board;  Harley Moon, D.V.M., Ph.D., Chair, National Research Council  Committee on Biological Threats to Agricultural Plants and Animals,  Veterinary Medical Research Institute, Iowa State University;  James A. Roth, D.V.M., Ph.D., Distinguished Professor of Immunology,  Assistant Dean, International Programs and Public Policy; Director,  Center for Food Security and Public Health, College of Veterinary  Medicine, Iowa State University;  John L. Sherwood, Ph.D., Chair, American Phytopathological Society  Public Policy Board, Professor and Department Head, Department of  Plant Pathology, University of Georgia;  Mark C. Thurmond, D.V.M., Ph.D., Professor, Department of Medicine  and Epidemiology, University of California, Davis;  Alfonso Torres, D.V.M., MS, Ph.D, Executive Director, New York State  Animal Health Diagnostic Laboratory, and Associate Dean for Veterinary  Public Policy, College of Veterinary Medicine, Cornell University; and  Mark Wheelis, Senior Lecturer in Microbiology, University of California.
section_title: Summary of Experts’ Observations
paragraphs: We conducted structured interviews with nongovernment experts in the  fields of animal and plant diseases, terrorism, bioterrorism, and  agroterrorism. Before conducting our interviews, we reviewed the experts’  relevant studies and publications and provided them with a list of  questions. We sought their views on a range of topics, including the  vulnerability of U.S. agriculture, government agencies’ roles and  responsibilities, and agencies’ efforts to protect against agroterrorism.
section_title: Vulnerability of U.S. Agriculture
paragraphs: In general, experts agree that U.S. agriculture is vulnerable to  agroterrorism because of the relative ease with which highly contagious  diseases can be introduced in livestock and crops. An agroterrorism  event could not only cause severe economic losses to farmers and rural  communities, it could also halt or slow down international trade, and  negatively impact consumer confidence in the government’s ability to  ensure the safety of our food supply. For these reasons, many experts  believe that agriculture is an attractive target for terrorists.   Some  experts note that the methods for containing the spread of highly  infectious animal diseases—the highly visible and costly slaughter,  incineration, and/or burial of large numbers of animals—creates the  incentive for terrorists to attack.
Most experts note that livestock presents a more attractive target for  terrorists than crops, although both are vulnerable. The biggest threat at  the farm level would be the deliberate introduction of FMD, a highly  contagious animal disease that has been eradicated in the United States.  Highly contagious animal diseases can spread more quickly than plant  diseases, and the concentration of animals in feedlots and livestock  markets would contribute to the rapid spread of infection. Experts  remarked that an attack of this sort would be cheap, requires no  technical expertise, and would not harm the perpetrator. Some experts  remark that transportation of live cattle, hogs, and poultry, across the  country further enables diseases to spread quickly and easily over large  areas. On the other hand, some of the experts state that plant diseases  often need particular weather and environmental conditions for them to  take hold and flourish, making them a less attractive target.
Most experts identify the same group of animal diseases as the most  likely to be used against agriculture—those include FMD, avian  influenza, classical and African swine fevers, and exotic Newcastle  disease. However, there is wide consensus among experts that FMD  poses the highest risk because it is highly contagious, it results in the  need to destroy large numbers of animals which, in turn, generates a  great deal of media attention, and can inflict severe economic losses.  Some of the experts also raise concerns about zoonotic diseases such as  Rift Valley fever, Nipah Virus, and highly pathogenic avian influenza, but  not all experts agree that zoonotic diseases pose a significant threat. On  the plant side, some experts identify soybean rust as the disease of most  concern because it is easy to introduce and can spread by wind-borne  spores. Another expert raises concerns about the threat of  contamination with genetically engineered seeds and observes that it  would only take one or two seeds to contaminate an entire cargo of  product.
section_title: Government Agencies’ Roles and Responsibilities
paragraphs: Some experts we interviewed agree that the federal government is  undertaking significant initiatives to protect against agroterrorism. They  have generally favorable comments regarding the role that DHS plays in  protecting against agroterrorism. Some see the emergence of DHS as a  coordinator for agroterrorism activities within the federal government  as a major change that signals the importance of the agriculture sector.  Some experts also indicate that there was initial confusion about DHS’  role and that, because the agency is still very new, their role is still  evolving.
Many experts identify the lack of communication at the federal level as  their biggest concern and observe that within the federal government  there is no clear understanding of the initiatives that are in place to  protect against an attack and that there appears to be a duplication of  efforts.   Some experts believe that there is little coordination between  federal and state agencies, or between states, and that federal agencies  are not sufficiently sharing information with state and local officials.  Also, there is insufficient coordination and communication with  industry groups.
section_title: Agencies’ Efforts to Protect against Agroterrorism
paragraphs: In terms of planning efforts, several experts indicated that the  development of a National Response Plan and associated Emergency  Support Functions is exactly what was needed. They believe that it is  important to include the states’ input in the preparation of those  documents since the states will be the first responders. Several experts  state that preparing a response plan for dealing with an unintentional  outbreak would also be useful in preparing for an agroterrorism event.  Many experts note that test exercises can help identify potential  problems in response plans that may arise in application.
Many experts agree that focusing the majority of efforts on preventing  agroterrorism is not the answer because it is impossible to prevent all  disease introductions, whether accidental or intentional. Instead,  several experts note that agencies need to focus more on rapid  detection and identification of diseases and in establishing quick  response mechanisms.
Most experts agree that USDA’s creation of the National Animal Health  Laboratory Network and the National Plant Diagnostic Network is a  positive development. However, some experts disagree as to whether  the networks can provide sufficient surge capacity or if they need to be  expanded.
Some experts recommend additional research and development to  create FMD vaccines that contain markers to differentiate animals that  are merely vaccinated from those that are infected.
While some experts agree that training of veterinarians in foreign animal  diseases is inadequate, others note that actual training and awareness of  the importance of such training has improved. Some experts explain  that foreign animal disease training is not required in all veterinary  schools. This training is also not a prerequisite to become a USDA-  accredited veterinarian. On the plant side, some experts note that the  United States does not have an adequate number of people trained in  plant pathology. Many experts agree that more federal funding should be  dedicated to plant pathology research and job creation.
Some experts recommend using rapid diagnostic tools at the site of an  outbreak, rather than shipping samples to USDA reference laboratories.  They state that this would save valuable time in containing diseases,  whether naturally occurring or resulting from agroterrorism. The use of  these rapid tools on site would also help prevent laboratories from  becoming overwhelmed with samples, particularly if a terrorist attack  involved the multi-focal introduction of a disease or if diseases were  repeatedly introduced over long periods of time.
section_title: Additional Information on National and Agency-Specific Steps Taken to Protect against Agroterrorism
subsections: section_title: National Infrastructure Protection Plan
paragraphs: DHS worked jointly with other federal agencies to develop the interim  National Infrastructure Protection Plan, a standardized plan to safeguard  the nation’s critical infrastructure, including agriculture, before a terrorist  attack occurs. USDA and HHS, in consultation with DHS, developed sector- specific plans for agriculture and food, which were incorporated into the  interim National Infrastructure Protection Plan. These sector-specific plans  outline activities including:  Identifying the sector’s assets;  Identifying and assessing the vulnerabilities and interdependencies  among assets, and analyzing potential risks based on threats and  consequences;  Prioritizing assets based on an analysis and normalization of   Developing sustainable programs to protect assets and implementing  these programs when necessary; and  Using metrics to measure and communicate the effectiveness of the  sector-specific plans.
The National Infrastructure Protection Plan outlines roles and  responsibilities for federal, state, and local governments to safeguard  agriculture. The plan includes a description of coordination activities to  reduce the vulnerability of critical infrastructures. According to DHS  officials, the department—along with other federal departments and  agencies—will work with state and local governments and the private  sector to further refine stakeholder roles and responsibilities in order to  implement the National Infrastructure Protection Plan. In addition, these  entities will work together to implement sector-specific plans that will  support the National Infrastructure Protection Plan. The results of these  implementation efforts will be reflected in the next version of the National  Infrastructure Protection Plan, which according to DHS officials, will be  issued within 270 days of issuance of the current interim plan.
section_title: National Response Plan
paragraphs: In addition to the National Infrastructure Protection Plan, DHS coordinated  the integration of various interagency and agency-specific incident  management plans into a single all-hazard National Response Plan that  would be used in the event of a terrorist attack. The National Response  Plan includes appendixes, known as Emergency Support Functions, that  detail the responsibilities of federal agencies for coordinating resources  during national emergencies. One of the these appendixes, Emergency  Support Function-11, outlines the roles and responsibilities of local, state,  and federal responders in addressing the national response to outbreaks or  other emergencies in the food and agriculture sector. For example,  Emergency Support Function-11:   Assigns USDA, through APHIS, as the lead agency for responding to a  disease outbreak, and outlines USDA’s role in supporting such activities  as detection, control, and eradication;   Assigns state agencies, along with USDA’s Area Veterinarian-in-Charge,  the task of establishing a Joint Operations Center, which will serve as  the focal point for coordinating the disease management and decision- making process; and  Assigns local or county governments with the task of activating an  Emergency Operations Center to provide a local base of operations.
section_title: National Incident Management System
paragraphs: As directed by HSPD-5, DHS is overseeing the adoption of a National  Incident Management System by federal and state agencies that will be  used in an agroterrorism event. According to HSPD-5, the National Incident  Management System, released in March 2004, is intended to provide a  consistent nationwide approach for federal, state, and local governments to  work effectively and efficiently together to prepare for, respond to, and  recover from domestic incidents, regardless of cause, size, and complexity.  The National Incident Management System is a management framework  rather than a plan. It is intended to ensure coordinated responses to  disasters and terrorist attacks by outlining common standards for  preparedness training, exercises, and certification. A key component of the  National Incident Management System is the Incident Command System,  which is designed to coordinate the communications, personnel, and  procedures of different agencies and levels of government within a  common organizational structure during an emergency. The Incident  Command System, which was initially developed by the USDA Forest  Service and the state of California to help fight forest fires, has already  been adopted by a number of agencies and state governments. According  to USDA and state officials, the Incident Command System has already  been used in two natural animal disease outbreaks—an outbreak of low- pathogenic avian influenza among turkeys in Virginia and an exotic  Newcastle disease outbreak among chickens in California.
section_title: Test Exercises
paragraphs: Since 2001, exercises have simulated animal and plant disease outbreaks  and have tested aspects of the new National Incident Management System  protocols and the latest federal and state emergency response plans. These  exercises are in line with HSPD-9’s goal of ensuring that the combined  federal, state, and local response capabilities are adequate to respond  quickly and effectively to a terrorist attack. For example, in July 2004,  Kansas State University sponsored “Exercise High Plains Guardian,” a 2- day exercise to test the ability of federal and state military and civilian first  responders to cooperate in responding to an outbreak of FMD. The  scenario addressed quarantines, highway closings, elapsed time waiting for  federal lab results to confirm the suspicions of state veterinarians, and,  after positive confirmation, massive euthanizing and carcass disposal  efforts. As a result of these exercises, federal, state, and industry officials  told us that in general, the exercises have been useful in allowing players to  better understand their roles and responsibilities in a real-life event,  uncover shortfalls they had not necessarily foreseen in planning, and test  solutions. For example, the 2002 FMD exercise “Crimson Sky” made it clear  that USDA would be the lead federal department in providing policy and  direction for detecting, controlling, and eradicating an animal disease  outbreak. At the same time, the exercise indicated the importance of  interdependence between federal, state, and industry stakeholders in  carrying out emergency management and logistical response functions.  Furthermore, the exercise raised key issues concerning information- sharing between these players and the public, stopping and resuming  movement of animals, mobilizing federal resources, indemnity, vaccination  of herds, and decontamination policy.
section_title: Vulnerability Assessments
paragraphs: FDA’s initial vulnerability assessment utilized an analytical framework  called Operational Risk Management that considered both the severity of  the public health impact and the likelihood of such an event taking place.  FDA incorporated threat information received from the intelligence  community. To validate the findings, FDA contracted with the Institute of  Food Technologists to conduct a review of the initial assessment and  provide a critique of its application to food security. This review validated  FDA’s vulnerability assessment and provided additional information on the  public health consequences of a range of scenarios involving various  products, agents, and processes. FDA also contracted with Battelle  Memorial Institute to conduct a “Food and Cosmetics, Chemical,  Biological, and Radiological Threat Assessment.” This assessment provided  another decision-making tool and validated previous findings.
FDA updated and refined these assessments using a process developed by  DOD for use in assessing the vulnerabilities of military targets. This  assessment tool is known as “CARVER + Shock” and takes into  consideration information such as accessibility, vulnerability, and shock  (the shock value of an attack on a target due to the heinous nature of  terrorist events). FDA plans to use the results of these updated  assessments to develop technology interventions and countermeasures,  identify research needs, and provide guidance to the private sector.  Similarly, USDA is using the CARVER + Shock tool for assessing  vulnerabilities in USDA-regulated products, based on subject matter  experts and intelligence information. USDA was still developing the  assessment at the time of our review.
section_title: Interagency Working Groups
paragraphs: In addition to the Government Coordinating Council and the Food and  Agriculture Sector Council, federal agencies have established a number of  interagency working groups. One such interagency working group  composed of DHS, USDA, and CDC, is overseeing the development of a  national disease surveillance system. This system, when established, will  allow DHS to incorporate information on disease outbreaks from other  agencies to determine whether an outbreak is natural or intentional. USDA,  with support from DHS and EPA, is leading another working group that is  preparing a plant disease recovery system that is intended to allow U.S.  crop production to quickly recover from an attack. A final example of one  of the interagency working groups is one led by EPA and supported by  USDA, HHS, DHS, and DOD that has laid out interagency roles in  supporting state and local governments in decontamination and disposal of  infected plants and diseased animals following a major disease outbreak.
section_title: Research Efforts
paragraphs: DHS, USDA, and other agencies are funding research to protect agriculture.  Of note, DHS has established two Centers of Excellence that, along with  partner institutions, will oversee research to protect agriculture and the  food supply. DHS is providing $15 million in funding to the University of  Minnesota to oversee research into post-harvest food protection and $18  million to Texas A&M University to oversee research into diseases that  affect food animals. This funding is for a 3-year period of time. For  example, the Center of Excellence at Texas A&M will support efforts to  model the outbreak of FMD, which will allow responders to develop  accurate plans to counter an outbreak. The center will also support  research into the development of real-time diagnostic equipment and  vaccines against foreign animal and zoonotic diseases. Furthermore, the  center will develop training curricula for first responders, industry officials,  and production workers to increase response capability and awareness of  possible threats. USDA is also funding efforts to increase agricultural  security through the ARS, the research arm of USDA, and the Cooperative  State Research Education and Extension Service, which supports research  at universities and other institutions. USDA funding supported research at  facilities such as the National Agricultural Biosecurity Center at Kansas  State University, which will conduct projects including the evaluation of  contaminated carcass disposal efforts, assessments of animal and plant  disease test exercises, and the analysis of pathways by which foreign  animal and plant disease can enter the United States. Finally, other  agencies are supporting research into agricultural security. For example,  CDC provided $1 million per year to Iowa State University to fund a center  for food security and public health. This center will support efforts such as  “train the trainer” programs to educate veterinarians in foreign animal  diseases.
section_title: National Animal Health Emergency Management System
paragraphs: USDA’s National Animal Health Emergency Management System  incorporates a nationwide network of state and federal personnel in each  state, a National Animal Health Laboratory Network, and Area Emergency  Coordinators operating within the National Response Plan and the National  Incident Management System. The system also includes a steering  committee consisting of representatives of the animal health community  and other stakeholders that provides a means of communication and  coordination on issues of emergency management and response. The  central principles of the National Animal Health Emergency Management  System are provided in a single set of written guidelines that consolidate  strategy, operations, facility management, and administrative procedures.
section_title: Comments from the U.S. Department of Agriculture
paragraphs: The following are GAO’s comments on the U.S. Department of Agriculture’s  letter dated February 23, 2005.
subsections: section_title: GAO Comments
paragraphs: 1. Regarding USDA’s comments about the use of rapid diagnostic tools at  the site of an outbreak, our report acknowledges that USDA has already  utilized these tools for the control of exotic Newcastle disease and  avian influenza, but notes that USDA has only done so in a laboratory  setting. The report also acknowledged USDA’s concern for using this  technology at the site of an outbreak. For example, we noted that rapid  diagnostic tools still need to be validated for many diseases, including  FMD. Furthermore, the report acknowledges USDA’s concern that  samples need to be sent to USDA’s reference laboratories for final  confirmation to determine the disease subtype, which must be known  to deploy the correct type of vaccine. However, we continue to believe  that use of these tools at the site of an outbreak would help reduce the  impact of a terrorist attack because the tools would allow for a more  rapid diagnosis so that informed control measures could be  implemented as quickly as possible, and they would also permit the  monitoring of nearby herds before symptoms appeared so that only  infected herds would have to be killed. We understand that it would not  be appropriate or cost-effective to test all animals within a herd for any  highly infectious foreign animal disease because in all likelihood, if one  tests positive, the other animals in that herd would already be infected.  Also, as noted by state officials, the use of these tools would help  prevent laboratories from becoming overwhelmed with test samples in  the event of a terrorist attack involving the introduction of diseases at  multiple locations. 2. Regarding USDA’s comments about the use of vaccines to control an  outbreak, we acknowledge that using vaccines to control an outbreak  has some limitations; however, as our report states, a recent USDA test  exercise of an intentional introduction of FMD in multiple locations  suggests that the current “stamping out approach” would have  catastrophic results. Also, in February 2005, the National Audit Office  in the United Kingdom reported that based on experience from the 2001  FMD outbreak in the United Kingdom, the ability to vaccinate, in  conjunction with culling, may be necessary to contain an FMD  outbreak. The report further states that the government in the United  Kingdom has substantially increased stocks of vaccines for FMD in  order to better contain the spread of FMD should another outbreak  occur. Furthermore, USDA’s draft response plan for an outbreak of foot  and mouth disease or other highly contagious animal disease notes that  vaccines may be used strategically to create barriers between infected  zones and disease-free zones. We have added this information to the  report.
Furthermore, our report does not imply that it is cost effective to  maintain a supply of vaccines for every possible permutation of each  disease of concern. In fact, the report clearly states that it is unlikely  that vaccines will ever be developed for all strains of diseases and the  report also notes that vaccines should be developed for those of  primary concern to USDA. We do not state that vaccines are necessary  for all foreign animal diseases. We acknowledge, however, that our  report did not address the need to develop marker vaccines, and we  have modified the report to reflect this need. Finally, in response to  USDA’s comment about simplifying the decision-making process on  vaccine use, we have added language to the report to clarify USDA’s  position.  3. We modified our report to state that while all U.S. veterinary schools  offer information about foreign animal diseases, only about 26 percent  of the nation’s veterinary graduates have taken a course specifically  dedicated to foreign animal diseases. We also revised the report to note  that, according to USDA officials, all veterinary students must take  instruction in infectious diseases and pathology which, according to  these officials, includes foreign animal diseases.
In addition, we modified the report to state that USDA officials believe  that requiring accredited veterinarians to be licensed ensures that they  receive basic training in foreign animal diseases. Furthermore, we note  that there are a small number of personnel trained specifically in the  diagnosis of foreign animal diseases.
Finally, we modified the report to state that USDA officials told us that  new efforts are being made to strengthen APHIS’ role in colleges of  veterinary medicine to provide information on various aspects of  regulatory medicine and that USDA intends to increase the number of  veterinarians entering public service by working to increase the  veterinary student awareness of potential careers in public service.  4. We modified our report to include a statement about USDA’s  Memorandum of Agreement.
section_title: Comments from the Department of Homeland Security
paragraphs: The following are GAO’s comments on the Department of Homeland  Security’s letter dated February 14, 2005.
subsections: section_title: GAO Comments
paragraphs: 1. DHS provided minor modifications to the total number of agricultural  inspectors transferred from USDA as well as the number of inspectors  remaining as of October 2004. We have added a footnote to our report  to address this change. DHS commented that following the transition of  inspectors from USDA to DHS in mid-2003, the number of agricultural  inspections increased. We agree, and our report clearly identifies this  increase, but also states that between 2002 and 2004, the overall  number of inspections declined.  2. At the time of our draft report, USDA noted that they were unaware of  the full scope of research efforts supported by DHS, and DHS officials  told us that there was no overall departmental coordination of policy  and budget issues concerning agriculture security research. DHS now  states that since the summer of 2003, the agency has been working with  USDA’s Agricultural Research Service and with the Animal and Plant  Health Inspection Service to develop a joint strategy for foreign animal  disease research and diagnostic programs, and that a report  summarizing this strategy was submitted to the House of  Representatives Appropriations Subcommittee for Homeland Security  in January 2005. We have modified our report to reflect this comment.  Regarding DHS’s other comments about research at the Plum Island  Animal Disease Center and at the National Center for Foreign Animal  and Zoonotic Diseases at Texas A&M University, our report  acknowledges these efforts so we made no further modifications.  3. We agree that, as DHS states, the fiscal year 2004 and 2005 grant  program guidance notes that states may expend funds towards the  prevention, response, and mitigation of agroterrorism incidents  through the purchase of equipment, training, exercises or planning.  However, as our report states, we believe that the guidance continues  to provide limited emphasis on agriculture relative to other funding  priorities. As a result, state governments, which have been accustomed  to seek funding for traditional emergency disciplines such as law  enforcement, may not be sufficiently informed about the availability of  DHS grant funds to protect their agriculture industries.
section_title: Comments from the Department of Health and Human Services
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to the persons named above, Josey Ballenger, Jill Ann Roth  Edelson, and Steve Rossman made key contributions to this report. Other  contributors included Kevin Bray, Karen Keegan, Amanda Kutz, Lynn  Musser, Omari Norman, Cynthia Norris, and Claire van der Lee.
section_title: Related GAO Products
paragraphs: Drinking Water: Experts’ Views on How Federal Funding Can Best Be  Spent to Improve Security.  GAO-04-1098T.  Washington, D.C.:  September  30, 2004.
Emerging Infectious Diseases: Review of State and Federal Disease  Surveillance Efforts. GAO-04-877.  Washington, D.C.:  September 30, 2004.
Homeland Security: Observations on the National Strategies Related to  Terrorism.  GAO-04-1075T.  Washington, D.C.: September 22, 2004. 9/11 Commission Report: Reorganization, Transformation, and  Information Sharing.  GAO-04-1033T.  Washington, D.C:  August 3, 2004.
Status of Key Recommendations GAO Has Made to DHS and Its Legacy  Agencies.  GAO-04-865R.  Washington, D.C.:  July 2, 2004.
Coast Guard: Key Management and Budget Challenges for Fiscal Year  2005 and Beyond.  GAO-04-636T. Washington, D.C.:  April 7, 2004.
Homeland Security: Summary of Challenges Faced in Targeting  Oceangoing Cargo Containers for Inspection.  GAO-04-557T.  Washington,  D.C.:  March 31, 2004.
Homeland Security: Risk Communication Principles May Assist in  Refinement of the Homeland Security Advisory System. GAO-04-538T.   Washington, D.C.: March 16, 2004.
Homeland Security: Preliminary Observations on Efforts to Target  Security Inspections of Cargo Containers.  GAO-04-325T.  Washington,  D.C.:  December 16, 2003.
Bioterrorism: A Threat to Agriculture and the Food Supply.  GAO-04-259T.   Washington, D.C.: November 19, 2003.
Combating Bioterrorism: Actions Needed to Improve Security at Plum  Island Animal Disease Center.  GAO-03-847. Washington, D.C.:   September 19, 2003.
Food-Processing Security: Voluntary Efforts Are Under Way, but Federal  Agencies Cannot Fully Assess Their Implementation. GAO-03-342.  Washington, D.C.: February 14, 2003.
Homeland Security: CDC’s Oversight of the Select Agent Program.   GAO-03-315R.  Washington, D.C.: November 22, 2002.