Live Animal Imports: Agencies Need Better Collaboration to Reduce the Risk of Animal-Related Diseases
Published: 2010-11-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The United States legally imported more than 1 billion live animals from 2005 through 2008. With increased trade and travel, zoonotic diseases (transmitted between animals and humans) and animal diseases can emerge anywhere and spread rapidly. The importation of live animals is governed by five principal statutes and implemented by four agencies. GAO was asked to examine, among other things, (1) potential gaps in the statutory and regulatory framework governing live animal imports, if any, that may allow the introduction and spread of zoonotic and animal diseases and (2) the extent to which the agencies collaborate to meet their responsibilities, and face barriers, if any, to collaboration. GAO reviewed statutes, met with agency officials, visited ports of entry, and surveyed experts on animal imports.
section_title: What GAO Found
paragraphs: The statutory and regulatory framework for live animal imports has gaps that could allow the introduction of diseases into the United States, according to the experts GAO surveyed, discussions with agency officials, and scientific studies. Specifically, (1) The Department of Health and Human Services' Centers for Disease Control and Prevention (CDC) has regulations to prevent the importation of live animals that may pose a previously identified disease risk to humans for some diseases, but gaps in its regulations may allow animals presenting other zoonotic disease risks to enter the United States. CDC has solicited comments in advance of a rulemaking to better prevent the importation of animals that pose zoonotic disease risks. (2) The Department of the Interior's Fish and Wildlife Service (FWS) has regulations to prevent imports of nonnative live animals that could become invasive. However, it has not generally emphasized preventing the introduction of disease through importation. FWS is taking some initial steps to address disease risks. For example, in January 2010, the department directed FWS to review statutory authorities and regulations to address existing problems concerning nonnative live animals and recommend tools to better prevent the introduction of new threats. In contrast, the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) has regulations to prevent importing live animals it finds may pose a disease risk to agricultural animals. In 2008, APHIS issued a long-term strategy that would broaden its oversight of live animal imports. APHIS, the Department of Homeland Security's Customs and Border Protection (CBP), CDC, and FWS have collaborated to meet their responsibilities related to live animal imports by taking actions in five areas--strategic planning, joint strategies, written procedures, leveraging resources, and sharing data. However, experts GAO surveyed and agency officials GAO interviewed identified barriers to further collaboration on live animal imports, such as different program priorities and unclear roles and responsibilities, which are inherent when multiple agencies have related responsibilities. For example, experts noted that because each of the agencies is focused on a different aspect of live animal imports, no single entity has comprehensive responsibility for the zoonotic and animal disease risks posed by live animal imports. Experts also reported the need for an entity to help the agencies overcome these barriers to collaboration. Furthermore, the agencies have largely incompatible data systems, and a completion date for CBP's planned data system, which would provide the agencies with full operational access to information on incoming shipments of live animals, has not been established. In addition, APHIS, CBP, CDC, and FWS have yet to jointly determine which data elements on live animal imports are needed in this system for them to effectively oversee these imports, according to CBP officials. As a result, it is unclear whether the data elements in the completed system will meet interagency needs.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior develop a strategy to address barriers to agency collaboration that may allow potentially risky imported animals into the United States and jointly determine data needs to effectively oversee imported animals. In commenting on a draft of this report, the Departments of Agriculture, Interior and Homeland Security generally agreed with GAO's findings and recommendations. The Department of Health and Human Services provided technical comments only.

section_title: Letter
paragraphs: The United States is the world’s leading import market for live animals:  From 2005 through 2008 more than 1 billion live animals were legally  imported into the United States for agriculture, clinical research,  education and exhibition, the aquarium and pet industries, and other uses.  However, these imports have the potential to transmit zoonotic diseases— infectious diseases that can be transmitted between animals and humans  and can cause a substantial number of deaths. Furthermore, zoonotic  diseases have represented about 75 percent of newly emerging infectious  diseases in recent years. Because of growing international trade and travel,  these zoonotic diseases can emerge anywhere and spread rapidly around  the globe, as demonstrated by the 2003 outbreak of severe acute  respiratory syndrome (SARS), a viral respiratory illness that caused  pneumonia in most patients and was responsible for over 700 deaths in  East Asia and 43 deaths in Canada. Over the past few years, another  zoonotic disease, a highly pathogenic strain of avian influenza, killed  millions of wild and domestic birds worldwide and infected over 400  people, more than half of whom died. The spread of zoonotic diseases, as  well as other diseases affecting only animals, can take a major economic  toll on many industries. For example, the highly pathogenic avian  influenza in East Asia cost the affected economies an estimated $10  billion. In the United States, an outbreak of exotic Newcastle disease—a  contagious and fatal viral disease affecting birds—resulted in the  destruction of over 4.5 million birds in 2002 and 2003 at a cost of more  than $395 million in lost trade.
The laws governing the importation of live animals include five statutes  that are implemented by four agencies. Specifically,    Animal Health Protection Act. The U.S. Department of Agriculture’s  (USDA) Animal and Plant Health Inspection Service (APHIS) may prohibit  imports of particular animals to prevent the introduction of any pest or  disease affecting agricultural animals, such as cattle, horses, poultry, and  swine.
Lacey Act. The Department of the Interior’s Fish and Wildlife Service  (FWS) administers the prohibition against the import of animals that have  been individually listed in the statute or prescribed in FWS regulation to  be “injurious to human beings, to the interests of agriculture, horticulture,  forestry, or to wildlife or the wildlife resources of the United States.”
The Endangered Species Act of 1973. FWS administers the prohibition  against the import of animals that have been listed as threatened or  endangered species and implements other international agreements  related to these species.
Public Health Service Act. The Department of Health and Human Services’  Centers for Disease Control and Prevention (CDC) issues regulations to  prevent the introduction, transmission, and spread of communicable  diseases, including zoonotic diseases.
Tariff Act of 1930. The Department of Homeland Security’s (DHS)
Customs and Border Protection (CBP) is responsible for inspecting  imports for compliance with United States law and assisting all federal  agencies in enforcing their regulations—including regulations for live  animal imports—at ports of entry.
As we have previously reported, when responsibilities cut across more  than one federal agency—as they do for the regulation of live animal  imports to prevent the introduction and spread of diseases—it is important  for agencies to work collaboratively. Taking into account the nation’s  long-range fiscal challenges, we noted that the federal government must  identify ways to deliver results more efficiently and in a way that is  consistent with its multiple demands and limited resources. We also  identified key practices that can help enhance and sustain federal  agencies’ collaboration. In addition, we have previously reported on the  need to collaborate on animal disease issues. For example, we reported in  2007 on the steps that USDA took to prepare for highly pathogenic avian  influenza in poultry and recommended that USDA and DHS clarify their  roles during emergency responses to a disease outbreak. Both USDA and  DHS officials told us that they have taken preliminary steps to clarify and  better define their coordination roles. For example, the two agencies meet  on a regular basis to discuss such coordination.
In this context, you asked us to examine (1) potential gaps in the statutory  and regulatory framework governing live animal imports, if any, that may  allow the introduction and spread of zoonotic and animal diseases; (2) the  extent to which APHIS, CBP, CDC, and FWS collaborate to meet their  responsibilities and face barriers, if any, to collaboration; and (3) the  performance information that the responsible agencies have reported on  live animal imports.
To identify potential gaps in the statutory and regulatory framework, we  reviewed relevant statutes, the agencies’ implementing regulations, and  other agency documents. We also reviewed APHIS and FWS data on the  number, type, and exporting country of all imported animals regulated by  these two agencies for fiscal years 2005 through 2009. For the APHIS and  FWS data, we analyzed documentation related to the data, and worked  with agency officials to identify data problems, and determined the data  were sufficiently reliable for the purposes of providing background to this  report. To obtain information on potential gaps in the statutory and  regulatory framework as well as agencies’ processes for overseeing live  animal imports, we interviewed officials at agency headquarters and ports  of entry—airports in Atlanta, Baltimore, Los Angeles, New York, and  Washington, D.C., and the land border crossings with Mexico at Otay Mesa  and San Ysidro, California. At these ports, we focused our review on the  legal importation of live animals and not on agencies’ actions to prevent  animal smuggling. We also reviewed scientific studies on zoonotic and  animal diseases, including studies by the National Academies of Sciences.
To examine the extent to which the four agencies collaborate to meet their  responsibilities and face barriers, if any, to collaboration, we reviewed  each agency’s strategic plans, policies, and protocols; reviewed  documentation on the allocation of staff resources; and interviewed  headquarters officials. We also examined the degree to which the agencies’  collaborative efforts reflected the key practices we had identified that can  help enhance and sustain collaboration among federal agencies.
To address the first two objectives, we also conducted a two-round survey  to identify potential gaps in the current statutory and regulatory  framework, how well responsible agencies collaborate to meet their  responsibilities, and potential barriers to collaboration. The first round of  the survey was conducted from January through February 2010, and the  second round was conducted from April through May 2010. We identified  knowledgeable experts who had primary employment responsibilities  related to or dependent on live animal imports, authored peer-reviewed  papers, presented at professional conferences, provided testimony on the  subject matter to Congress, or were recognized by their peers as experts  on live animal imports. To ensure a cross section of different sectors, we  selected experts from federal and state government, academia,  nongovernmental organizations, and industry to obtain a broad spectrum  of opinions. For the first round, we sent surveys that consisted of open- ended questions (questions that solicit additional information) to our  initial list of 39 experts, and we received responses from 33, resulting in a  response rate of about 85 percent. On the basis of recommendations  provided by those responding in our first round and other experts, we  expanded our list of experts to 64 for the survey’s second round, which  consisted of closed-ended questions (questions with a set of answers to  choose from). Of these 64 experts, we received responses from 56,  resulting in a response rate of about 88 percent for the second round.
To examine the performance information the responsible agencies have  reported on live animal imports in their planning and reporting documents,  we reviewed strategic plans, operational plans, mission statements, and  annual performance plans and reports from APHIS, CBP, CDC, and FWS.  A more detailed discussion of our scope and methodology is presented in  appendix I.
We conducted this performance audit from August 2009 through October  2010, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: APHIS, CBP, CDC, and FWS share responsibility for preventing the  importation of live animals that may introduce and spread zoonotic and  animal diseases. APHIS, CDC, and FWS have developed regulations that  provide specific requirements and restrictions on the importation of  animals. In some cases, more than one agency may regulate a given  animal. For example, CDC regulates dogs for their risk of spreading rabies  to humans, and APHIS regulates dogs from countries with screwworm, a  parasite that can cause great damage to domestic livestock and other  warm-blooded animals, for their risk of spreading this parasite to  agricultural animals. Information on each agency’s responsibilities   and oversight activities follows and is presented in greater detail in  appendix II.
subsections: section_title: Agencies That Are Responsible for Live Animal Imports
paragraphs: While CBP is responsible for overseeing all imports and assists other  agencies in enforcing their import regulations, APHIS, CDC, and FWS have  specific statutory and regulatory responsibilities for protecting human,  domesticated animal, and wildlife health from risks posed by live animal  imports.
APHIS. APHIS restricts the importation of live animals that it has  determined may pose a disease risk to agricultural animals, such as cattle,  horses, poultry, sheep, and swine. APHIS requires that many of the  animals it regulates be visually inspected at the port of entry and generally  requires the animals be accompanied by health certificates signed by a  licensed veterinarian in the country of export and import permits. APHIS  determines the level of inspection for animals on the basis of their  associated disease risk, for both the type of animal and country of export.  As a result of this determination, APHIS may restrict imports of certain  animals from certain countries or require that animals undergo quarantine  and disease testing. APHIS veterinarians inspect live animal imports at 15  land ports along the border with Mexico, 20 land ports along the border  with Canada, and 30 airports across the continental United States, and in  Alaska, Hawaii, and Puerto Rico. In addition, APHIS maintains animal  quarantine facilities in southern California, southern Florida, and New  York state and oversees private quarantine facilities for birds and horses in  southern California. At these quarantine facilities, imported animals are  held until test results for various diseases are received.
CBP. CBP assists other federal agencies in enforcing their import  regulations, has the primary authority to inspect imports, and seeks to  interdict shipments of contraband and the illegal importation of live  animals and other products while facilitating the flow of legal travel and  trade. According to CBP officials, when a live animal shipment arrives at a  port of entry, CBP holds and refers the shipment to the responsible agency  or agencies. CBP holds the import until an agency representative is  available to release it. After the responsible regulating agency has released  the import, CBP clears the import for entry into the United States. CBP  staff are present at more than 300 land, air, and sea ports of entry and are  trained in the procedures to follow when live animals are presented for  customs clearance.
CDC. CDC restricts the importation of live animals that it has determined  pose a risk to public health. CDC’s restrictions on these imports vary by  type of animal and can include banning certain imports, requiring permits,  requiring vaccination certificates, and requiring quarantine. CDC staff are  not present at all ports of entry to routinely inspect live animal imports.  According to CDC officials, CDC relies on APHIS, CBP, and FWS staff to  enforce its regulations at ports of entry. When the agencies’ staff have  questions about enforcing CDC’s regulations, they are to contact CDC  quarantine public health officers, who are often located at a CDC  quarantine station that is at or near the port of entry. CDC has 20  quarantine stations in the continental United States, Alaska, Hawaii, and  Puerto Rico.
FWS. FWS restricts the importation of certain wildlife. Specifically, FWS  restricts the importation of injurious wildlife and threatened or  endangered species and related species for which international trade is  regulated under international agreements. Injurious wildlife includes  animals that are individually listed in the Lacey Act or prescribed in FWS  regulations to be injurious to human beings; to the interests of agriculture,  horticulture, or forestry; or to wildlife or the wildlife resources of the  United States. FWS seeks to prevent the introduction of invasive species  as injurious wildlife under the Lacey Act. Invasive species are alien (or  nonnative) species whose introduction does, or is likely to, cause  economic or environmental harm or harm to human health. At ports of  entry, FWS wildlife inspectors review the required import documents and,  for some live animal shipments, perform visual inspections. If FWS  determines that the animals are prohibited from importation based on  FWS regulations, for example, are injurious to wildlife or threatened or  endangered species, it rejects the import unless it has an FWS permit,  which may be issued under certain conditions, such as educational  purposes. FWS has about 120 wildlife inspectors who handle shipments at  49 ports of entry nationwide, including 7 land ports along the Mexican  border, 24 land ports along the Canadian border, and 18 designated ports  for air, ocean, rail, and truck across the continental United States and in  Alaska and Hawaii.
section_title: Number, Type, and Purpose of Live Animals Imports
paragraphs: APHIS and FWS data systems provide information on the number of and  purpose for live animal imports, as well as on the country from which the  import has been shipped into the United States in recent years. According  to the APHIS data system, about 32 million live animals—mostly  agricultural or aquacultural—were imported under APHIS regulation in  fiscal year 2008, the most recent year for which verified data were  available. They included cattle, fish, poultry, and swine. According to the  FWS data system, about 177 million live animals—all wildlife—were  imported under FWS regulation in fiscal year 2009. About 157 million of  these imports were fish. Other types of animals imported under FWS  regulation included amphibians, birds, corals, crustaceans, insects,  mammals, mollusks, and reptiles. More information about the number and  type of live animal imports is in appendix III.
section_title: Interagency Collaboration
paragraphs: In 2000, we reported that agencies face a range of barriers when they  attempt to collaborate with other agencies. With these barriers in place,  federal agencies carry out programs in a fragmented, uncoordinated way,  resulting in a patchwork of programs that can waste scarce funds, confuse  and frustrate program customers, and limit the overall effectiveness of the  federal effort. Subsequently, in 2005, we identified key practices that can  help enhance and sustain collaboration among federal agencies. Among  the practices we identified were (1) defining and articulating a common  outcome; (2) defining and agreeing on roles and responsibilities; (3)  establishing mutually reinforcing or joint strategies; (4) identifying and  addressing needs by leveraging resources; and (5) establishing compatible  policies, procedures, and other means to operate across agency  boundaries. In our 2005 report, we stated that while we generally believe  that the application of as many of these practices as possible increases the  likelihood of effective collaboration, we also recognize that there is a wide  range of situations and circumstances in which agencies work together.
section_title: The One Health Initiative Discusses Collaboration to Address Zoonotic and Animal Diseases
paragraphs: Recognizing that zoonotic and animal diseases are interconnected, several  organizations—including the American Medical Association, the American  Veterinary Medical Association, and CDC—have taken steps to support the  One Health concept, which is a worldwide strategy for expanding  interdisciplinary collaboration and communications in all aspects of health  care for humans and animals. In 2007, the American Veterinary Medical  Association established the One Health Initiative Task Force to study the  feasibility of a campaign to facilitate collaboration and cooperation among  health science professions, academic institutions, governmental agencies,  and industries to help, among other things, assess, treat, and prevent  cross-species disease transmission. In 2008, the task force framed the  issue, stating that the convergence of people, animals, and the  environment has created a new dynamic in which the health of each group  is inextricably interconnected. Examples of recent diseases causing  animal, human, environmental, or economic harm are described in  appendix IV.
section_title: The National Invasive Species Council Focuses on Collaboration among Federal Agencies
paragraphs: In 1999, an executive order established the National Invasive Species  Council, cochaired by the Secretaries of Agriculture, Commerce, and the  Interior. Its members are the Secretaries and Administrators of 13 federal  departments and agencies. The council was charged with providing  national leadership; seeing that the federal invasive species activities are  coordinated, complementary, cost-efficient, and effective; and  encouraging planning and action at local, tribal, state, and regional levels.  The range of invasive species issues that the council is attempting to  address includes live animal imports that may bring diseases into the  United States. The executive order also required the Secretary of the  Interior to establish the Invasive Species Advisory Committee, a group of  30 nonfederal stakeholders from diverse constituencies (representing  state, tribal, local, and private concerns) around the nation, to advise the  council on invasive species issues. In 2008, the council issued its most  recent management plan for invasive species, the 2008-2012 National  Invasive Species Management Plan. The management plan lists goals and  performance elements that identify the federal agency with the lead or  participant role. It includes tasks pertaining to pathogens or diseases. For  example, one of the tasks is to develop a process for identifying high- priority invasive plants, animals, and plant or animal pathogens for  agencies’ actions. The council is currently preparing a progress report on  the implementation of the 2008-through-2012 plan, with an expected  completion date of October 2010.
section_title: Recent Studies Have Discussed the Regulation of Live Animal Imports
paragraphs: Studies by the National Academies of Sciences and others have found  significant deficiencies in the regulation of live animal imports that may  allow the introduction and spread of emerging zoonotic and animal  diseases. For example,    A 2005 National Academies of Sciences report referred to a “patchwork of  federal policies and agencies with limited or ill-defined jurisdiction” for  the importation of wildlife, “a significant gap in preventing and rapidly  detecting emergent diseases,” and “a lack of coordinated federal oversight”  over disease issues associated with these animals. It found that wildlife  are imported daily with little or no health monitoring, increasing the  likelihood that zoonotic or animal diseases will enter the United States.  The report also noted that the animal health infrastructure “does not have  formal and comprehensive-based science and risk analysis systems for  anticipating potential challenges to animal health; ranking their likelihood  of occurring and likely severity; evaluating alternative prevention,  detection, and diagnostic systems; and using this information to make  appropriate policy decisions.”
A 2007 study by the Defenders of Wildlife, a nonprofit organization that  supports wildlife conservation, concluded that no law mandates a  comprehensive assessment of the potential risk from the importation of a  given nonnative species to human and animal health.
In the November 2009 issue of CDC’s journal, Emerging Infectious  Diseases, scientists reported on their study of mammal imports and  concluded that these imports provide numerous opportunities for zoonotic  pathogens to enter the United States. The study recommended increased  surveillance of imported animals that pose an increased risk of harboring  zoonotic pathogens.
section_title: Gaps in the Statutory and Regulatory Framework for Some Live Animal Imports May Contribute to Disease Risks, according to Experts and Agency Officials
paragraphs: The statutory and regulatory framework governing live animal imports has  gaps that could allow the introduction and spread of zoonotic diseases and  diseases affecting wildlife, according to the experts we surveyed, our  discussions with agency officials, and scientific studies on zoonotic and  animal diseases. In particular, while APHIS has regulations in place to  protect agricultural animals from the risk of diseases in live animal  imports, CDC does not fully use its statutory authority to prevent the  importation of live animals that may pose a risk of zoonotic diseases, and  FWS generally does not restrict the entry of imported wildlife that may  pose disease risks.
subsections: section_title: APHIS Has Regulations to Protect U.S. Agriculture from Live Animal Imports That Could Carry Disease
paragraphs: APHIS has regulations to prevent the importation of live animals that it has  determined could pose a disease risk to agricultural animals. For example,  APHIS requires that commercial birds, such as those imported for resale,  breeding, or public display from countries other than Canada be  quarantined until found free of evidence of communicable diseases of  poultry. In addition, APHIS restricts the importation of certain animals  from certain countries, such as cattle from countries where foot-and- mouth disease—a highly contagious viral disease of cloven-hoofed animals  such as cattle, swine, and sheep—has been detected.
USDA’s Office of Inspector General has performed several audits of  APHIS’s live animal import processes in recent years. For example, an  August 2010 audit report identified weaknesses in the procedures APHIS  used to handle animals destined for a quarantine facility, beginning with  the precautions it took when receiving the animals into the country and  continuing to the conditions at the quarantine facilities. According to the  report, APHIS officials did not identify these weaknesses because they did  not exercise sufficient oversight to ensure import and quarantine  requirements were met. Instead, they relied on the experience and  expertise of port staff and import center officials. In addition, a 2008 audit  report on APHIS’s controls over live animal imports indicated that APHIS  relies on health certificates from the exporting country to certify the  animal’s health condition, age, and other import requirements. However,  the report stated, APHIS does not have adequate processes to determine  whether individual problems detected represent a larger systemic  noncompliance that needs to be addressed by agency inspection personnel  or the exporting country. The Inspector General recommended that APHIS  establish an automated system of records to document and track problems  with live imported animals and report these problems to key stakeholders.  According to the Inspector General, APHIS planned to implement this  recommendation and to have officials analyze data from the system each  month and communicate with stakeholders regarding corrective actions.  According to agency officials, APHIS began using this system—the  Veterinary Services Process Streamlining System—in June 2010.
We found that the agency has screening processes in place for the  imported animals it regulates that generally do not exist for other  imported animals regulated by other agencies. For example, as table 1  shows, for cattle from Canada or Mexico, APHIS is to assess whether key  diseases are present in the prospective exporting country, require a health  certificate from a veterinarian in the exporting country, and visually  inspect the cattle. In addition, for cattle not from Canada, Mexico, Central  America, or the West Indies, APHIS requires that the cattle be quarantined  to determine that they are free from disease. As the table shows, CDC and  FWS do not generally have similar processes for the animals they regulate.  (See app. V for additional types of imported animals and federal agency  disease risk screening requirements.)
Although APHIS does not regulate the importation of all live animals, most  of the experts responding to our survey supported a broader role for  APHIS. (See apps. VI and VII for more details on these experts and their  responses to the survey.) Specifically,    Fifty-three of the 55 experts responding to our survey question about  APHIS’s statutory and regulatory framework indicated that changes are  needed to prevent the importation of zoonotic and animal diseases.
Forty-eight of the 54 experts responding to a question in our survey  strongly or somewhat supported giving APHIS the authority to consider  the disease risk from wildlife as part of its existing risk assessment  process.
In 2008, APHIS took a step toward broadening its oversight of live animal  imports and becoming more responsive to emerging disease threats. It  issued a long-term strategy—known as VS2015—that identifies key  changes APHIS states are essential for the organization in 2015, including  (1) an expanded veterinary health mission and (2) an increased focus on  disease prevention, preparedness, detection, and early response  activities. Specifically,  Expanded veterinary health mission. Consistent with the One Health  concept, APHIS would expand its mission to address not only disease  issues that affect agricultural animals but also those associated with  zoonotic and wildlife diseases. According to the long-term strategy, APHIS  plans to    provide national leadership on the animal health component associated    work with wildlife entities to address health issues that affect production  agriculture and wildlife health, and  lend its veterinary assets (e.g., laboratory networks, stockpiles, and  response corps) and provide leadership in areas within its expertise (e.g.,  epidemiology, surveillance, planning, risk analysis, and modeling) when  public health issues arise involving nonnative and wildlife species.
Increased focus on disease prevention, preparedness, detection, and  early response activities. APHIS’s goal is to reduce the frequency of  disease outbreaks that affect animals by emphasizing prevention and  preparedness. According to the long-term strategy, APHIS plans to    design and direct comprehensive national animal health surveillance  systems capable of finding foreign, emerging, and known diseases, and of  supporting international reporting and trade verification requirements;  investigate potential emerging animal health threats and apply decision  criteria to determine appropriate early responses;    when needed, extend its prevention and early response efforts to address  animal health issues occurring outside of the United States, including  identifying, prioritizing, planning, and directing APHIS-funded animal  health surveillance and disease control or eradication programs carried  out overseas; and    assist other countries as they develop their animal health capacities and  provide leadership in the development of global animal health standards  and methods.
In support of VS2015, APHIS formed an internal work team that, according  to agency officials, is working on more comprehensive training of APHIS  staff; better use of technology for collaboration, communication, and data  tracking; and the engagement of industry as a more active partner.
section_title: CDC Has Regulations for Some Live Animal Imports but Does Not Prevent the Importation of Many Animals That May Pose a Risk of Zoonotic Diseases
paragraphs: CDC has regulations to prevent the importation of certain live animals that  may pose a previously identified disease risk to humans for some diseases,  such as rabies, but, according to agency officials, CDC’s regulations are  limited to specific species and regions and do not comprehensively  prevent the importation of animals that are known to present a high risk of  zoonotic diseases. That is, CDC restricts imports of some animals to  prevent the introduction of specific diseases: nonhuman primates, to  prevent the spread of tuberculosis, among other things; bats, to prevent  the introduction of a variety of infectious pathogens, including Ebola virus;  rodents from Africa, to prevent monkeypox; dogs and cats, to prevent  zoonotic diseases in general and rabies in dogs; and certain turtles, to  prevent Salmonella. In 2004, CDC banned the importation of birds from  specified countries based on the threat that imports from such countries  increased the risk that highly pathogenic avian influenza may be  introduced into the United States. In 2009, CDC rescinded this ban.  According to CDC’s notice rescinding the ban, APHIS’s import restrictions  on birds and poultry adequately address risks to human health, and CDC  will work closely with APHIS to monitor the international situation  regarding highly pathogenic avian influenza.
Even though CDC has these restrictions, imported animals that present a  zoonotic risk could enter into the United States. For example,    While CDC generally requires proof of current rabies vaccination and the  confinement of most dogs for up to 30 days after vaccination, it has  received reports of large-volume shipments of puppies intended for  immediate resale. According to agency officials, these animals often  appear younger than the age on their accompanying documents, that is,  they are too young to receive an effective rabies vaccination, and their  vaccination status is questionable. In addition, according to agency  officials, if CDC finds at ports of entry that a dog was not vaccinated for  rabies, the agency allows it to enter, if the owner agrees to keep the dog  confined until it can be properly vaccinated and then confined for an  additional 30 days following vaccination to prevent the potential spread of  rabies. However, state and local agencies that are to monitor confinement  frequently lack resources to do so, according to CDC officials.
CDC’s regulations do not require rabies vaccinations for cats, which are  highly susceptible to certain strains of rabies virus and can also transmit  the infection to humans.
In addition, experts responding to our survey told us that CDC generally  reacts only when a zoonotic disease problem arises. For example, since  the 1970s it has been well known that monkeypox, a zoonotic disease, was  endemic to Africa. However, according CDC officials, CDC did not have a  process to conduct a risk assessment on the potential movement of  monkeypox to the United States. Furthermore, they said, if such a risk  assessment process had been in place, CDC might have restricted the  importation of certain animals from Africa. After a 2003 outbreak of  monkeypox in the United States, which sickened over 70 people, CDC  restricted the importation of African rodents and other animals that may  carry the monkeypox virus. However, CDC still allows the importation of  rodents from countries outside of Africa, and these imported rodents are  not subject to examination to determine whether they may be carrying  zoonotic disease. Furthermore, according to experts responding to our  survey and CDC officials, the importation of many other wildlife species is  allowed with little or no screening for zoonotic disease risks. For example,  mice, rats, and gerbils are not screened for zoonotic diseases, but the  animal family that includes these animals has been found to harbor 21  zoonotic diseases.
CDC’s regulation of live animal imports does not sufficiently protect  against zoonotic disease risks, according to the experts responding to our  survey and scientific studies. According to 50 of the 55 experts responding  to our survey question about CDC’s statutory and regulatory framework,  changes are needed. For example, 40 of the 51 experts responding to a  question in our survey strongly or somewhat supported giving CDC the  authority to use pre-import screening, such as a process that assesses  disease risk by species and country and determines allowable imports on  the basis of that assessment. CDC is considering other regulatory  mechanisms that would allow CDC to suspend the entry of animal imports  into the United States from designated foreign countries for public health  reasons. Decisions to suspend animal imports from designated foreign  countries would be based on the existence of a communicable disease in  that country and the likelihood that allowing such imports would increase  the likelihood of introducing disease into the United States. While these  regulatory mechanisms are not specifically “pre-import screening,” these  mechanisms may serve the same purpose.
The CDC officials we interviewed acknowledged gaps in the agency’s  regulation of live animal imports for zoonotic diseases. To address this  problem, in 2007, CDC issued an advance notice of proposed rulemaking  on live animal imports to take steps to better prevent the introduction of  zoonotic disease into the United States. The questions raised in the  advance notice of proposed rulemaking include whether CDC should (1)  establish a regulation that maintains a list of species or categories of high- risk animals for which importation is restricted (e.g., either prohibited  from entry or subject to certain requirements), (2) apply these potential  restrictions to broad taxonomic groupings (e.g., all rodents) or individual  species, (3) issue these potential restrictions on a limited geographical  basis (i.e., certain countries or regions) or more broadly, and (4) make  rabies vaccination a requirement for entry into the United States for all  dogs and cats. CDC is currently analyzing the comments that it received,  revising the proposed language, and conducting economic analyses. CDC  expects to publish a notice of proposed rulemaking in 2011.
section_title: Although FWS Has Regulations for Injurious Wildlife, It Does Not Restrict the Entry of Imported Wildlife That May Pose Disease Risks
paragraphs: Under the authority of the Lacey Act, FWS has implemented regulations to  restrict imports of various types of nonnative live animals that have been  identified as injurious wildlife because, for example, they could become  invasive. However, FWS’s regulations allow other types of wildlife to enter  the United States with little assessment of the disease risk or health status  of the animal, despite the possible presence of diseases in animals that are  not endemic to the United States. For example, FWS does not restrict the  importation of live amphibians or assess their risk for the presence of  disease, creating a risk that the Bd fungus (Batrachochytrium  dendrobatidis)—which causes a highly contagious disease that is  potentially fatal to amphibians—will continue to enter and spread. The  Department of the Interior has been petitioned by the Defenders of Wildlife  to ban imports of live amphibians unless they are free of the Bd pathogen.  As of September 2010, the department planned to gather information from  the public before deciding whether to develop a regulation in response to  this petition. Furthermore, the Lacey Act’s process to ban the importation of  injurious wildlife often requires too much time for the process to be  effective, according to FWS officials and experts responding to our survey.  On average, it takes about 4 years for FWS to identify a species or group of  species as injurious wildlife. During this time, the animals in question  continue to be imported into the United States.
In addition, according to FWS officials, FWS inspectors visually inspect  some live wildlife imports, which may include observation for signs of  disease, but they are not veterinarians, and they do not have expertise in  detecting diseased animals. Furthermore, experts responding to our  survey said that visual inspections have limited effectiveness in detecting  diseased animals. They noted that it is often difficult to distinguish  between a healthy, uninfected animal and an apparently healthy but  infected animal, and even healthy animals can carry pathogens that could  harm other species or humans but not harm the host.
In written comments to our survey, some experts reported that the Lacey  Act should be amended to better prevent the importation of live animals  that pose disease risks, while other experts said FWS should use its  current authority to improve its regulations in this area. According to 52 of  the 55 experts responding to our survey question about FWS’s statutory  and regulatory framework, changes are needed. Of the 53 experts who  responded to our survey questions about specific potential changes, 44  strongly or somewhat supported giving FWS the authority to use pre- import screening, and 43 strongly or somewhat supported having FWS  expedite the process for classifying species as injurious wildlife.
The Department of the Interior has taken preliminary steps that may  address gaps in FWS’s regulation of live animal imports. In addition to  reviewing the petition to restrict amphibian imports, in January 2010, the  Secretary of the Interior directed FWS to comprehensively review  statutory authorities and regulations to address existing invasive species  problems and to recommend potential tools to more effectively prevent  the introduction of new invasive threats. According to Department of the  Interior testimony provided at a March 2010 hearing on invasive species,  FWS is reviewing several proposals to create a more proactive and  comprehensive approach to preventing the spread of invasive species,  including streamlining the evaluation process, examining gaps that the  Lacey Act’s injurious wildlife provisions leave in the listing process,  revising its risk assessment process, and supporting improved regulatory  and educational approaches.
section_title: Agencies Have Collaborated to Meet Their Responsibilities, but Experts and Agency Officials Identified Barriers to Further Collaboration
paragraphs: APHIS, CBP, CDC, and FWS have collaborated to meet their  responsibilities by taking actions in five areas—strategic planning, joint  strategies, written procedures, leveraging resources, and sharing data— but experts responding to our survey and agency officials we interviewed  identified barriers to further collaboration on live animal imports. As we  have previously reported, agencies encounter a range of barriers when  they attempt to collaborate with other agencies. Experts also identified  the need for an entity to help the agencies overcome these barriers.
subsections: section_title: Although Agencies Have Collaborated to Meet Common Goals, They Face Barriers to Additional Collaboration
paragraphs: Strategic planning. APHIS, CBP, CDC, and FWS have engaged in strategic  planning that recognizes the need for joint efforts to reduce the risks of  zoonotic and animal diseases from live animal imports. Specifically,  according to APHIS’s 2007-through-2012 strategic plan, it is working with  CBP to reduce pest and disease threats at the borders. The strategic plan  also states that the agency’s risk assessment protocols must recognize the  growing importance of zoonotic diseases and the need to work with public  health agencies to reduce the risk of these diseases. Within APHIS, the  program office of Veterinary Services’ strategic plan—VS2015—states that  Veterinary Services intends to meet future animal health challenges, such  as emerging zoonotic and animal diseases, by 2015. According to this plan,  Veterinary Services will expand its mission to include public health  concerns connected to any type of animal. In addition, the plan states that  Veterinary Services will work with wildlife entities to address health issues  that affect the health of both agricultural animals and wildlife. Such  collaboration would involve working with CDC and FWS. According to  CBP’s strategic plan for 2009 through 2014, CBP is actively pursuing new  relationships with CDC to enhance CBP’s response to public health  threats. CDC officials told us that it has identified a strategic goal to  enhance CDC’s ability to prevent, detect, and respond to zoonotic diseases  associated with the importation of live animals. Furthermore, according  to FWS’s law enforcement strategic plan for 2006 through 2010, increased  coordination will be required with agencies (such as CDC and APHIS) that  are responsible for addressing linkages between wildlife trade and the  cross-border spread of zoonotic and animal diseases.
As we have previously reported, federal agencies can use their strategic  and annual performance plans as tools to drive collaboration with other  agencies and partners and establish complementary goals and strategies  for achieving results. While the agencies’ strategic planning addresses  some concerns about the disease risk from live imported animals, it does  not specify how they will collaborate to address the risk of disease from  live animal imports. Such specificity is difficult, according to several  experts responding to our survey, in part because the agencies’ program  priorities are based on different missions, constituencies, and priorities. In  particular, experts responding to our survey noted that because each of  the agencies is focused on a different aspect of live animal imports, no  single entity has comprehensive responsibility for the zoonotic and animal  diseases risks posed by live animal imports. As one expert noted, the  principal barrier to collaboration is agencies’ “failure to take a broader  view of the entire importation process,” focusing instead on only those  components of the process each agency controls under its statutory  authority. As we have previously reported, when agencies do not have a  compelling rationale, such as legislation, directives, or their perceptions of  the benefits from collaboration, it is difficult to overcome differences in  missions and priorities and to define and articulate a common outcome  that is consistent with their respective agency missions. However, as the  One Health concept recognizes, human and animal diseases are  interconnected. In this regard, the federal agencies that are responsible for  live animal imports appear to have a common goal—preventing the  introduction and spread of zoonotic and animal diseases from live animal  imports.
Joint strategies to reduce disease risk from imported live animals.  Several of the agencies we reviewed participated in joint strategies to  directly or indirectly address risks posed by imported live animals. For  example,    APHIS, FWS, and the Department of Commerce’s National Oceanic and  Atmospheric Administration jointly developed the National Aquatic  Animal Health Plan in 2008. Under this plan, the agencies are to prepare  coordinated research and development strategies and budget  recommendations to provide a framework for how the three agencies  should develop programs for diseases that affect the health of aquatic  animals, including finfish, crustaceans, and mollusks. Activities  addressed in the plan include (1) defining pathogens of national concern;  (2) preventing, controlling, and managing pathogens or the diseases  caused by those pathogens; (3) describing and implementing surveillance  programs; and (4) describing strategies for continued outreach and  awareness regarding national aquatic animal health strategies and the  plan. As of July 2010, an advisory committee was being formed and a  surveillance network had been established for viral hemorrhagic  septicemia, a deadly infectious fish disease that affects 28 susceptible  species of fresh and saltwater fish and is a growing threat in the Great  Lakes region. While this plan is not fully launched, experts responding to  our survey commented that the effort has strengthened collaboration  among international, federal, and state partners. According to the  Department of the Interior, this plan is a model for federal cooperation  with regard to movement of aquatic animal diseases, and it will be  broadened to include amphibians and reptiles in the future.
The National Invasive Species Council’s 2008-2012 National Invasive  Species Management Plan, which is the council’s primary coordination  tool for the prevention and control of invasive species, includes an  objective to expand the coordination of invasive species programs and  expenditures to leverage resources. It also directs the relevant agencies to  update the budget for federal agencies’ expenditures concerning invasive  species. The council expects to report on the plan’s progress in October  2010. APHIS, CBP, and FWS have participated in the council since its  inception, while CDC has recently rejoined the group.
The Aquatic Nuisance Species Task Force—an intergovernmental  organization composed of 13 federal agencies, including FWS, APHIS, and  the Department of Commerce’s National Oceanic and Atmospheric  Administration—is working to prevent and control aquatic nuisance  species. The task force was established by the Nonindigenous Aquatic  Nuisance Prevention and Control Act of 1990. In 2007, the task force  developed a strategic plan for 2007 through 2012 that includes an objective  for analyzing and evaluating rapid response plans, including plans for  foreign animal disease events, to see how they could apply to reported  introductions of invasive species. In addition, the task force and the  National Invasive Species Council have identified various pathways by  which pathogens can be introduced into the country. These pathways  include container water in which aquatic animals are transported.  According to FWS officials, this container water can contain pathogens  and, in some instances, importers may not disinfect the water before  disposing of it.
In 2009, APHIS, CBP, CDC, and several southern California animal  agencies formed a task force to address issues with the importation of  puppies, such as reducing and eliminating the illegal smuggling and selling  of dogs that are underage, in poor health, or do not have the required  health certifications.
These strategies are positive steps toward furthering the common goal of  preventing disease risk from live animal imports. As we have previously  reported, collaborating agencies need to establish strategies that work in  concert with those of their partners or are joint in nature. Such strategies  help in aligning the partner agencies’ activities, core processes, and  resources to accomplish the common outcome. In addition, all 56 experts  responding to our survey indicated that it is very or moderately important  for the federal agencies to collaborate to develop a coordinated national  strategy to better align activities, processes, and resources.
According to the experts responding to our survey, the agencies develop  joint strategies to respond quickly to emergencies as they arise, but the  agencies tend to develop joint strategies in reaction to an identified  problem, rather than in anticipation of it. For example, one expert noted  that the outbreak of monkeypox in 2003 spread to prairie dogs and  subsequently to humans. The expert, as well as CDC officials, commented  that although this outbreak was addressed promptly, it might have been  avoided if officials had considered the risk of this disease and taken  appropriate actions before an outbreak occurred.
Several studies and CDC officials also cited the need for a formal joint  strategy to prevent the introduction of zoonotic and animal diseases, such  as a comprehensive risk assessment system, and for responding to health  risks, such as having plans and resources for early detection and response.  Experts also commented that the development of such a system should  focus on how live animal imports affect the health of humans, agricultural  animals, and wildlife. Moreover, the 2005 National Academies of Sciences  report noted that the animal health infrastructure does not have formal  and comprehensive science-based risk analysis systems for anticipating  potential challenges to animal health. In addition, experts responding to  our survey commented that a comprehensive risk assessment system  should be established on the basis of an analysis of imported animals to  assess the threat that these animals pose. The experts stated that the  components of this risk assessment system might include an analysis of  the species’ exporting country, diseases of concern, typical packaging and  delivery times, and methods of shipment of concern, among other things.  Suggested uses of the risk assessment include targeting passengers and  cargo most likely to be carrying prohibited animals, and making decisions  based on this information. According to experts responding to our survey,  agencies could use this information to determine whether the importation  of particular species from certain countries should be banned and which  animals require pre-import screening, including the increased use of  disease testing and quarantine at the ports of entry. For example, such risk  assessment could be similar to APHIS’s process, which assesses the  disease risk within defined regions on a consistent and scientific basis and  evaluates the animal health status of countries or regions requesting  approval to import live animals into the United States.
Written procedures for ports of entry. The four agencies have written  procedures to follow when working with other federal agencies at ports of  entry. In particular, three of the agencies—APHIS, CBP, and FWS—signed  a memorandum of understanding (MOU) on forfeiture that lays out the  specific roles and responsibilities each has for seizing, quarantining, and  disposing of birds that are brought into the United States in violation of  laws or regulations. In addition, APHIS and CBP signed an MOU that  outlines the agencies’ roles for entry and inspection of the imported  animals that APHIS regulates. Two of the four agencies—APHIS and  CBP—also have other types of written procedures, while CDC is  developing guidance, according to CDC officials. Specifically,    APHIS has guidance that outlines the procedures and responsibilities that  its division of Veterinary Services is to follow with CBP in handling legally  and illegally imported pet and performing birds arriving as passenger  baggage, from when the birds arrive at the port of entry until they are  released to enter into the United States or refused entry. For example, the  guidance specifies which birds are eligible for entry and which agency is  responsible for (1) transferring birds to a quarantine station and (2)  obtaining supplies for handling the birds.
CBP has a standard operating procedure that informs its staff at ports of  entry of procedures to follow in handling shipments of APHIS-regulated  live fish. Specifically, if the species has been approved by APHIS for  import, CBP staff are to allow it to proceed; if the species has not already  been approved, then the staff are to hold the shipment for Veterinary  Services; if the species is not regulated by APHIS, CBP is to hold the  shipment for USDA’s Agricultural Marketing Service, which administers  programs that facilitate the marketing of U.S. agricultural products.
CBP and APHIS have written guidance for coordinating their processing of  live animals arriving at Canadian land border ports of entry.
CBP and APHIS have written procedures for the importation of livestock  at four Mexican land border ports of entry and certain cattle at all Mexican  land border ports of entry.
CBP has written procedures to help its port staff make appropriate  referrals to other agencies.
According to CDC officials, the agency is developing internal standard  operating procedures to distribute to its staff at ports of entry on CDC- regulated animals. The officials said the first such guidance will be on how  to handle imported turtles, although the officials did not know when this  guidance would be issued.
While the agencies have developed some written procedures, officials told  us that they do not have written procedures for all animal imports. In the  absence of written procedures, agencies collaborate informally at ports of  entry on how to handle incoming shipments. Specifically, according to  FWS headquarters officials we spoke with, FWS and CDC port officials  regularly coordinate on physical inspections of live animals they both  regulate, such as nonhuman primates, turtles and tortoises, and bats. For  example, according to CBP officials, when turtles are imported into the  United States, CBP usually contacts FWS inspectors. According to FWS  officials, if the type of turtle being imported is not banned, FWS may  contact CDC or APHIS for inspection or further action if it believes there  is potential for another type of violation, such as undersized turtles that  pose a risk for Salmonella (CDC) or turtles with ticks that may have  Heartwater infection (APHIS), a potentially fatal disease to cattle. In  addition, officials at ports of entry from CBP and APHIS told us that they  usually have access to an official from another agency to speak with if  questions arise about a shipment. For example, CBP officials at several  ports told us they contact APHIS, CDC, and FWS officials informally  through e-mails, telephone calls, and in person in order to verify that  procedures are being followed for live animal imports they regulate.  Finally, some experts responding to our survey noted that officials at some  ports have cultivated effective collaborative relationships.
However, we have previously reported that by using informal coordination  mechanisms, agencies may rely on relationships with individual officials to  ensure effective collaboration and that these informal relationships could  end once personnel move to their next assignments. Without written  procedures, agencies’ roles and responsibilities are not clearly defined. We  reported that agencies can strengthen their commitment to work  collaboratively by articulating their roles and responsibilities in formal  documents to facilitate decision making. Such formal documents can  include MOUs, interagency guidance, or interagency planning documents,  signed by senior officials in the respective agencies. These documents can  clarify which agencies will be responsible for particular activities, and how  they will organize their joint and individual efforts.
Experts responding to our survey generally agreed that uncertainty about  agencies’ roles and responsibilities for imported animals is a barrier,  particularly for species that are (1) not regulated for disease risk by any  agency or (2) regulated by more than one agency. For example, several of  the experts noted that federal regulations do not address the risk to  human and animal health posed by the importation of most nonnative wild  animals, such as non-African rodents, and that where regulations do allow  for the import of nonnative wild animals, no disease assessment is made.  In addition, the agencies do not have written procedures for all species  that are regulated by more than one agency, such as reptiles. For example,  APHIS and FWS do not have a written procedure to coordinate their  shared responsibilities for regulating reptiles—which are a source of  Salmonella infection in humans and also carry disease-causing parasites.
Leveraging resources. APHIS, CBP, CDC, and FWS have taken steps to  leverage resources—staff and funding—to enhance their ability to address  disease risks associated with live animal imports. For example,    APHIS has provided CDC headquarters with a liaison to represent USDA’s  interests on a broad range of topics, including live animal imports, and  shares information with CDC on zoonotic diseases. CDC officials stated  that they are currently exploring the possibility of establishing a DHS  liaison.
APHIS, FWS, the U.S. Coast Guard, and the Department of Commerce’s  National Oceanic and Atmospheric Administration worked together to  launch two national campaigns designed to help the public understand its  role in preventing the introduction and spread of zoonotic and animal  diseases. The first campaign, called “Stop Aquatic Hitchhikers,” is directed  toward the public who engage in aquatic activities to, among other things,  prevent the spread of invasive species, zoonotic diseases, and animal  pathogens. The second campaign, “Habitattitude,” is directed toward,  among others, pet owners to promote environmentally friendly behaviors,  such as not releasing nonnative pets into the environment.
While the agencies have worked together to leverage their resources, they  do not separate the amount of funding and level of staff for live animal  imports from other agency activities. As a result, they may not be able to  determine whether their funding and staff are sufficient, and the extent to  which they could be leveraged in a collaborative effort. Furthermore, the  four agencies vary significantly in the extent to which they have resources  for regulating live animal imports, according to agency officials and  experts responding to our survey. For example, APHIS has staff who  perform services—such as review of information provided by foreign  governments—to support assessments of the risk of live animal imports  into the United States. In addition, APHIS has quarantine facilities that  inspect and test imports for diseases prior to an animal being released into  the United States. In contrast, FWS does not have similar resources for  assessing risk and has no quarantine facilities. The experts responding to  our survey also noted that resource constraints, such as limited facilities  and staff, make it difficult for the four agencies to devote enough time to  collaboration when they face time constraints in completing daily tasks.  The experts responding to our survey noted that under these conditions it  is challenging for the agencies to collaborate.
As we have previously reported, collaborating agencies should identify the  human, information technology, physical, and financial resources needed  to initiate or sustain their collaborative effort. By assessing their relative  strengths and limitations, collaborating agencies can look for  opportunities to obtain additional benefits that would not be available if  they were working separately. Forty-nine of the 54 experts who responded  to a survey question about leveraging resources strongly or somewhat  supported leveraging APHIS resources to assist FWS in preventing the  importation of animal diseases, and 48 indicated that APHIS resources  should be leveraged to assist CDC in preventing the importation of  zoonotic diseases. In addition, according to APHIS officials we spoke with,  APHIS has expertise that could assist FWS and CDC in assessing disease  risks in other countries. Furthermore, 50 of 56 experts responding to our  survey reported that it is very or moderately important for federal agencies  to collaborate to develop a plan to maximize existing resources.
Data sharing. As we have reported, agencies can facilitate collaboration  by coordinating data information systems for carrying out shared  objectives. According to CBP officials, the agency is developing the  International Trade Data System (ITDS) within the Automated  Commercial Environment (ACE) system. ACE will serve as a Web-based  portal for exchanging trade information among federal agencies that share  the responsibility for facilitating international trade. Currently, APHIS  and FWS can access data, such as importer data and other related  information, but cannot enter information into the system. In its 2009  Report to Congress on the International Trade Data System, CBP stated  that agencies participating in ITDS, including APHIS, CDC, and FWS, have  formed working groups to ensure, among other things, that data elements  are identified and specified to the detail necessary in shipment  information. For example, according to agency officials, a working group  of agencies that use data on or oversee imported eggs was formed. While  agencies do not yet have access to an integrated data system, agency  officials and experts responding to our survey identified efforts to share  data. For example, FWS has shared its data with CDC to identify possible  health risks from imports of nonnative wildlife. In addition, according to  APHIS officials, the agency is beginning to implement terminology in its  trade database that is consistent with CBP’s so that the agencies can share  information about incoming shipments.
According to CBP officials, APHIS, CDC, FWS and other agencies will  ultimately be able to enter and retrieve information using the ACE system.  However, CBP officials do not have a target date for when APHIS, CBP,  CDC, and FWS would have full operational access to ACE, and they stated  that a unified data system has been a goal since 1995; ITDS has been  ongoing since 2006. In addition, while the agencies participating in ITDS  have formed workgroups for some types of trade data, APHIS, CBP, CDC,  and FWS have yet to jointly determine which data elements are needed for  them to effectively oversee live animal imports, according to CBP officials.  As a result, it is unclear whether the data in the completed system will  meet interagency needs.
Until ITDS is completed, the agencies responsible for live animal imports  continue to collect and rely on data that are not easily shared. Experts  responding to our survey pointed out that the agencies have not linked  their data systems so that they can share information on live animal  shipments, as well as track violations. In particular, APHIS and FWS  maintain separate databases that contain information on shipments of  animals that they regulate, and CBP maintains a database on all imports,  including live animals. However, the three databases do not interface, so  that agencies regulating the same shipment of live animals can have access  to the same information at the same time.
section_title: Experts Responding to Our Survey Identified the Need for an Entity to Help the Agencies Overcome Barriers to Collaboration
paragraphs: The experts responding to our survey, including federal and state agency  officials, also generally pointed to the need for some formal entity to help  overcome barriers to achieving their common interest in preventing the  importation of animals that may be carrying zoonotic or animal diseases.  For example, one expert observed that such an entity could help the  agencies identify gaps and inconsistencies in the overall regulation of live  animal imports for zoonotic and animal diseases and enable the agencies  to collaborate regularly, and 53 of 56 experts responding to our survey  reported that it was very or moderately important for the agencies to  collaborate to identify gaps in regulations related to live animal imports.  We asked the experts about the extent to which they would support the  creation of a workgroup to help the federal agencies collaborate in  preventing the importation of animals that may be carrying zoonotic and  animal diseases. Most of the experts responding to this question—52 of  55—strongly or somewhat supported the creation of such a workgroup.  (See app. VII for the experts’ detailed responses.)
section_title: APHIS, CDC, and FWS Have Reported Some Information on Their Performance on Live Animal Imports
paragraphs: APHIS and FWS routinely report information on their performance to  oversee the importation of live animals, and CDC has reported  performance information for one species. CBP does not report any  performance information on live animal imports. As we have previously  reported, agencies can use performance information to make decisions  oriented toward improving results. In that same report, we stated that  federal managers can use performance information to identify  performance problems and look for solutions, develop approaches that  improve results, and make other important management decisions,  including those that affect future strategies, planning and budgeting,  identifying priorities, and allocating resources.
APHIS. APHIS has reported performance information on live animal  imports that aligns with the goals it established in its strategic plan for its  Veterinary Services program office. Specifically, APHIS measured  progress on its performance goal of protecting the United States from the  occurrence of adverse animal health events. For example, APHIS reported  that in fiscal year 2009 it conducted risk assessments on the animal health  status of at least 14 foreign countries that have been denied access to U.S.  import markets. In fiscal year 2009, APHIS conducted risk analyses in the  European Union for the presence of exotic Newcastle disease, highly  pathogenic avian influenza, and classical swine fever—a highly contagious  virus that can cause high mortality rates in swine populations.  Additionally, APHIS reported that in fiscal year 2009 it did not have any  disease outbreaks associated with imports of animals from foreign regions  that APHIS has reviewed for animal health status.
CBP. CBP has not reported any performance information on live animal  imports. As we previously noted, however, it has agencywide and field  operations strategic plans that recognize the agency’s role in preventing  the importation of zoonotic and animal diseases.
CDC. In general, CDC has not developed comprehensive performance  information on live animal imports. However, CDC has reported on  mortality rates for one live animal import—nonhuman primates. In its 2008  annual performance report, CDC reported that this mortality rate was less  than 1 percent for fiscal years 2005, 2006, 2007, and 2008, down from about  20 percent before 1989. CDC attributed this improvement to its instituting  facility inspections and new infection control requirements. In that same  report, CDC reported on its performance goal of maintaining low mortality  in nonhuman primates imported to the United States for science,  exhibition, and educational purposes to, for example, reduce the potential  exposure of humans to zoonotic diseases, such as Ebola and  tuberculosis.
FWS. FWS reported performance information dealing with live wildlife  imports in its 2008 operational plan. In this plan, FWS reported on the  number of injurious wildlife interdicted at international ports of entry and  land borders (270), number of shipments that contained injurious wildlife  (54), the number of wildlife shipments physically inspected (31,000), and  the number of interdicted wildlife shipments (4,000). This information  supports FWS’s performance goal of preventing the unlawful import,  export, and interstate commerce of foreign fish, wildlife, and plants in its  law enforcement strategic plan for 2006 through 2010.
section_title: Conclusions
paragraphs: With the growth in emerging zoonotic diseases, as well as the risk of other  animal diseases in an increasing global marketplace, federal agencies play  an increasingly important role in preventing the introduction of these  diseases into the United States. However, as we found, gaps in the  statutory and regulatory framework across federal agencies increase the  risk that some live animal imports will carry diseases into the United  States, as was the case for African rodents carrying monkeypox in 2003. Of  the three agencies responsible for regulating live animal imports for  disease risks—APHIS, CDC, and FWS—only APHIS comprehensively  assesses an animal’s disease risk or health status, and APHIS has issued a  strategy for expanding its role in overseeing nonagricultural animals. In  contrast, CDC and FWS have gaps in their oversight of disease risks from  live animal imports. CDC’s regulations direct its focus to particular species  or diseases, and the agency does not have a process for identifying risks  from some emerging diseases that could be imported in live animals. FWS  generally does not restrict the entry of imported wildlife that may pose  disease risks and does not generally assess the disease risk or health  status of these animals. Experts responding to our survey indicated that  changes are needed in FWS’s statutory authority, its regulations, or both.  Recognizing such issues, APHIS, CDC, and FWS have separately proposed  additional actions to better protect against disease risks from live  imported animals, including actions that may involve pre-import  screening.
The four agencies we reviewed have collaborated to meet their  responsibilities to some extent. They have recognized the need to work  together in their strategic planning, formulated some joint strategies,  developed some written procedures for collaboration, leveraged resources  in some situations, and shared some data on live animal imports. However,  experts responding to our survey and agency officials identified barriers to  further collaboration in each of these areas. These barriers—such as  different program priorities and unclear roles and responsibilities—are  inherent when multiple agencies have related responsibilities.  Furthermore, the agencies have largely incompatible data systems, and it  appears that some time will pass before these issues are resolved or ACE  is able to offer a conduit for data sharing among APHIS, CBP, CDC, and  FWS. Because the agencies have not determined which data they will  need, it is also unclear whether the data elements in the latest version of  ACE will meet interagency needs. While these barriers pose a challenge,  the agencies still have a common interest in preventing the introduction of  diseases from live animal imports. Recognizing this common interest, the  experts responding to our survey, including federal and state officials,  reported that increased collaboration through some type of formal entity,  such as a workgroup, is needed to help overcome these barriers.  Furthermore, the experts and the National Academies of Sciences noted  that the absence of a risk assessment system for comprehensively  addressing disease risks from live animal imports could result in zoonotic  and animal diseases entering the United States.
section_title: Recommendations for Executive Action
paragraphs: To better prevent the importation of live animals carrying zoonotic and  animal diseases and improve the responsible agencies’ collaboration, we  recommend that the Secretaries of Agriculture, Health and Human  Services, Homeland Security, and the Interior take the following two  actions:    Develop and implement, in coordination with the relevant federal  agencies, a strategy for their collaboration in preventing the importation of  animals that may be carrying zoonotic and animal diseases into the United  States. This strategy should help the agencies  Identify and resolve differing program priorities so that the agencies  can work collaboratively to ensure that live animal imports posing a  risk of zoonotic and animal diseases do not enter the United States.  Such efforts could include collaborative methods for prevention, such  as a comprehensive risk assessment system for live animal imports.
Lay out individual agency roles and responsibilities for all live animal  imports, including how a collaborative effort will be led.
Identify resources dedicated to live animal imports and leverage these  resources to the extent possible to support the agencies’ efforts.
Examine ways to systematically share data on shipments of live animal  imports that are regulated by more than one agency until ACE is able to  offer data-sharing capabilities to each agency.
Explore the need for any additional legislative or executive authority to  develop and implement this strategy such as the authority to establish a  coordinating entity (e.g., an interagency workgroup).
Jointly determine, in collaboration with CBP, the data elements that  APHIS, CDC, and FWS will need ACE to contain, so that the agencies can  effectively oversee all live animal imports.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to USDA, the Department of Health and  Human Services, DHS, and the Department of the Interior for their review  and comment. In their written comments, USDA, DHS, and the  Department of the Interior generally agreed with our findings and  recommendations. The Department of Health and Human Services only  provided technical comments, which we included as appropriate.
USDA agreed with our recommendations and commented that it  appreciates our emphasis on increasing the level of collaboration among  federal agencies. USDA also commented that it believes a key component to  successfully leveraging the agencies’ strengths lies in finding new ways to  approach these opportunities and that it therefore supports the formation of  an interdepartmental steering committee for the oversight of animal imports  as soon as possible. USDA also stated that in collaboration with the  committee and other departments, it would seek to determine the need for  creating additional authority, clarify the scope of existing authority, and  implement current authority more efficiently through expanded  memorandums of agreements or other interdepartmental cooperative  measures. Furthermore, USDA stated that it would report to us on the  components of a successful strategy for addressing our recommendations.  USDA’s written comments are presented in appendix VIII.
DHS also agreed with our recommendations and stated that it would work  with the other departments to gauge interest in development of a joint  strategic implementation plan. In addition, DHS described its existing  collaborative efforts with APHIS, CDC, and FWS, with respect to live  animal import processes and agencies’ data needs. DHS’s written  comments are presented in appendix IX, and we incorporated DHS’s  technical comments as appropriate.
The Department of the Interior agreed with our findings and  recommendations. In addition, the department provided the following  comments:    While GAO asked experts whether a workgroup should be created to help  federal agencies collaborate, GAO did not consider whether an existing  body could perform this function. The use of an existing interagency body  to serve as a coordinating entity to help federal agencies prevent the  importation of animals that may be carrying zoonotic and animal diseases  was not mentioned in experts’ responses to the first round of our survey,  which was the basis for asking this question. Placing a coordinating entity  for live animal imports within an existing interagency body may help avoid  duplication of effort. If the agencies determine that it is appropriate to  place the coordinating entity for live animal imports within an existing  interagency body, this response would be consistent with our  recommendation.
The report does not refer to possible confusion that may be caused by  multiple agencies having related authorities, and the report could have  provided more information on agency outreach to the public. However, as  the department noted, the issue of public outreach was not a central  question of our review.
The report should emphasize the National Aquatic Animal Health Plan as a  model for federal cooperation with regard to movement of aquatic animal  diseases. We believe the report recognizes this plan, stating that it is an  example of federal agencies’ joint strategies to reduce disease risks from live  animal imports, and provided more information on the plan’s relevant efforts.
The Department of the Interior’s written comments and our responses are  presented in appendix X.
We are sending copies of this report to the appropriate congressional  committees; the Secretaries of Agriculture, Health and Human Services,  Homeland Security, and the Interior; the Director, Office of Management  and Budget; and other interested parties. The report is also available at no  charge on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-3841 or shamesl@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix XI.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines the (1) potential gaps in the statutory and regulatory  framework governing live animal imports, if any, that may allow the  introduction and spread of zoonotic and animal diseases; (2) extent to  which the U.S. Department of Agriculture’s Animal and Plant Health  Inspection Service (APHIS), Department of Homeland Security’s Customs  and Border Protection (CBP), Department of Health and Human Services’  Centers for Disease Control and Prevention, (CDC), and Department of the  Interior’s Fish and Wildlife Service (FWS) collaborate to meet their  responsibilities and face barriers, if any, to collaboration; and (3) the  performance information that the responsible agencies have reported on  live animal imports.
To identify potential gaps in the statutory and regulatory framework, we  reviewed relevant statutes, including the Animal Health Protection Act, the  Public Health Service Act, the Lacey Act, and the Endangered Species Act  of 1973; the agencies’ implementing regulations; and agency documents on  the procedures employed to regulate the importation of live animals from  APHIS, CBP, CDC, and FWS. We interviewed officials from these agencies  at agency headquarters and ports of entry. Using information from  interviews of agency officials and agency documents, we compared the  level of inspection and review used by each of the agencies to regulate the  importation of various types of animals, including mammals, birds, fish,  and reptiles. In addition, we reviewed scientific studies on zoonotic and  animal diseases, including studies by the National Academies of Sciences.
We also reviewed APHIS and FWS data on the number, type, and  exporting country of all imported animals regulated by these two agencies  that entered the United States for fiscal years 2005 through 2009. For the  APHIS and FWS data, we analyzed documentation related to the data and  worked with agency officials to identify any potential data problems and  determined that the data were sufficiently reliable for the purposes of  providing background information in this report. We analyzed the APHIS  and FWS data to determine the number of animals imported each fiscal  year, the countries from which animals are most frequently imported, and  the purposes for which animals are most frequently imported.
To examine the extent to which the agencies collaborate to meet their  responsibilities and face barriers, if any, to collaboration, we reviewed  strategic plans, memorandums of understanding, standard operating  practices, and other policies and protocols from each of the four agencies.  We also reviewed joint strategies developed by interagency working  groups, such as the National Invasive Species Council’s management plan  and the National Aquatic Animal Health Plan. We interviewed agency  headquarters officials and agency officials at ports of entry, including  airports in Atlanta, Georgia; Baltimore, Maryland; Los Angeles, California;  New York, New York; and Washington, D.C.; and the Otay Mesa,  California, and San Ysidro, California, land border crossings between  California and Mexico, on ongoing and planned efforts for coordination.  We obtained documentation on the allocation of staff resources. Finally,  we assessed the agencies’ collaboration efforts according to practices we  identified that can help enhance and sustain collaboration among federal  agencies.
To help address the first two objectives, we conducted a two-round survey  to identify (1) potential gaps in the current statutory and regulatory  framework that may allow for the introduction of and spread of zoonotic  and animal diseases, (2) how well the responsible federal agencies work  together to meet their responsibilities, and (3) potential barriers to  collaboration. The process we followed is based on GAO guidance for  identifying experts for panels or other work requiring expertise in a specific  area. We identified potential experts on disease risk posed by live animal  imports who had primary employment responsibilities related to or  dependent on live animal imports, authored peer-reviewed papers,  presented at professional conferences, provided testimony on the subject  matter to Congress, or were recognized by their peers as experts on live  animal imports. We then selected experts from federal and state  government, academia, nongovernmental organizations, and industry to  obtain a broad spectrum of views. We conducted pretests with several  survey recipients prior to distributing both surveys. The goals of the pretests  were to ensure that (1) the questions were clear and unambiguous and (2)  terminology was used correctly. The first round of the survey consisted of  five open-ended questions (questions that solicit additional information) in  which experts provided their opinions on gaps in the current statutory and  regulatory framework, how well the responsible federal agencies work  together to meet their responsibilities, and potential barriers to  collaboration. In the first round, we received responses from 33 out of the  39 experts contacted, resulting in a response rate of about 85 percent.
We performed a content analysis of the responses to the open-ended  questions in order to compile a list of gaps in the statutory and regulatory  framework, corrective actions to address those gaps, the effectiveness of  federal agencies’ collaboration, and barriers to federal agencies’  collaboration mentioned by the experts. We used this list to construct the  second round of survey questions. These were primarily closed-ended  (questions with a set of answers to choose from). We expanded our  second round of the survey to include additional experts recommended by  those responding to our first round and other experts. Of the 64 experts  we contacted, 56 provided responses, resulting in a response rate of about  88 percent in the second round.
The first round of the survey was conducted from January through  February 2010, and the second round was conducted from April through  May 2010. To the extent possible, we followed up with experts to clarify  their responses. The questions and aggregated responses are presented in  appendix VII. Responses to the survey express only the views of the  experts.
To examine what performance information the responsible agencies  report on live animal imports in their planning and reporting documents,  we reviewed strategic plans, operational plans, mission statements, and  annual performance plans and reports from APHIS, CBP, CDC, and FWS.  Review of these documents allowed us to determine the extent to which  these agencies set out performance goals, established measures to assess  performance toward achieving those goals, and reported on the  effectiveness of their efforts for activities directly involving live animal  imports. We analyzed the extent to which each of the four agencies used  performance objectives and measures and reports on the effectiveness of  these activities for live animal imports.
We conducted this performance audit from August 2009 through October  2010, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Agencies’ Processes for Overseeing Live Animal Imports
paragraphs: This appendix describes the processes that the U.S. Department of  Agriculture’s Animal and Plant Health Inspection Service, Department of  Homeland Security’s Customs and Border Protection, Department of  Health and Human Services’ Centers for Disease Control and Prevention,  and Department of the Interior’s Fish and Wildlife Service use for  processing live animal imports for entry into the United States.
APHIS restricts the importation of live animals that it has determined may  pose a disease risk to agricultural animals, such as cattle, horses, poultry,  sheep, and swine. APHIS has developed import processes that depend on  the level of risk associated with either the type of animal or country of  export. APHIS has a memorandum of agreement with CBP whereby CBP  refers live animal shipments to APHIS port veterinarians for inspection.  APHIS port veterinarians visually inspect all applicable live animal  shipments and review the import documentation, which may include a  declaration of importation, vaccination records, and health certificates  from a licensed veterinarian in the country of export. APHIS requires that  most imported animals that it regulates be accompanied by a health  certificate. A licensed veterinarian in the country of export inspects the  animals and then signs the health certificate certifying the health status of  the animals and whether U.S. requirements are met. The most common  type of certification states that the animals to be imported were inspected  and determined to be free of communicable disease.
If the animals do not pass inspection, the animals are either quarantined  and then reinspected or are refused entry. For example, if cattle from  Mexico fail a visual inspection for tick-free status, they are dipped and  quarantined for 10 to 14 days and then presented for a second inspection.  If ticks are found during the second inspection, the cattle will be rejected,  branded as rejected, and sent back to Mexico. For those animals that  require quarantine, such as horses, importers are required to reserve space  at either an APHIS-managed animal import center or an APHIS-approved  private quarantine facility. During the quarantine, the animal undergoes  disease testing. Animals that test positive for a regulated disease are  refused entry into the United States.
APHIS has established processes for specific animals and exporting  countries. For example, for imports from Canada and Mexico, APHIS has  established streamlined processes, such as eliminating requirements for  permits or quarantine for some animals. Additionally, commercial birds— birds that are imported for resale, breeding, or public display—entering  the United States through a land border from Canada are not required to  have a permit or undergo quarantine, as long as they are accompanied by a  veterinary health certificate from a Canadian government veterinarian.  Commercial birds not imported from Canada are required to be  quarantined and tested for avian influenza. In some instances, APHIS  restricts the importation of animals based on risk. For example, APHIS  restricts the import of commercial birds from countries with highly  pathogenic avian influenza and cattle from countries with foot-and-mouth  disease. An example of species-specific regulation can be found with  imports of fish susceptible to Spring viremia of carp; such species include  the common carp and goldfish. APHIS checks that these imports have the  required documents, visually checks the shipments to ensure that they are  not leaking or emitting an atypical odor, and assesses the animals’ disease  status if the shipment is chosen for inspection.
APHIS relies on a manual process to account for and track the movement  of the live animal imports from CBP to APHIS inspection at the border and  to their final destination. According to agency officials, APHIS is  developing an automated data system, the Veterinary Services Process  Streamlining System, which is expected to replace the existing manual,  paper-oriented process and will track live animal imports, exports,  interstate movement of animals, and veterinary accreditation. According  to APHIS officials, the new system became operational in June 2010 and  will be able to track live animal imports in calendar year 2011.
CBP assists APHIS, CDC, and FWS in enforcing their import regulations,  has the primary authority to inspect imports, and seeks to interdict  shipments of contraband and the illegal importation of live animals and  other products while facilitating the flow of legal trade and travel. If there  is a problem with a particular shipment, CBP will levy the appropriate  fines and penalties.
CBP requires importers to file entry documents that describe the  merchandise, quantity, value, and exporting country, among other things,  and a Harmonized Tariff Schedule classification, which is a schedule of  tariffs associated with individual products. All entry documents must be  filed before the imported goods are allowed to be released into U.S.  commerce. For faster release, importers or their brokers may provide CBP  with pre-arrival notification of an incoming shipment by submitting  information on the shipment locally or electronically submitting  information on the shipment to either CBP’s legacy computer system, the  Automated Commercial System, or the Automated Commercial  Environment, the agency’s replacement system. CBP screens the incoming  information through its information systems to verify if the shipment  meets the criteria or requires further examination or inspection. According  to agency officials, if CBP then determines that further inspection is  needed by APHIS, FWS, or CDC, CBP will hold the shipment, provide  minimal custodial care, and contact the relevant agency. According to  agency officials, CBP holds the shipment until an agency representative of  the other government agency is available to inspect and release it.  According to agency officials, if an agency representative is unavailable,  then CBP denies entry of the shipment.
CDC restricts the importation of live animals that it has determined pose a  risk to public health and bans the importation of certain animals. All live  animal imports on which CDC has placed import restrictions are to be  visually examined by the inspecting personnel to ensure that the animal  has no obvious signs of infectious diseases. Dogs and cats that show signs  of infectious diseases are to be examined, tested, or treated by a licensed  veterinarian at the owner’s expense. According to agency officials, other  CDC-regulated animals that show signs of infectious diseases, such as  nonhuman primates, are inspected at an import facility. For many of the  animal imports restricted by CDC, the agency requires a permit for  importation. Imports that are restricted to these purposes and require a  permit include African rodents, civets, live bats, and shipments of more  than six turtles with a shell length of less than 4 inches. For nonhuman  primates only, CDC requires that persons or facilities importing such  animals be registered with CDC. If the shipment has the required  documents, it is released to a registered importer. Nonhuman primates are  quarantined for 31 days after entry on the importer’s premises. No permit  is required for the importation of dogs and cats. Generally dogs greater  than 3 months of age from countries where rabies is present must have a  valid certificate of vaccination against rabies signed by a licensed  veterinarian showing that the dog was vaccinated greater than or equal to  30 days prior to import. If the dog is more than 3 months old and does not  have a vaccination certificate, the dog may be admitted if the owner agrees  to confine the dog until vaccination, vaccinate the dog within 4 days upon  arrival at the ports of entry, and then confine the dog for an additional 30  days following vaccination. If the dog is more than 3 months old and has a  certificate showing a vaccination done less than 30 days prior to arrival,  the dog may be admitted if the owner signs an agreement to confine the  dog for the balance of 30 days. If the dog is less than 3 months old, the dog  may be admitted if the owner signs an agreement to confine the dog until it  is 3 months old, and then have it vaccinated and confined for an additional  30 days. Confinement is defined as restricting the animal to a building or  other enclosure, in isolation from other animals and people, except for  contact necessary for its care. If the dog is allowed out of the enclosure,  the owner must muzzle the dog and use a leash. After agreeing to these  conditions, the dog is released and the agreement is forwarded to a CDC  quarantine station. The rabies vaccination requirement does not apply to  dogs that have been exclusively in a rabies-free area for at least 6 months  immediately preceding arrival or since birth. Cats are only required to pass  visual inspection.
FWS has restrictions on the importation of certain wildlife. Specifically,  FWS restricts the importation of injurious wildlife and threatened or  endangered species and related species for which international trade is  regulated under international agreements. According to agency officials,  FWS inspectors work with public health officials and other federal  inspectors at ports of entry to enforce wildlife regulations and ensure the  safety and legality of wild animal imports. According to agency officials,  FWS inspectors coordinate with the other agencies to ensure that the  requirements for animals that are jointly regulated by FWS and APHIS  and/or CDC have been met, such as APHIS prohibitions on hedgehogs that  can transmit foot-and-mouth disease or CDC inspection requirements for  small turtles. Importers of wildlife shipments generally must provide FWS  with a 48-hour notice of the shipment’s arrival. Commercial importers of  wildlife must be licensed by FWS.
According to agency officials, the following processes occur at the port of  entry. The shipment is declared at the port of entry, and FWS reviews the  accuracy and consistency of the required documents, which depend on  species and can include declaration forms, permits, import/export  licenses, invoices, and packing lists. Following documentation review,  FWS inspectors then decide if a physical inspection is required. Common  reasons for inspecting shipments include the type of live animal, exporting  country, importer history, intelligence on the shipment, outcome of  documentation review, or random selection. If the shipment fails a  physical inspection, FWS either seizes the animals with the violations and  releases the remainder of the shipment or seizes the entire shipment,  based on the type of animal or violation. If the shipment passes physical  inspection and has the required documentation, then FWS clears the  shipment. If the shipment is not selected for physical inspection and the  required documentation is present, then FWS clears the shipment.
section_title: Appendix III: Data on the Number of Live Animals Imported in Recent Years
paragraphs: APHIS and FWS provide information on the number of live animal  imports, the purpose of the animal import, and the country from which the  import has been shipped for recent years. APHIS’s Import Tracking  System records the number of APHIS-regulated animals imported by fiscal  year. FWS’s Law Enforcement Management Information System records  the number of FWS-regulated animals imported by fiscal year. The APHIS  and FWS data systems may overlap because both agencies regulate some  of the same species, such as certain fish and birds. CDC does not maintain  a database on live animal imports.
Table 2 shows the number of APHIS-regulated animals imported for fiscal  years 2005 through 2008.
Prior to fiscal year 2007—when APHIS began recording large numbers of  fish imports—APHIS recorded that imports of live swine, poultry, and  cattle were about 99 percent of its regulated live animal imports. About 94  percent of these imports came from Canada, with the remainder generally  coming from Mexico. These animals were primarily imported for slaughter  plants or farms. By fiscal year 2008, imports of fish represented about half  of the total number of APHIS live animal imports, with the largest  suppliers of these animals, including China, Malaysia, Hong Kong, the  United Kingdom, Thailand, and Singapore, primarily importing these fish  for commercial purposes. According to agency officials, APHIS reported  large numbers of fish beginning in fiscal year 2007 because of a new  regulation on the import of fish, which previously were not required to  have APHIS permits and thus were not counted by APHIS. In August 2006,  APHIS issued regulations requiring importers of species of fish that are  susceptible to Spring viremia of carp, a contagious, fatal viral disease, to  obtain an APHIS permit prior to importation into the United States.
Table 3 shows the number of FWS-regulated live wildlife imported from  2005 through 2009. FWS officials attributed the decline of live animal  imports in fiscal year 2009 in part to the recession, as well as the increase  in FWS user fees, which included new handling fees.
In fiscal year 2009, wildlife imports came from a variety of countries and  were primarily imported for commercial purposes. For example,  Singapore and Thailand were the leading exporters for fish, Haiti and  Taiwan for crustaceans, amphibians from Taiwan, mollusks from  Indonesia and the Philippines, insects from Costa Rica, reptiles from  Vietnam, corals from Indonesia, mammals from Canada and the  Netherlands, birds from Senegal, spiders from Ghana, and worms from  Canada and France.
Although mammals represent a small percentage of FWS-recorded imports  of live wildlife excluding imports of fish—ranging from 0.3 percent in 2005  to 2.5 percent in 2008—they are commonly associated with the spread of  zoonotic diseases. The following describes FWS-regulated imported  mammals and their associated disease risks, according to FWS data for  fiscal year 2009:    Bovines, including bison and water buffalo, with 201,561 imported  primarily from Canada for commercial purposes. The animal family that  includes bovines has been found to harbor 15 zoonotic diseases, including  Ebola and Rift Valley fever.
Mice, rats, and gerbils, with 141,060 imported primarily from the  Netherlands for commercial purposes. The animal family that includes  these animals has been found to harbor 21 zoonotic diseases.
Old world monkeys, with 24,106 imported primarily from China for  biomedical research. The animal family that includes these animals has  been found to harbor 13 zoonotic diseases, including yellow fever and  Marburg disease.
Chinchillas, with 4,302 imported primarily from Canada and the  Netherlands for commercial purposes. The animal family that includes  chinchillas has been found to harbor 2 zoonotic diseases: rabies and  monkeypox.
section_title: Appendix IV: Examples of Recent U.S. Animal Disease Outbreaks Causing Animal, Human, and Environmental or Economic Harm
subsections: section_title: Three cases of bovine spongiform encephalopathy in cattle have been identified from 2003 through 2006, one of which was caused by an imported cow.
paragraphs: Transmitted to cattle  through contaminated  feed containing, for  example, the spinal cord  or brain matter of  infected cattle.  Transmitted to humans  through eating the  contaminated meat of  infected cattle.
Bovine spongiform  encephalopathy is  transmitted to humans  causing a variant form of  Creutzfeldt-Jakob disease.
An estimated $11 billion  in losses in U.S. exports  resulted from bovine  spongiform  encephalopathy-related  restrictions in the United  States.
From 2003 through 2007,  three fatal variant  Creutzfeldt-Jakob cases  occurred in two United  Kingdom citizens and one  Saudi Arabian citizen who  were residing in the United  States. They were likely  exposed to bovine  spongiform  encephalopathy in their  native countries.
May have been  introduced through a  shipment to northern  California in the late  1950s or early 1960s.
Caused by an aquatic  fungal pathogen,  Batrachochytrium  dendrobatidis (Bd).
Bd is an emerging  infectious disease of  amphibians, especially  frogs.
Bd is responsible for a  large disease-caused  loss of biodiversity.
Has been linked with  serious declines  almost everywhere  that amphibians are  present, including  North America.
Bd appears to be  spreading through the  international amphibian  trade, the international  pet trade, the bait trade,  and inadvertently in  produce.
An outbreak of the  disease occurred in  the western United  States from  September 2002  through September  2003.
Transmitted by infected  birds, contaminated  people, and  contaminated equipment  to other birds.
The 2002-through-2003  outbreak resulted in nearly  4.5 million birds destroyed.
Humans can be infected  with Newcastle virus and  infection generally causes  conjunctivitis (i.e., pink  eye). Most often, those  affected are workers in the  poultry industry or  laboratory technicians who  handle the virus.
As a result of the 2002- through-2003 outbreak,  over 50 countries  imposed some form of  trade restriction against  United States poultry  exports. The outbreak  caused an estimated  $395 million loss in  direct and indirect trade.  Federal dollars allocated  to the eradication effort  are estimated at $138.9  million.
In February 2004, an  outbreak of highly  pathogenic avian  influenza was  detected and reported  in a flock of 7,000  chickens in south- central Texas. This  was the first outbreak  of highly pathogenic  avian influenza in 20  years.
Transmitted by infected  birds.
By mid-2005 in southeast  Asia, more than 140  million birds had died or  been destroyed.
By mid-2005 in  southeast Asia, losses to  the poultry industry were  estimated to be in  excess of $10 billion.
Despite control measures,  the disease continues to  spread, resulting in animal  and human fatalities (more  than half of the human  cases have been fatal).  Many in the scientific  community are concerned  about a global pandemic  of human avian influenza. .
First outbreak  occurred in 1988 and  affected marine fish in  the Pacific Northwest.
Transmission is by  infected fish, tissues  from infected fish, and  water that has contained  infected fish.
Viral hemorrhagic  septicemia is known to  cause fish mortality,  particularly for rainbow  trout, turbot, and herring,  in short periods of time.
Although large numbers  of fish loss have been  reported, long-term  economic loses are  unclear.
Outbreaks of a more  virulent strain of viral  hemorrhagic  septicemia began  occurring in United  States waters of the  Great Lakes in 2006.
Ballast water is  considered the most  likely original vector.
APHIS currently lists 28  susceptible species.
To meet federal and  state regulations,  aquaculture facilities  incur additional testing  expenses to ensure their  fish are healthy.
Emerged in 1999 and  has been found  throughout the  continental United  States.
Transmitted by  mosquitoes and can  cause encephalitis in  humans.
West Nile virus in the  United States has infected  29,766 people, resulting in  1,166 fatalities from 1999  through August 10, 2010.
The estimated economic  impact of the disease in  the United States from  1999 through 2007 was  $400 million.
section_title: Appendix V: Overview of Federal Agencies’ Disease Risk Screening for Selected Types of Imported Animals
paragraphs: Visual inspection  at U.S. port of  entry for disease  CBP does not develop regulations for how to import an animal, so it is not included in the list of  regulating agencies.
Feeder cattle from Mexico, which are cattle imported for the purpose of feeding for a period of time  prior to slaughter, are tested for tuberculosis and brucellosis and checked for ticks prior to entry into  the United States. Breeding cattle are tested for tuberculosis and brucellosis and checked for ticks.
APHIS, FWS, and CDC do not perform this type of screening for this imported animal.
APHIS does not have any regulations in place to assess the disease risk of turtle imports. APHIS  prohibits the importation of the following types of turtles: leopard tortoise, African spurred tortoise, and  Bell’s hingeback tortoise.
FWS does not screen all shipments of turtles for disease risk. It requires 48-hour notification of the  shipment and shipment declaration forms, which provide a description of the animals in the shipment.  FWS visually inspects some live animal shipments (e.g., 18 percent in fiscal year 2008). The purpose  of the inspection is to determine whether the animals are on the Lacey Act’s list of prohibited injurious  animals or are prohibited from entry based on the Endangered Species Act of 1973 and international  agreements to regulate threatened or endangered species, such as the Convention on International  Trade in Endangered Species of Wild Fauna and Flora—as well as to assess whether the turtles are  in compliance with APHIS and CDC regulations.
section_title: Appendix VI: Experts Responding to Our Survey on Live Animal Imports
paragraphs: This appendix provides the affiliations of federal and state government,  academics, nongovernmental, and industry experts who completed one or  both rounds of a two-round survey from January 2010 to May 2010 to  identify potential gaps in the current statutory and regulatory framework,  how well the responsible federal agencies work together to meet their  responsibilities, and appropriate corrective actions.
Biological Scientist, Centers for Epidemiology and Animal Health,  Veterinary Services, U.S. Animal and Plant Health Inspection Service    Senior Advisor for Science and Policy, U.S. Department of Homeland    State Public Health Veterinarian and Assistant State Epidemiologist,  Infectious Disease Epidemiology, Office of Public Health, Louisiana  Department of Health and Hospitals    Director, Veterinary Regulatory Support, Plant Protection and Quarantine,  U.S. Animal and Plant Health Inspection Service    Veterinary Medical Officer, Western Region Import and Export  Coordinator, Veterinary Services, U.S. Animal and Plant Health Inspection  Service    Professor, Department of Veterinary Pathology, College of Veterinary  Medicine, University of Georgia    Policy Director, Global Invasive Species Programme    Director, Science Center, Natural Resources Defense Council    Virginia M. Ullman Professor, Arizona State University    Executive Vice President and General Director for Living Institutions,    Director of Regulatory Affairs, Taylor Shellfish Company, Inc.
Veterinary Medical Officer, National Wildlife Health Center, U.S.
National Director, Veterinary Medicine, PETCO Animal Supplies, Inc.
Senior Veterinarian, Los Angeles County Department of Public Health,  Veterinary Public Health and Rabies Control Program    Associate Vice President, Conservation Medicine, Wildlife Trust    Professor and Director, Southeastern Cooperative Wildlife Disease Study,    Chief, Division of Management Authority, International Affairs Program,  U.S. Fish and Wildlife Service    Special Agent in Charge, Office of Law Enforcement, U.S. Fish and Wildlife    Professor of Epidemiology, Department of Pathobiological Sciences,  School of Veterinary Medicine, University of Wisconsin-Madison    Branch Chief, Convention on International Trade in Endangered Species  Operations, Division of Management Authority, U.S. Fish and Wildlife  Service    Executive Director, Global Initiative for Food Systems Leadership and  Professor, School of Public Health and College of Veterinary Medicine,  University of Minnesota    Director, National Center for Import and Export, Veterinary Services, U.S.
Animal and Plant Health Inspection Service    Director of International Conservation, Defenders of Wildlife    Senior Wildlife Veterinarian and Supervisor, California Department of Fish    Fish and Wildlife Biologist, Branch of Aquatic Invasive Species, U.S. Fish    Wildlife Health Specialist, Arizona Game and Fish Department    Professor of International Health and of Medicine, Boston University    Public Health Veterinarian, National Association of State Public Health  Veterinarians    Associate Professor of Biology, and Director, Program in Sustainable  Development and Conservation Biology, Department of Biology,  University of Maryland    Branch Chief, Quarantine and Border Health Services Branch, U.S. Centers  for Disease Control and Prevention    Chief, Branch of Aquatic Invasive Species, U.S. Fish and Wildlife Service    Professor, School for Global Animal Health, Executive Director,  Washington Animal Disease Diagnostic Laboratory, Director, Animal  Health Research Center, Washington State University College of  Veterinary Medicine    Professor of Pathology, Western University of Health Sciences College of    Vice President of Veterinary Services, Chicago Zoological Society    Branch Chief, Agriculture Production, Office of Health Affairs, U.S.
Assistant Director, Live Animal Imports, National Center for Import and  Export, U.S. Animal and Plant Health Inspection Service    Chairman, Health and Regulatory Committee, American Horse Council    Amphibian and Reptile Coordinator, Association of Fish and Wildlife    Research Branch Chief, Arizona Game and Fish Department    Wildlife Veterinary Specialist, Wildlife Disease Laboratory, Michigan  Department of Natural Resources and Environment    Vice President, Government Affairs, Association of Zoos and Aquariums    Executive Director, Association of American Veterinary Medical Colleges    Epidemiologist, (formerly) Johns Hopkins Bloomberg School of Public  Health, Johns Hopkins University    Operations Specialist, Delta Air Lines, Inc.
Manager, Live Animals and Perishables, Special Cargo Standards,    Coordinator, Wildlife Management Division, Arizona Game and Fish    Postdoctoral Research Fellow, Center for Forest Sustainability, School of  Forestry and Wildlife Sciences, Department of Biological Sciences, Auburn  University    General Manager, Koppert Biological Systems, Inc.
Supervisor, Wildlife Health Section, Wildlife Disease Laboratory, Michigan    Eastern Region Import Export Coordinator, Veterinary Services, U.S.
Animal and Plant Health Inspection Service    Assistant Director Zoonotic, Influenza and Vector Borne Disease Unit,  Bureau of Communicable Disease, New York City Department of Health  and Mental Hygiene    Assistant Research Professor, Ecology and Evolutionary Biology, Brown    Assistant Director for Field Programs, Global Health Program, Wildlife    Outreach Coordinator, Fisheries and Habitat Conservation, Branch of  Invasive Species, U.S. Fish and Wildlife Service    State Public Health Veterinarian and Section Manager, Zoonoses and  Special Projects Section, Michigan Department of Community Health    Acting Director Agriculture Policy and Planning, Agriculture Programs and  Trade Liaison, Office of Field Operations, U. S. Customs and Border  Protection    Vice President, Conservation and Science, Lincoln Park Zoo    Director, Planning, Finance, and Strategy Staff, Veterinary Services, U.S.
Animal and Plant Health Inspection Service    Corporate Vice President, Veterinary and Professional Services, Charles  River Laboratories, Inc.
section_title: Appendix VII: GAO Survey Questions and Responses
subsections: section_title: Expert Survey: Live Animal Imports into the United States and the Spread of Animal and Zoonotic Diseases
paragraphs: We conducted a two-round survey to identify (1) potential gaps in the  current statutory and regulatory framework that may allow for the  introduction of and spread of zoonotic and animal diseases, (2) how well  the responsible federal agencies work together to meet their  responsibilities, and (3) potential barriers to collaboration. We identified  potential experts on disease risk posed by live animal imports who had  primary employment responsibilities related to or dependent on live  animal imports, authored peer-reviewed papers, presented at professional  conferences, provided testimony on the subject matter to Congress, or  were recognized by their peers as experts on live animal imports. We then  selected experts from federal and state government, academia,  nongovernmental organizations, and industry to obtain a broad spectrum  of views. The first round of the survey consisted of five open-ended  questions (questions that solicit additional information) in which experts  provided their opinions on gaps in the current statutory and regulatory  framework, how well the responsible federal agencies work together to  meet their responsibilities, and potential barriers to collaboration. In the  first round, we received responses from 33 out of the 39 experts contacted,  resulting in a response rate of about 85 percent. We performed a content  analysis of the responses to the open-ended questions in order to compile  a list of gaps in the statutory and regulatory framework, corrective actions  to address those gaps, the effectiveness of federal agencies’ collaboration,  and barriers to federal agencies’ collaboration mentioned by the experts.  We used this list to construct the second round of survey questions. These  were primarily closed-ended (questions with a set of answers to choose  from). We expanded our second round of the survey to include additional  experts recommended by those responding to our first round and other  experts. Of the 64 experts we contacted, 56 provided responses, resulting  in a response rate of about 88 percent in the second round. The first round  of the survey was conducted from January through February 2010, and the  second round was conducted from April through May 2010. While this  appendix displays only the quantitative, closed-ended responses, we also  relied on the responses to the qualitative, open-ended questions to inform  our findings in this report. The views expressed by the experts responding  to our surveys do not necessarily represent the views of GAO.
section_title: Round One Questions
paragraphs: 1.  What weaknesses or gaps, if any, do you feel exist in the statutory and  regulatory framework governing live animal imports with respect to  preventing the introduction of zoonotic and animal diseases?  2.  What corrective actions should be taken to address these weaknesses  or gaps?  3.  Federal agencies responsible for live animal imports include Animal  and Plant Health Inspection Service (APHIS), Centers for Disease  Control and Prevention (CDC), Customs and Border Protection (CBP),  and Fish and Wildlife Service (FWS). How effectively (or not) do the  federal agencies collaborate to meet their responsibilities?  4.  What barriers exist for collaboration among federal agencies?  5.  During our site visits with regulatory authorities, we heard about their  goal to facilitate efficient cargo and passenger import processing while  preventing prohibited animals and animal products to be imported into  the United States. What is the best way to ensure that statutes and  regulations prevent importation of zoonotic and animal diseases  without impeding commerce and passenger travel?  6.  If you consulted with others within your agency, firm, or organization  when answering the questions, how many others did you consult?
subsections: section_title: Your Background
paragraphs: 7. Please briefly describe your expertise. Include professional credentials,  membership and roles in professional associations, titles of publications,  congressional testimonies, primary employment responsibilities related to  or dependent on live animal imports, etc.
section_title: Round Two Questions and Responses
subsections: section_title: Section 1: Participant Status
paragraphs: 1.  What is your full name?  2.  What is your title?  3.  What is the name of your organization?  4.  What is your telephone number?  5.  What is your e-mail address?  6.  Did you complete a survey in round 1 or are you a new participant in  Round 2?
I completed a survey in Round #1 – Skip to question #8    I am a new participant in Round #2 – Continue to question #7  7.  What is your background or expertise related to live animal imports?
section_title: Section 2: Animal and Plant Health Inspection Service (APHIS)
paragraphs: 8.  Based on your knowledge of APHIS’s statutory and regulatory  framework, do you believe changes ARE or ARE NOT needed to  prevent the importation of zoonotic and animals diseases?
section_title: 9. How much, if at all, do you support or oppose the following potential changes for APHIS to prevent the
paragraphs: importation of zoonotic and animal diseases?
Don’t  know No response One expert provided two responses, “Strongly support” and “Somewhat support” for question 9C.
section_title: Section 3: Centers for Disease Control and Prevention (CDC)
paragraphs: 10.  Based on your knowledge of CDC’s statutory and regulatory  framework, do you believe changes ARE or ARE NOT needed to  prevent the importation of zoonotic diseases?
section_title: 11. How much, if at all, do you support or oppose the following potential changes for CDC to prevent the
paragraphs: importation of zoonotic diseases?
section_title: Section 4: Fish and Wildlife Service (FWS)
paragraphs: 12.  Based on your knowledge of FWS’s statutory and regulatory  framework, do you believe changes ARE or ARE NOT needed to  prevent the importation of zoonotic and animal diseases?
section_title: 13. How much, if at all, do you support or oppose the following potential changes for FWS to prevent this
paragraphs: importation of zoonotic and animal diseases?
section_title: Section 5: Interagency Collaboration
paragraphs: 14.  Based on your knowledge of the current statutory and regulatory  framework, do you believe a centralized agency should be created to  regulate all live animal imports?
15.  Within which of the following should a centralized agency be placed?
Animal and Plant Health Inspection Service (APHIS)
Customs and Border Protection (CBP)
Centers for Disease Control and Prevention (CDC)
Fish and Wildlife Service (FWS)
16.  How much, if at all, do you support or oppose the creation of a  workgroup to help federal agencies collaborate in preventing the  importation of zoonotic and animal diseases?  17.  How important, if at all, is representation from the following entities on such a workgroup?
18. What other entities, if any, should be included on such a workgroup?
Answers included American College of Laboratory Animal Medicine;  American Medical Association; American Veterinary Medical Association;  Association of Fish and Wildlife Agencies; Council of State and Territorial  Epidemiologists; county departments of public health; Defenders of  Wildlife; Food and Agriculture Organization of the United Nations;  International Union for the Conservation of Nature; National Association  of State Public Health Veterinarians; National Institutes of Health; National  Science Foundation; Pet Industry Joint Advisory Council; U.S. Agency for  International Development; U.S. Coast Guard, U. S. Department of Health  and Human Services Office of Global Health Affairs; U.S. Department of  State; The Wildlife Society; Wildlife Disease Association; Wildlife Trust.  19.  How important, if at all, are the following activities for a workgroup to help federal agencies collaborate in  preventing the importation of zoonotic and animal diseases?
20.  Based upon your knowledge of interagency collaboration at ports of  entry, do you believe communications among the agencies are  adequate?
section_title: 21. How important, if at all, are the following activities to improve interagency communications?
paragraphs: 22.  Based upon your knowledge of interagency collaboration at ports of  entry, do you believe training among the agencies is adequate or  inadequate?
section_title: 23. How important, if at all, are the following activities to improve interagency training?
section_title: Section 6: Enforcement of Regulations
paragraphs: 24  How important, if at all, are the following enforcement actions to  prevent the importation of zoonotic and animal diseases?
section_title: Section 7: Agency Data Used for Live Animal Imports
paragraphs: 25.  How important, if at all, is making the following data accessible on the  Web?
section_title: Section 8: Other Comments
paragraphs: 26. What comments, if any, do you have about the issues discussed in this  survey?  27. What other live animal import concerns, if any, do you have that we  have not discussed?
section_title: Appendix VIII: Comments from the U.S. Department of Agriculture
section_title: Appendix IX: Comments from the Department of Homeland Security
section_title: Appendix X: Comments from the Department of the Interior
paragraphs: The following are GAO’s comments on the Department of the Interior’s  letter.
subsections: section_title: GAO Comments
paragraphs: 1.  In the report, we state that federal agencies face a range of barriers  when they attempt to collaborate with other agencies and that these  barriers can confuse and frustrate program customers. In addition, as  the Department of the Interior notes, this issue was not part of our  objectives.  2.  Our report does not attempt to describe all of the pathways by which  live animal imports could introduce diseases into the United States.  However, we modified the report to include a reference to container  water in which aquatic animals are transported as a potential pathway.  3.  In the report, we state that the National Aquatic Animal Health Plan is  an example of federal agencies’ joint strategies to reduce disease risks  from live animal imports. We have added language to provide more  information on this plan’s relevant efforts.  4.  We revised the report to reflect this comment by deleting from the  highlights page the reference to FWS’s review of a petition on  amphibians.  5.  We added language to the highlights page to clarify that FWS was  directed to review statutory authorities and regulations to address  existing problems associated with nonnative live animals.  6.  We added language to the report to clarify that imported live animals  are used for additional purposes.  7.  We modified language in the report to clarify that FWS’ authority to list  organisms as injurious wildlife is not limited to live animals.  8.  We modified the report to attribute a description of CBP’s processes to  CBP officials only.  9.  We modified the report to clarify that FWS regulates all wildlife.  10.  We did not change the language because it is a quote from the cited  National Academies of Sciences report that we attributed.  11.  We modified the report to clarify that the Bd pathogen is a fungus.
12.  We modified the report to clarify that FWS is revising its risk  assessment procedures.  13.  The National Invasive Species Council’s activities to help federal  agencies collaborate are described in the report. We added information  on the Invasive Species Advisory Committee, which works closely with  the National Invasive Species Council. In addition, we added  information on the Aquatic Nuisance Species Task Force.  14.  The use of an existing interagency body to serve as a coordinating  entity to help federal agencies prevent the importation of animals that  may be carrying zoonotic and animal diseases was not mentioned in  experts’ responses to the first round of our survey, which was the basis  for our second round of survey questions. Placing a coordinating entity  for live animal imports within an existing interagency body may help in  avoiding duplication of effort. We recommended the development and  implementation of a strategy to help the agencies explore the need for  any additional legislative or executive authority to develop and  implement this strategy, such as the authority to establish a  coordinating entity (e.g., an interagency workgroup). If the agencies  determine that it is appropriate to place the coordinating entity for live  animal imports within an existing interagency body, this response  would be consistent with our recommendation.  15.  We modified the report to clarify that agencies focus on only those  components of the process each agency controls under its statutory  authority. As noted in the report, in January 2010, the Secretary of the  Interior directed FWS to comprehensively review statutory authorities  and regulations.  16.  We modified the report to add that an evaluation of the amount of  FWS’s funding and level of staff for live animal imports has occurred.  17.  We modified the report to clarify that FWS requires that all carriers  transporting wild mammals and birds to the United States have a  certificate of veterinary medical inspection signed by a veterinarian.
section_title: Appendix XI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Thomas M. Cook, Assistant  Director; Kevin S. Bray; Gary T. Brown; Elizabeth Curda; Mary Denigan- Macauley; Elizabeth Dunn; Jeanette Jacobs; Mitchell Karpman; Diane G.  LoFaro; Terry Richardson; Cynthia Saunders; Carol Herrnstadt Shulman;  Kathryn A. Smith; Kiki Theodoropoulos; and Megan M. Taylor made key  contributions to this report.
section_title: Related GAO Products
paragraphs: National Security: Key Challenges and Solutions to Strengthen  Interagency Collaboration. GAO-10-822T. Washington, D.C.: June 9, 2010.
Language Access: Selected Agencies Can Improve Services to Limited  English Proficient Persons. GAO-10-91. Washington, D.C.: April 26, 2010.
Biosurveillance: Developing a Collaboration Strategy Is Essential to  Fostering Interagency Data and Resource Sharing. GAO-10-171.  Washington, D.C.: December 18, 2009.
Food Safety: Agencies Need to Address Gaps in Enforcement and  Collaboration to Enhance Safety of Imported Food. GAO-09-873.  Washington, D.C.: September 15, 2009.
Seafood Fraud: FDA Program Changes and Better Collaboration among  Key Federal Agencies Could Improve Detection and Prevention.  GAO-09-258. Washington, D.C.: February 19, 2009.
Veterinarian Workforce: Actions Are Needed to Ensure Sufficient  Capacity for Protecting Public and Animal Health. GAO-09-178.  Washington, D.C.: February 4, 2009.
Natural Resource Management: Opportunities Exist to Enhance Federal  Participation in Collaborative Efforts to Reduce Conflicts and Improve  Natural Resource Conditions. GAO-08-262. Washington, D.C.: February  12, 2008.
National Animal Identification System: USDA Needs to Resolve Several  Key Implementation Issues to Achieve Rapid and Effective Disease  Traceback. GAO-07-592. Washington, D.C.: July 6, 2007.
Avian Influenza: USDA Has Taken Important Steps to Prepare for  Outbreaks, but Better Planning Could Improve Response. GAO-07-652.  Washington, D.C.: June 11, 2007.
Homeland Security: Management and Coordination Problems Increase  the Vulnerability of U.S. Agriculture to Foreign Pests and Disease.  GAO-06-644. Washington, D.C.: May 19, 2006.
Results-Oriented Government: Practices That Can Help Enhance and  Sustain Collaboration among Federal Agencies. GAO-06-15. Washington,  D.C.: October 21, 2005.
Managing for Results: Barriers to Interagency Coordination.  GAO/GGD-00-106. Washington, D.C.: March 29, 2000.
Agency Performance Plans: Examples of Practices That Can Improve  Usefulness to Decisionmakers. GAO/GGD/AIMD-99-69. Washington, D.C.:  February 26, 1999.
Agencies’ Annual Performance Plans Under the Results Act: An  Assessment Guide to Facilitate Congressional Decisionmaking.  GAO/GGD/AIMD-10.1.18. Washington, D.C.: February 1998.
Wildlife Protection: Fish and Wildlife Service’s Inspection Program  Needs Strengthening. GAO/RCED-95-8. Washington, D.C.: December 29,  1994.